(182 days)
No
The document explicitly states "Mentions AI, DNN, or ML: Not Found" and the device description focuses on electrical stimulation, not data processing or algorithmic decision-making.
Yes.
The device is specifically stated to provide "therapeutic relief for chronic, intractable pain" by utilizing pulsed electrical current for stimulation, directly aiming to treat a medical condition.
No.
The device is described as a Spinal Cord Stimulator (SCS) System intended to provide therapeutic relief for chronic, intractable pain by utilizing pulsed electrical current. It is used to treat pain, not to diagnose a condition. The "trial devices" are used to "determine efficacy before recommendation for a permanent device," which is a form of treatment assessment, not diagnosis.
No
The device description explicitly states the system is comprised of an implantable stimulator, receiver component, and an externally worn transmitter, which are all hardware components.
Based on the provided text, this device is not an IVD (In Vitro Diagnostic).
Here's why:
- Intended Use: The intended use is for the treatment of chronic, intractable pain of the trunk and/or lower limbs through spinal cord stimulation. This is a therapeutic intervention, not a diagnostic test performed on samples taken from the body.
- Device Description: The device is an implantable stimulator system that delivers electrical current to nerves. This is a physical therapy device, not a device used to analyze biological samples.
- No mention of in vitro testing: The text does not describe any process involving testing samples (like blood, urine, tissue) outside of the body.
IVD devices are used to examine specimens derived from the human body to provide information for diagnostic, monitoring, or compatibility purposes. This device does not fit that description.
N/A
Intended Use / Indications for Use
The Freedom Spinal Cord Stimulator (SCS) System is intended as the sole mitigating agent, or as an adjunct to other modes of therapy used in a multidisciplinary approach for chronic, intractable pain of the trunk and/or lower limbs, including unilateral or bilateral pain.
The Freedom-8A Trial Lead Kit is only used in conjunction with the Freedom-8A Stimulator Receiver Kit, and the Freedom-4A Trial Lead Kit is used for either the Receiver Kit Freedom-4A or the Receiver Kit Freedom-8A Stimulator. The trial devices are solely used for trial stimulation (no longer than 30 days) to determine efficacy before recommendation for a permanent (long term) device.
Product codes
GZB
Device Description
This premarket notification submission is identical to K180981, but includes updates to widen the available range of stimulation parameters to:
- A. Repetition Rate: 5 Hz to 10 kHz;
- B. Pulse Width: 30 us to 1000 us.
No design modifications to the Freedom SCS System of K180981 were made in support of this premarket notification submission. Updates to the labeled product specifications do not change the intended use, indications for use, or adversely affect device safety or effectiveness as compared to the legally marketed predicate device.
The Stimwave Technologies Incorporated (Stimwave) Freedom Spinal Cord SCS System (System) is used for spinal column stimulation to provide therapeutic relief for chronic. intractable pain of the trunk and/or lower limbs including unilateral or bilateral pain. The therapy utilizes pulsed electrical current to create an energy field that acts on nerves near the spinal column. The System is comprised of an implantable stimulator (Freedom-8A/4A Stimulator), receiver component (Receiver), and an externally worn transmitter (Wearable Antenna Assembly (WAA)) to power the device. The System is implanted only following a successful trial period with the Freedom-8A/4A Trial Lead.
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Not Found
Anatomical Site
Spinal Cord, Epidural space, L5 to T5
Indicated Patient Age Range
Not Found
Intended User / Care Setting
Intended Clinician: Orthopedic, Neurosurgeon, Anesthesiologist
Intended User: Layperson
Environmental Use: Hospital, Home
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)
A multicenter, prospective, randomized controlled study demonstrated the efficacy of the Stimwave Freedom SCS System for the treatment of chronic back, or back and leg pain associated with FBSS using stimulation waveforms with therapeutic frequencies at 10,000 Hz in comparison to stimulation waveforms from 50 Hz to 1500 Hz. The primary endpoint was defined as the percentage of subjects who responded (50% or more relief as measured by VAS compared to average baseline pain VAS) to SCS therapy for back pain in both the test and control groups at the end of 6 months follow-up after a one-month initial trial period. The primary endpoint showed a non-inferiority outcome with a p=0.0082, allowing sequential testing of the secondary endpoints for non-inferiority until one of the tests did not pass. The following secondary endpoints also demonstrated non-inferiority:
- A. Percent reduction in severity of back pain (VAS);
- B. Percent reduction in severity of leg pain (VAS);
- C. Change in ODI scores;
- D. Change in PGIC scores.
The most common adverse event reported was migration (15%), which is a known risk for all neurostimulation devices. To mitigate the risk of migration, Stimwave had introduced the SandShark Injectable Anchor (SIA) System (K172644) to market in late 2017, which has virtually eliminated the occurrence of migration for the Freedom SCS System in commercial utilization. The SIA System was not available at the time of the study. Thus, the risk of migration for the Freedom SCS System has been mitigated as far as possible. Procedure-related adverse events and serious adverse events included incision pain (7%) and infection (1%).
These results demonstrated that the Freedom SCS System utilizing stimulation waveforms with frequencies at 10,000 Hz, is just as safe and effective as the Freedom SCS System utilizing stimulation waveforms with frequencies in the range of 50 Hz to 1500 Hz as the sole mitigating agent, or as an adjunct to other modes of therapy used in a multidisciplinary approach for chronic, intractable pain of the trunk and/or lower limbs, including unilateral or bilateral pain.
Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)
Not Found
Predicate Device(s)
Reference Device(s)
Predetermined Change Control Plan (PCCP) - All Relevant Information
Not Found
§ 882.5880 Implanted spinal cord stimulator for pain relief.
(a)
Identification. An implanted spinal cord stimulator for pain relief is a device that is used to stimulate electrically a patient's spinal cord to relieve severe intractable pain. The stimulator consists of an implanted receiver with electrodes that are placed on the patient's spinal cord and an external transmitter for transmitting the stimulating pulses across the patient's skin to the implanted receiver.(b)
Classification. Class II (performance standards).
0
Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). The FDA logo is composed of two distinct elements: the Department of Health and Human Services logo on the left and the FDA acronym along with the full name of the agency on the right. The Department of Health and Human Services logo features a stylized representation of a human figure, while the FDA portion includes the acronym "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.
March 29, 2019
Stimwave Technologies Incorporated Elizabeth Greene Chief Compliance Officer Stimwave Technologies Inc. 1310 Park Central Boulevard South Pompano Beach, Florida 33064
Re: K182720
Trade/Device Name: Freedom Spinal Cord Stimulator (SCS) System Regulation Number: 21 CFR 882.5880 Regulation Name: Implanted Spinal Cord Stimulator For Pain Relief Regulatory Class: Class II Product Code: GZB Dated: February 28, 2019 Received: March 1, 2019
Dear Elizabeth Greene:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrl/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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
1
801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; 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
2
Indications for Use
510(k) Number (if known) K182720
Device Name Freedom Spinal Cord Stimulator (SCS) System
Indications for Use (Describe)
The Freedom Spinal Cord Stimulator (SCS) System is intended as the sole mitigating agent, or as an adjunct to other modes of therapy used in a multidisciplinary approach for chronic, intractable pain of the trunk and/or lower limbs, including unilateral or bilateral pain.
The Freedom-8A Trial Lead Kit is only used in conjunction with the Freedom-8A Stimulator Receiver Kit, and the Freedom-4A Trial Lead Kit is used for either the Receiver Kit Freedom-4A or the Receiver Kit Freedom-8A Stimulator. The trial devices are solely used for trial stimulation (no longer than 30 days) to determine efficacy before recommendation for a permanent (long term) device.
| Type of Use (Select one or both, as applicable) | |
|---|---|
| ------------------------------------------------- | -- |
X Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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Image /page/3/Picture/0 description: The image shows the logo for Stimwave Technologies. The word "stim" is in blue, "wave" is in green, and "TECHNOLOGIES" is in blue. To the right of the words is a blue graphic of concentric arcs, resembling radio waves.
510(k) Summary
For Freedom Spinal Cord Stimulator (SCS) System
K182720
1. Submission Sponsor
Stimwave Technologies Incorporated 1310 Park Central Boulevard Pompano Beach Florida 33064 USA Phone: 800.965.5134 Fax: 800.965.5134 Contact: Elizabeth Greene, Chief Compliance Officer
2. Date Prepared
March 27, 2019
3. Device Identification
| Trade/Proprietary Name: | Freedom Spinal Cord Stimulator (SCS) System |
|---|---|
| Common/Usual Name: | Spinal Cord Stimulator |
| Classification Name: | Stimulator, Spinal-Cord, Implanted (Pain Relief) |
| Classification Regulation: | 882.5880 |
| Product Code: | GZB |
| Device Class: | Class II |
| Classification Panel: | Neurology |
4. Legally Marketed Predicate Device(s)
Stimwave Freedom SCS System FR8A/FR4A, PDBT-915-2A (K180981)
5. Device Description
This premarket notification submission is identical to K180981, but includes updates to widen the available range of stimulation parameters to:
- A. Repetition Rate: 5 Hz to 10 kHz;
- B. Pulse Width: 30 us to 1000 us.
4
Image /page/4/Picture/0 description: The image shows the logo for Stimwave Technologies. The word "stim" is in blue, and the word "wave" is in green. Below the words "stim wave" is the word "TECHNOLOGIES" in blue. To the right of the words is a blue graphic of concentric circles.
No design modifications to the Freedom SCS System of K180981 were made in support of this premarket notification submission. Updates to the labeled product specifications do not change the intended use, indications for use, or adversely affect device safety or effectiveness as compared to the legally marketed predicate device.
The Stimwave Technologies Incorporated (Stimwave) Freedom Spinal Cord SCS System (System) is used for spinal column stimulation to provide therapeutic relief for chronic. intractable pain of the trunk and/or lower limbs including unilateral or bilateral pain. The therapy utilizes pulsed electrical current to create an energy field that acts on nerves near the spinal column. The System is comprised of an implantable stimulator (Freedom-8A/4A Stimulator), receiver component (Receiver), and an externally worn transmitter (Wearable Antenna Assembly (WAA)) to power the device. The System is implanted only following a successful trial period with the Freedom-8A/4A Trial Lead.
| Freedom-8A and Freedom-4A Stimulator (Receiver Kit) | |
|---|---|
| Freedom-8A | |
| Stimulator, | |
| Freedom-4A | |
| Stimulator | A polyurethane (Pellethane 55D) casing with an embedded receiver, flexible |
| circuit board and electrodes (Platinum Iridium 90:10) that is placed in the | |
| patient's epidural space. The Freedom-8A Stimulator has eight (8) electrodes, | |
| and the Freedom-4A Stimulator has four (4) electrodes. Matches device | |
| specifications of K180981 with the exception of the widened range of | |
| stimulation parameters for repetition rate (5 Hz to 10 kHz) and pulse width (30 | |
| $μ$ s to 1000 $μ$ s). | |
| Receiver | A copper and PEEK cable with dual couplers; placed within the center lumen of |
| the Freedom-8A or Freedom-4A Stimulator with the distal end combination of | |
| Receiver and Stimulator being placed under the skin. Two (2) Receivers are | |
| provided with each kit. Identical to K180981. | |
| Stylet(s) | A stainless steel wire with a polypropylene handle that is inserted into the open |
| central lumen of the stimulator to provide rigidity during implantation. Two (2) | |
| stylets are provided in the Receiver Kit, one straight and one bent, each with | |
| diameter of 0.30 mm. Identical to K180981. | |
| Needle | A 13-gauge stainless steel needle that acts as a conduit for passage of the |
| Stimulator into the epidural space. Identical to K180981. | |
| Guidewire | A stainless steel, rigid, solid core guidewire used to create a hollow pathway in |
| the epidural space for the Stimulator to pass through easily. Identical to | |
| K180981. |
Freedom-8A and Freedom-4A Stimulator (Receiver Kit)
Wearable Antenna Assembly (WAA Kit)
- WAA The WAA housing includes the following components: A. Microwave Field Stimulator (MFS) - A printed circuit board (PCB) that generates RF power with embedded waveform parameter settings and switches for changing parameter settings as needed by the user. Identical to K180981; B. Switch Membrane - An elastomeric silicon rubber pad that corresponds to switches on the MFS that allows the user to turn the device on/off or
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Image /page/5/Picture/0 description: The image shows the logo for Stimwave Technologies. The word "stim" is in blue, and the word "wave" is in green. The word "TECHNOLOGIES" is in blue and is located in a blue oval. To the right of the word "wave" are three curved lines that look like sound waves.
Wearable Antenna Assembly (WAA Kit)
| Charger Kit | |
|---|---|
| increase or decrease power amplitude as well as interpret device power | |
| status (On, Off, Charging, Transmitting, and Bluetooth® Connection). | |
| Identical to K180981; | |
| C. | Battery Assembly – A battery and wire assembly for charging and the MFS |
| for power delivery. Identical to K180981. | |
| Transmitting (Tx) Antenna Assembly – An antenna and coaxial cable assembly | |
| that is attached to the WAA that is used to transmit microwave energy to the | |
| implanted Stimulator. Identical to K180981. | |
| Battery Charger | An off-the-shelf battery charger that uses a power adapter and USB to micro- |
| USB cable to recharge the encased lithium ion battery of the WAA. Identical to | |
| K180981. |
Freedom-8A and Freedom-4A Spare Lead (Spare Lead Kit)
| Freedom-8A
Spare Lead,
Freedom-4A
Spare Lead | A polyurethane (Pellethane 55D) casing with an embedded receiver, flexible
circuit board and electrodes (Platinum Iridium 90:10) that is placed in the
patient's epidural space. The Freedom-8A Spare Lead has eight (8) electrodes,
and the Freedom-4A Spare Lead has four (4) electrodes. Matches device
specifications of K180981 with the exception of the widened range of
stimulation parameters for repetition rate (5 Hz to 10 kHz) and pulse width (30
$\u03bcs$ s to 1000 $\u03bcs$ s). |
|-------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| RF Stylet | A copper and PEEK cable with dual couplers; placed within the center lumen of
the Freedom-8A or Freedom-4A Spare Lead with the distal end combination of
RF Stylet and Spare Lead being placed under the skin. Two (2) RF Stylets are
provided with each kit. Identical to K180981. |
| Stylet(s) | A stainless steel wire with a polypropylene handle that is inserted into the open
central lumen of the stimulator to provide rigidity during implantation. Two (2)
stylets are provided in the Spare Lead Kit, one straight and one bent, each with
diameter of 0.30 mm. Identical to K180981. |
| Needle | A 13-gauge stainless steel needle that acts as a conduit for passage of the Spare
Lead into the epidural space. Identical to K180981. |
| Guidewire | A stainless steel, rigid, solid core guidewire used to create a hollow pathway in
the epidural space for the Spare Lead to pass through easily. Identical to
K180981. |
Freedom-8A and Freedom-4A Trial Lead (Trial Lead Kit)
| Freedom-8A
Trial Lead,
Freedom-4A
Trial Lead | A polyurethane (Pellethane 55D) casing with an embedded receiver, flexible
circuit board and electrodes (Platinum Iridium 90:10) that is placed
percutaneously in the patient's epidural space. The Freedom-8A Trial Lead has
eight (8) electrodes, and the Freedom-4A Trial Lead has four (4) electrodes.
Matches device specifications of K180981 with the exception of the widened
range of stimulation parameters for repetition rate (5 Hz to 10 kHz) and pulse
width (30 $\mu$ s to 1000 $\mu$ s). |
| ------------------------------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
|---|
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Image /page/6/Picture/0 description: The image contains the logo for Stimwave Technologies. The word "stim" is in dark blue, and the word "wave" is in green. The word "TECHNOLOGIES" is in black and is located in a black rounded rectangle. There are blue curved lines to the right of the word "wave".
Freedom-8A and Freedom-4A Trial Lead (Trial Lead Kit)
| RF Stylet | A copper and PEEK cable with dual couplers; placed within the center lumen of
the Freedom-8A or Freedom-4A Trial Lead with the distal end combination of
RF Stylet and Trial Lead being placed under the skin. Two (2) RF Stylets are
provided with each kit. Identical to K180981. |
|-----------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Stylet(s) | A stainless steel wire with a polypropylene handle that is inserted into the open
central lumen of the stimulator to provide rigidity during implantation. Two (2)
stylets are provided in the Trial Lead Kit, one straight and one bent with a
diameter of 0.30 mm. Identical to K180981. |
| Needle | A 13-gauge stainless steel needle that acts as a conduit for passage of the Trial
Lead into the epidural space. Identical to K180981. |
| Guidewire | A stainless steel, rigid, solid core guidewire used to create a hollow pathway in
the epidural space for the Trial Lead to pass through more easily. Identical to
K180981. |
Sterile Revision Kit
| Stylet(s) | A stainless steel wire with a polypropylene handle that is inserted into the open
central lumen of the stimulator to provide rigidity during implantation. Two (2)
stylets are provided in the Sterile Revision Kit, one straight and one bent with a
diameter of 0.30 mm. Identical to K180981. |
|-----------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Needle | A 13-gauge stainless steel needle that acts as a conduit for passage of the
Stimulator/Lead into the epidural space. Identical to K180981. |
| Guidewire | A stainless steel, rigid, solid core guidewire used to create a hollow pathway in
the epidural space for the Stimulator/Lead to pass through easily. Identical to
K180981. |
Sterile Single Pack Accessories
| RF Stylet | A copper and PEEK cable with dual couplers; placed within the center lumen of the Freedom-8A or Freedom-4A Stimulator, Spare Lead, or Trial Lead with the distal end combination of RF Stylet and Stimulator, Spare Lead, or Trial Lead being placed under the skin. One (1) RF Stylet is provided in the single pack. Identical to K180981. |
|---|---|
| Needle (4.5") | A 13-gauge stainless steel needle that acts as a conduit for passage of the Stimulator/Lead into the epidural space. Identical to K810981. |
| Needle (6") | A 13-gauge stainless steel needle that acts as a conduit for passage of the Stimulator/Lead into the epidural space. Identical to K180981. |
| Guidewires | A stainless steel, rigid, solid core guidewire used to create a hollow pathway in the epidural space for the Stimulator/Lead to pass through easily. Three (3) guidewires are provided, each with different diameters (1.05mm, 1.30mm, and 1.60mm), but all the same length (45cm). Identical to K180981. |
| Introducer | A stainless steel stylet and polymer sheath that dilates the path over the guidewire for advancing the Stimulator/Lead into place. Identical to K180981. |
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Image /page/7/Picture/0 description: The image contains the logo for Stimwave Technologies. The word "stim" is in blue, "wave" is in green, and "TECHNOLOGIES" is in black. To the right of the words is a blue graphic of concentric circles.
| Non-Sterile Single Pack Accessories | |
|---|---|
| Small SeaSilk | |
| Antenna (12" | |
| Cable Length) | An antenna (conductive ink printed onto laminate) bonded to the outside of a |
| fabric shirt and coaxial cable assembly. Attaches to the WAA and used to | |
| transmit microwave energy to the implanted Stimulator/Lead. Identical to | |
| K180981. | |
| Small SeaSilk | |
| Antenna (27" | |
| Cable Length) | An antenna (conductive ink printed onto laminate) bonded to the outside of a |
| fabric shirt and coaxial cable assembly. Attaches to the WAA and used to | |
| transmit microwave energy to the implanted Stimulator/Lead. Identical to | |
| K180981. | |
| Large SeaSilk | |
| Antenna (30" | |
| Cable Length) | An antenna (conductive ink printed onto laminate) bonded to the outside of a |
| fabric shirt and coaxial cable assembly. Attaches to the WAA and used to | |
| transmit microwave energy to the implanted Stimulator/Lead. Identical to the | |
| K180981. | |
| Large SeaSilk | |
| Antenna (28" | |
| Cable Length) | An antenna (conductive ink printed onto laminate) bonded to the outside of a |
| fabric shirt and coaxial cable assembly. Attaches to the WAA and used to | |
| transmit microwave energy to the implanted Stimulator/Lead. Identical to the | |
| K180981. | |
| Small Antenna | |
| (12" Cable | |
| Length) | A flexible dipole antenna and coaxial cable assembly that is attached to the |
| WAA that is used to transmit microwave energy to the implanted Stimulator. | |
| Identical to K180981. | |
| Small Antenna | |
| (27" Cable | |
| Length) | A flexible dipole antenna and coaxial cable assembly that is attached to the |
| WAA that is used to transmit microwave energy to the implanted Stimulator. | |
| Identical to K180981. | |
| Large Antenna | |
| (30" Cable | |
| Length) | A flexible dipole array antenna and coaxial cable assembly that is attached to |
| the WAA that is used to transmit microwave energy to the implanted Stimulator. | |
| Identical to K180981. |
Non-Sterile Single Pack Accessories
6. Indication for Use Statement
The Freedom Spinal Cord Stimulator (SCS) System is intended as the sole mitigating agent, or as an adjunct to other modes of therapy used in a multidisciplinary approach for chronic, intractable pain of the trunk and/or lower limbs, including unilateral or bilateral pain. The Freedom-8A Trial Lead Kit is only used in conjunction with the Freedom-8A Stimulator Receiver Kit, and the Freedom-4A Trial Lead Kit is used for either the Receiver Kit Freedom-4A Stimulator or the Receiver Kit Freedom-8A Stimulator. The trial devices are solely used for trial stimulation (no longer than 30 days) to determine efficacy before recommendation for a permanent (long term) device.
7. Substantial Equivalence Discussion
The following table compares the Stimwave Freedom SCS System to the primary predicate device with respect to intended use, technological characteristics and principles of operation, providing more detailed information regarding the basis for the determination of substantial equivalence.
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Image /page/8/Picture/0 description: The image shows the logo for Stimwave Technologies. The word "stim" is in blue, and the word "wave" is in green. Below the words "stim" and "wave" is the word "TECHNOLOGIES" in blue. To the right of the words is a blue circular wave pattern.
| Comparator | Stimwave Freedom SCS System
(Predicate K180981) | Stimwave Freedom SCS System
(Subject Device K182720) |
|----------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------|
| Product Code | GZB | Same as K180981 |
| Regulation No. | 882.5880 | Same as K180981 |
| Regulation Name | Stimulator, Spinal-Cord,
Implanted (Pain Relief) | Same as K180981 |
| Intended Use | Stimulation of spinal cord for chronic,
intractable pain of trunk and lower
limbs | Same as K180981 |
| Mode of Action | RF wireless transmission of energy
to produce stimulation at Stimulator
electrodes. WAA sends a pulsed RF
signal on a carrier frequency of
915MHz to the Stimulator | Same as K180981 |
| Implant Site | Epidural space, L5 to T5 | Same as K180981 |
| Environmental Use | Hospital, Home | Same as K180981 |
| Intended Clinician | Orthopedic, Neurosurgeon,
Anesthesiologist | Same as K180981 |
| Intended User | Layperson | Same as K180981 |
| Electrode Material | Platinum-iridium 90:10 | Same as K180981 |
| Stimulator Body Material | Polyurethane 2363-55D | Same as K180981 |
| Cable Features | Multi-lumen Tube | Same as K180981 |
| Stimulator Length | 45 centimeters | Same as K180981 |
| Diameter | 1.35 millimeters | Same as K180981 |
| Electrode Array Length | 24.0 millimeters
52.0 millimeters | Same as K180981 |
| No. of Electrodes | 4 or 8 | Same as K180981 |
| Electrode Length | 3.0 millimeters | Same as K180981 |
| Electrode Spacing | 4.0 millimeters | Same as K180981 |
| Electrode Surface Area | 12.72 mm² | Same as K180981 |
| Method of Introduction | Percutaneous and Anchor Incision | Same as K180981 |
| Tissue Contact | Yes | Same as K180981 |
| Sterilization | Ethylene Oxide (EO) | Same as K180981 |
| Labeling | Labeled as Sterile, Single Use,
Prescription Device | Same as K180981 |
| Package | Backer card and two sterile
pouches | Same as K180981 |
| Pulse Frequency | 5 to 1500 Hertz | 5 to 10,000 Hertz |
| Pulse Width | 50 to 500 microseconds | 30 to 1000 microseconds |
| Current/Voltage Regulated | Current | Same as K180981 |
| Output Voltage (300 Ω) | 0 to 4.1 V | Same as K180981 |
| Output Voltage (500 Ω) | 0 to 6.4 V | Same as K180981 |
| Output Voltage (800 Ω) | 0 to 7.5 V | Same as K180981 |
| Output Current (300 Ω) | 0 to 13.5 mA | Same as K180981 |
| Output Current (500 Ω) | 0 to 12.8 mA | Same as K180981 |
| Output Current (800 Ω) | 0 to 9.4 mA | Same as K180981 |
| Waveform | Charge Balanced (delayed) | Same as K180981 |
| Comparator | Stimwave Freedom SCS System
(Predicate K180981) | Stimwave Freedom SCS
System
(Subject Device K182720) |
| Polarity | Programmable
(Anode, Cathode, or Off) | Same as K180981 |
| Pulse Shape | Decaying Exponential | Same as K180981 |
| Avg. Current Density (300 Ω) | 105.0 mA/cm² | Same as K180981 |
| Avg. Current Density (500 Ω) | 95.1 mA/cm² | Same as K180981 |
| Avg. Current Density (800 Ω) | 69.0 mA/cm² | Same as K180981 |
| Max. Phase Charge* (300 Ω) | 6.8 µC/pulse | Same as K180981 |
| Max. Phase Charge* (500 Ω) | 6.4 µC/pulse | Same as K180981 |
| Max. Phase Charge* (800 Ω) | 4.7 µC/pulse | Same as K180981 |
| Max. Charge Density* (300 Ω) | 53.1 µC/cm² | Same as K180981 |
| Max. Charge Density* (500 Ω) | 50.3 µC/cm² | Same as K180981 |
| Max. Charge Density* (800 Ω) | 36.9 µC/cm² | Same as K180981 |
| Max. Current Density* (300 Ω) | 106.1 mA/cm² | Same as K180981 |
| Max. Current Density* (500 Ω) | 100.6 mA/cm² | Same as K180981 |
| Max. Current Density* (800 Ω) | 73.9 mA/cm² | Same as K180981 |
| Net Charge | 0 µC | Same as K180981 |
| Avg. Phase Power (300 Ω) | 0.053 W/phase | Same as K180981 |
| Avg. Phase Power (500 Ω) | 0.073 W/phase | Same as K180981 |
| Avg. Phase Power (800 Ω) | 0.062 W/phase | Same as K180981 |
| Avg. Phase Power Density (300 Ω) | 0.42 W/cm²/phase | Same as K180981 |
| Avg. Phase Power Density (500 Ω) | 0.58 W/cm²/phase | Same as K180981 |
| Avg. Phase Power Density (800 Ω) | 0.48 W/cm²/phase | Same as K180981 |
| Pulse Delivery Mode | Continuous | Same as K180981 |
| ON/OFF Times | No Cycling | Same as K180981 |
| Current Path Options | Bipolar | Same as K180981 |
| Power Delivery | Embedded receiver and coupled
receiver in lumen of Stimulator | Same as K180981 |
| Transmit Frequency | 915 MHz | Same as K180981 |
| Material | Platinum-iridium 90:10,
Polyurethane 2363-55D | Same as K180981 |
| Sterile | Yes - ethylene oxide | Same as K180981 |
| Contract Sterilizer | Steris Isomedix Services | Same as K180981 |
| Single-Use | Yes | Same as K180981 |
| Shelf Life | 2 year | Same as K180981 |
| Complies with ISO 10993-1 | Yes | Same as K180981 |
| Safety Testing Passed | Yes | Same as K180981 |
| MR Conditional | Yes | Same as K180981 |
| Accessories | Receiver/RF Stylet, Stylet(s),
Guidewire, Needle | Same as K180981 |
| Single Pack Accessories | Sterile: RF Stylet, Needle(s),
Guidewires, Introducer
Non-Sterile: SeaSilk Antenna(s),
Antenna Assembly | Same as K180981 |
| Charger | USB Charger | Same as K180981 |
| Wearable Antenna Assembly | Aluminum transmitter & separate,
connected Antenna | Same as K180981 |
| Software Level of Concern | Moderate | Same as K180981 |
| iPad Application | WaveCrest™ | Same as K180981 |
| Patient Programmer Application | WaveCrest Mobile | Same as K180981 |
| Comparator | Stimwave Freedom SCS System
(Predicate K180981) | Stimwave Freedom SCS
System
(Subject Device K182720) |
| Kits | Receiver Kit, Spare Lead Kit, Trial
Lead Kit, Sterile Revision Kit, WAA
Kit, Charger Kit, Single Pack
Accessories | Same as K180981 |
Table 5A. Comparison of Characteristics
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Image /page/9/Picture/0 description: The image contains the logo for Stimwave Technologies. The word "stim" is in blue, and the word "wave" is in green. The word "TECHNOLOGIES" is in blue and is located in a blue rounded rectangle. To the right of the words is a blue graphic that looks like sound waves.
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Image /page/10/Picture/0 description: The image contains the logo for Stimwave Technologies. The word "stim" is in blue, and the word "wave" is in green. The word "TECHNOLOGIES" is in blue and underlined. To the right of the word "wave" are blue curved lines that resemble radio waves.
(*) asterisk denotes that formulas were used for the calculations.
8. Biocompatibility Data
Materials of this premarket notification submission are identical to K180981. The materials of the Freedom-8A/4A Stimulator in direct contact with tissue remain unchanged from the Freedom SCS System (K170141) and thus, the biocompatibility tests conducted on representative subassemblies of the Freedom SCS System (Freedom-4, K141399) directly apply to the Freedom SCS System (K170141, and K180981). The materials, construction and intended use of the Freedom SCS System is comparable to the predicate devices, and have a long history of safety with respect to biocompatibility. The biological safety of the Freedom-8A/4A Stimulator (same as the Freedom-4 Stimulator) was evaluated in accordance to ISO 10993-1:2009 and guidance document Blue Book Memorandum G95-1 Use of International Standard ISO-10993, and Biological Evaluation of Medical Devices: Part 1: Evaluation and Testing. Under these, for the stated indications for use, the device was classified as a (C), implant device in contact with tissue/bone. The results for the biocompatible testing of the Freedom-8A/4A Stimulator (same as the Freedom-4 Stimulator) for cytotoxicity, sensitization, irritation or intracutaneous reactivity, acute systemic toxicity, genotoxicity, implantation (4, 8, and 13 weeks), and subchronic toxicity demonstrated no negative impacts from the materials that are used in the Freedom SCS System. The Freedom-8A/4A Stimulator materials in direct tissue contact include Pellethane 55D (Stimulator) and Pt-Ir (90:10) (Stimulator only), both having an extensive record (previously cleared and approved) of chronic and carcinogenetic safety. The Receiver/RF Stylet is never in direct or indirect contact with tissue. The WAA is intended to be on top of a thin shirt or article of clothing around the midsection of the patient. The User Manual provided to the patient describes that the WAA should always be worn on top of a layer of clothing. The WAA does not come into contact with the patient's skin. The categorization by nature of body contact of the WAA is thus "non-contacting device", and not included in the scope of ISO 10993-1:2009. The Freedom SCS System meets biological safety and compatibility requirements of ISO 10993-1:2009 and Blue Book Memorandum G95-1.
9. Non-Clinical Performance Data
No modifications to the Freedom SCS System of K180981 were made in support of this premarket notification submission. The Freedom SCS System was always designed with the widened stimulation parameters for repetition rate and pulse width, but in predicate
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Image /page/11/Picture/0 description: The image shows the logo for Stimwave Technologies. The word "stim" is in blue, and the word "wave" is in green. The word "TECHNOLOGIES" is in blue and is located below the words "stim wave". To the right of the words is a blue graphic of concentric circles.
devices (K180981 and preceding), the software restricted these settings. Performance testing presented in this submission is identical to K180981, and verifies that there is no change to performance, demonstrating substantial equivalence between the subject device and the predicate device (K180981).
The Freedom SCS System was tested to verify that the performance meets the system design requirements as well as all applicable voluntary standards. The Freedom SCS System complies with all design requirements and applicable voluntary standards.
AAMI ANSI ISO 14708-3:2008 - For protection from temperature change including shipping and storage temperature ranges, the Freedom-8A/4A Stimulator was functional, receiving a safe rating following post visual inspection and passed the change of temperature testing performed as specified by AAMI ANSI ISO 14708-3:2008. For atmospheric pressure change, the Freedom-8A/4A Stimulator were functional following post testing functionality inspection and passed atmospheric pressure change testing as specified by AAMI ANSI ISO 14708-3:2008. This testing presented for K180981 is leveraged from K170141, and is directly applicable for demonstration of device safety and efficacy as the packaging and the Freedom-8A/4A Stimulator remains unchanged by electrical component upgrades. The testing for the Freedom-8A/4A Stimulator with the upgraded ASIC demonstrates no change to device performance and specification, and thus, demonstrates continued safety and efficacy compared to the predicates. The Receiver/RF Stylet is identical to K180981 and a passive component that does not impact the outcome of the leveraged tests for safety and effectiveness. The Freedom-8A/4A Stimulator and Receiver/RF Stylet testing presented for this premarket notification submission is leveraged from K180981, and is directly applicable for demonstration of device safety and efficacy as the Freedom-8A/4A Stimulator and Receiver/RF Stylet remains the same the predicate.
For testing external defibrillation exposure, the Freedom-8A/4A Stimulator and Receiver were verified as functional after exposure to external defibrillation. Thus, the Freedom SCS System complies with testing as specified by AAMI ANSI ISO 14708-3:2008. The Freedom-8A/4A Stimulator and Receiver/RF Stylet testing presented for this premarket notification submission is leveraged from K180981, and is directly applicable for demonstration of device safety and efficacy as the Freedom-8A/4A Stimulator design remains unchanged by the widened range of stimulation parameters for repetition rate and pulse width. The Freedom-8A/4A Stimulator stimulation parameter labeling update does not affect the outcome of external defibrillation exposure testing and as such, demonstrates no change to device performance and specification, and continued safety and efficacy compared to the predicate. The Freedom-8A/4A Stimulator and Receiver/RF Stylet testing presented for this premarket notification submission is leveraged from K180981, and is directly applicable for demonstration of device safety and efficacy as the Freedom-8A/4A Stimulator and Receiver/RF Stylet remains the same as the predicate.
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Image /page/12/Picture/0 description: The image shows the logo for Stimwave Technologies. The word "stim" is in blue, and the word "wave" is in green. The word "TECHNOLOGIES" is in blue and is located in a blue rounded rectangle. There are blue curved lines to the right of the word "wave".
Following the thermal shock testing, the Freedom-8A/4A Stimulator was found to have "no irreversible damage" and fully functional as specified by the manufacturer, and to have no physical anomalies present at the time of inspection. Thus, the Freedom-8A/4A Stimulator complies with the thermal shock design requirements and the applicable standard. The testing presented for this premarket notification submission is leveraged from K180981, and is directly applicable for demonstration of device safety and efficacy as the Freedom-8A/4A Stimulator design remains unchanged by the widened range of stimulation parameters for repetition rate and pulse width. The Freedom-8A/4A Stimulator stimulation parameter labeling update does not affect the outcome of thermal shock testing and as such, demonstrates no change to device performance and specification, and continued safety and efficacy compared to the predicate. The Receiver/RF Stylet remains the same the predicate and is a passive component that does not impact the outcome of the leveraged tests for safety and effectiveness.
For leakage current testing, the Freedom-8A/4A Stimulator was produced zero leakage current on all tested paths for all tested samples. Thus, the Freedom-8A/4A Stimulator complies with the leakage design requirements and the applicable standard The Freedom-8A/4A Stimulator and Receiver/RF Stylet testing presented for this premarket notification submission is leveraged from K180981, and is directly applicable for demonstration of device safety and efficacy as the Freedom-8A/4A Stimulator design remains unchanged by the widened range of stimulation parameters for repetition rate and pulse width. The Freedom-8A/4A Stimulator stimulation parameter labeling update does not affect the outcome of leakage current testing and as such, demonstrates no change to device performance and specification, and continued safety and efficacy compared to the predicate. The Receiver/RF Stylet remains the same the predicate and is a passive component that does not impact the outcome of the leveraged tests for safety and effectiveness.
For testing the insertion and withdrawal of the stylet within the Stimulator, the stylet was found to require less than 2.5N of insertion or withdrawal force for all tested stylets in all tested stimulator samples. For testing the insertion and withdrawal of the Receiver within the Stimulator, the Receiver/RF Stylet was found to require less than 2.2N of insertion or withdrawal force for all tested stylets in all tested stimulator samples. Visual inspection confirmed no damage was present in any stimulator samples. Thus, the Freedom-8A/4A Stimulator and Receiver/RF Stylet comply with design specifications for stylet insertion and withdrawal force. The Freedom-8A/4A Stimulator and Receiver/RF Stylet testing presented for this premarket notification submission is leveraged from K180981, and is directly applicable for demonstration of device safety and efficacy as the Freedom-8A/4A Stimulator design remains unchanged by the widened range of stimulation parameters for repetition rate and pulse width. The Freedom-8A/4A Stimulation parameter labeling update does not affect the outcome of insertion and withdrawal of the stylet testing
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Image /page/13/Picture/0 description: The image shows the logo for Stimwave Technologies. The word "stim" is in blue, and the word "wave" is in green. The word "TECHNOLOGIES" is in blue and is located in a blue rounded rectangle. To the right of the word "wave" are three blue curved lines that resemble radio waves.
and as such, demonstrates no change to device performance and specification, and continued safety and efficacy compared to the predicate. The Receiver/RF Stylet testing is leveraged from K180981, and is directly applicable for demonstration of device safety and effectiveness, as Receiver/RF Stylet remains the same.
For mechanical testing, the Freedom-8A/4A Stimulator passed all criteria of the test, showing no visible damage to the stimulator body or functional damage to the components. Mechanical testing included tensile testing, flex testing and torsion testing. Thus, the Freedom-8A/4A Stimulator complies with all stimulator mechanical design requirements. The Freedom-8A/4A Stimulator and Receiver/RF Stylet testing presented for this premarket notification submission is leveraged from K180981, and is directly applicable for demonstration of device safety and efficacy as the Freedom-8A/4A Stimulator design remains unchanged by the widened range of stimulation parameters for repetition rate and pulse width. The Freedom-8A/4A Stimulator stimulation parameter labeling update does not affect the outcome of mechanical testing and as such, demonstrates no change to device performance and specification, and continued safety and efficacy compared to the predicate. The Receiver/RF Stylet testing is leveraged from K180981, and is directly applicable for demonstration of device safety and effectiveness, as Receiver/RF Stylet remains the same.
For magnetic resonance imaging (MRI) radio frequency (RF) induced heating as related to specific absorbance rate (SAR), the Freedom-8A Stimulator produced a maximum temperature increase lower than the allowable limit for the 1.5T and 3T MRI procedure and thus passed the 1.5T and 3T testing. The Freedom-8A Stimulator produced a maximum temperature increase lower than the allowable limit for the 1.5T and 3T MRI procedure and thus passed both. The Freedom-8A/4A Stimulator and Receiver/RF Stylet testing presented for this premarket notification submission is leveraged from K180981, and is directly applicable for demonstration of device safety and efficacy as the Freedom-8A/4A Stimulator design remains unchanged by the widened range of stimulation parameters for repetition rate and pulse width. The Freedom-8A/4A Stimulation parameter labeling update does not affect the outcome of MRI RF induced heating testing and as such. demonstrates no change to device performance and specification, and continued safety and efficacy compared to the predicate.
ASTM F2182-11a - In accordance with F2182-11a - American Society for Testing and Materials (ASTM) International Standard Test Method for Measurement of Radio Frequency Induced Heating Near Passive Implants During Magnetic Resonance Imaging. the Freedom-8A/4A Stimulator showed that its presence would not cause injury to the patient with the implant during an MRI procedure. The Freedom-8A Stimulator is a passive implant that is not powered while the external unit is not transmitting to it. The Freedom-8A/4A Stimulator and Receiver/RF Stylet testing presented for this premarket notification submission is leveraged from K180981, and is directly applicable for demonstration of device safety and efficacy as the Freedom-8A/4A Stimulator design remains unchanged by
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Image /page/14/Picture/0 description: The image shows the logo for Stimwave Technologies. The word "stim" is written in blue, and the word "wave" is written in green. Below the words "stim wave" is the word "TECHNOLOGIES" written in blue inside of a black rounded rectangle. To the right of the words "stim wave" is a blue graphic that looks like a series of concentric arcs.
the widened range of stimulation parameters for repetition rate and pulse width. The Freedom-8A/4A Stimulator stimulation parameter labeling update does not affect the outcome of MRI testing and as such, demonstrates no change to device performance and specification, and continued safety and efficacy compared to the predicate.
ASTM F2119-07 - In accordance with F2119-07 - American Society for Testing and Materials (ASTM) International Standard Test Method for Evaluation of MR Image Artifacts from Passive Implants, the Freedom-8A Stimulator showed that it does not produce image artifacts in 1.5T or 3T MRI procedures. The Freedom-8A/4A Stimulator and Receiver/RF Stylet testing presented for this premarket notification submission is leveraged from K180981, and is directly applicable for demonstration of device safety and efficacy as the Freedom-8A/4A Stimulator design remains unchanged by the widened range of stimulation parameters for repetition rate and pulse width. The Freedom-8A/4A Stimulator stimulation parameter labeling update does not affect the outcome of MRI testing and as such, demonstrates no change to device performance and specification, and continued safety and efficacy compared to the predicate.
ASTM F2052-06 - In accordance with F2052-06 - The American Society for Testing and Materials (ASTM) International Designation Standard Test Method for Measurement of Magnetically Induced Displacement Force on Medical Devices in the Magnetic Resonance Environment, the Freedom-8A Stimulator showed that it does not harm the patient due to its displacement by forces induced by 1.5T or 3T MRI exposure. The Freedom-8A Stimulator passes the ASTM acceptance criteria for deflection angle in a 1.5T and 3T MRI system. The Freedom-8A Stimulator will not present an additional risk or hazard to a patient when used in their tested MR environment. The Freedom-8A/4A Stimulator and Receiver/RF Stylet testing presented for this premarket notification submission is leveraged from K180981, and is directly applicable for demonstration of device safety and efficacy as the Freedom-8A/4A Stimulator design remains unchanged by the widened range of stimulation parameters for repetition rate and pulse width. The Freedom-8A/4A Stimulator stimulation parameter labeling update does not affect the outcome of MRI testing and as such, demonstrates no change to device performance and specification, and continued safety and efficacy compared to the predicate.
ASTM F2213-06 - In accordance with F2213-06 - American Society for Testing and Materials (ASTM) International Standard Test Method for Measurement of Magnetically Induced Torque on Passive Implants in the Magnetic Resonance Environment, the Freedom-8A/4A Stimulator must show that it does not harm the patient due to its torque by forces induced by MRI exposure. The Freedom-8A Stimulator will not present an additional risk or hazard to a patient in the 1.5T MRI or 3T environments or less with regard to torque.
The stimulation waveforms following post-exposure showed no component damage had occurred after MR exposure. During testing, no component damage was observed in any
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Image /page/15/Picture/0 description: The image shows the logo for Stimwave Technologies. The word "stim" is in blue, and the word "wave" is in green. The word "TECHNOLOGIES" is in blue and is located in a black rounded rectangle. To the right of the word "wave" are three curved lines that are purple.
waveform. Based on these test results, the Freedom-8A Stimulator will be fully functional following standard 1.5T or 3T MR procedures and its performance or functionality is not affected by such exposures.
The Freedom-8A/4A Stimulator and Receiver/RF Stylet testing presented for this premarket notification submission is leveraged from K180981, and is directly applicable for demonstration of device safety and efficacy as the Freedom-8A/4A Stimulator design remains unchanged by the widened range of stimulation parameters for repetition rate and pulse width. The Freedom-8A/4A Stimulation parameter labeling update does not affect the outcome of MRI testing and as such, demonstrates no change to device performance and specification, and continued safety and efficacy compared to the predicate.
IEC 60601-1 -The WAA was tested for compliance with IEC 60601-1. For testing the WAA for protection from temperature change, including shipping and storage temperature ranges, the WAA met the passing criteria of both of the visual and functional inspections following the testing. It showed no physical damage and was fully operational. Thus, the WAA of the Freedom SCS System satisfies the outlined protection from temperature change design requirements and the applicable standard. IEC 60601-1. For atmospheric pressure change testing, the WAA met the passing criteria of both of the visual and functional inspections following the testing. It showed no physical damage and was fully operational. Thus, the WAA of the Freedom SCS System satisfies the outlined atmospheric pressure change design requirements and the applicable standard, IEC 60601-1. For the push, drop, impact and mold stress relief testing of the WAA, it was determined through testing that the WAA is robust to withstand expected damage in accordance with general safety standards. The WAA met the passing criteria of both of the visual and functional inspections following the testing. It showed no physical damage and was fully operational. Thus, the WAA component of the Freedom-8A/4A SCS System satisfies the outlined push, drop, impact, and mold stress relief design requirements and the applicable standard, IEC 60601-1. For the identification, marking and documents of the WAA it was determined through an analysis of the labeling that the WAA complies with the requirements of the standard. All requirements and markings are clearly identified and viewable either from the external case of the product or from within the accompanying documents. For the means of protection, creepage distances, and air clearances of the WAA it was determined through an analysis of the design that the system satisfies the requirements of the applicable standard, IEC 60601-1. The WAA testing presented for this premarket notification submission is leveraged from K180981, and is directly applicable for demonstration of device safety and efficacy as the WAA design remains unchanged by the widened range of stimulation parameters for repetition rate and pulse width. The Freedom-8A/4A Stimulator stimulation parameter labeling update does not affect the outcome of compliance testing to IEC 60601-1 and as such demonstrates no change to device performance and specification, and continued safety and efficacy compared to the predicate.
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Image /page/16/Picture/0 description: The image contains the logo for Stimwave Technologies. The word "stim" is in blue, and the word "wave" is in green. To the right of the word "wave" are concentric purple circles. Below the words "stim wave" is the word "TECHNOLOGIES" in blue.
IEC 60529 - The WAA was tested for compliance with IEC 60529. For testing the ingress of water, the WAA met the passing criteria of both of the visual and functional inspections following the testing. It showed no physical damage and was fully operational. Thus, the WAA component of the Freedom SCS System satisfies the outlined Ingress of Water design requirements and the applicable standard IEC 60529. For particulate matter testing. the WAA met the passing criteria of both of the visual and functional inspections following the testing. It showed no physical damage and was fully operational. Thus, the WAA component of the Freedom SCS System satisfies the outlined Particulate Matter design requirements and the applicable standard, IEC 60529. The WAA testing presented for this premarket notification submission is leveraged from K180981, and is directly applicable for demonstration of device safety and efficacy as the WAA design remains unchanged by the widened range of stimulation parameters for repetition rate and pulse width. The Freedom-8A/4A Stimulation stimulation parameter labeling update does not affect the outcome of compliance testing to IEC 60529 and as such demonstrates no change to device performance and specification, and continued safety and efficacy compared to the predicate.
IEC 60601-1-2 - The WAA was tested for compliance with IEC 60601-1-2. For testing the WAA for electromagnetic compatibility, the unit met all acceptance criteria for emissions, low-frequency magnetic fields, immunity, electrostatic discharge, radiated RF electromagnetic fields, electrical fast transients and magnetic fields. The WAA operated within all test limits and showed no physical damage and was fully operational. Thus, the WAA for the Freedom SCS System satisfies the IEC 60601-1-2 standard. The WAA testing presented for this premarket notification submission is leveraged from K180981, and is directly applicable for demonstration of device safety and efficacy as the WAA design remains unchanged by the widened range of stimulation parameters for repetition rate and pulse width. The Freedom-8A/4A Stimulation parameter labeling update does not affect the outcome of compliance testing to IEC 60601-1-2 and as such demonstrates no change to device performance and specification, and continued safety and efficacy compared to the predicate.
The Freedom SCS System complies with the applicable standards for neurostimulators, electrical safety, electromagnetic interference and compatibility, biocompatibility, packaging, and sterilization. The software of the Freedom SCS System passed all verification tests outlined and the design requirements for Software Verification have been met. The device passed all the testing in accordance with national and international standards.
Following performance testing, it has been determined that the Freedom SCS System is substantially equivalent to legally marketed predicate devices for the therapy for chronic, intractable pain of the trunk and/or lower limbs, including unilateral pain.
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Image /page/17/Picture/0 description: The image shows the logo for Stimwave Technologies. The word "stim" is in dark blue, and the word "wave" is in green. Below the words is the word "TECHNOLOGIES" in dark blue inside of a dark blue rounded rectangle. To the right of the words is a series of curved lines that are also in dark blue.
Due to the similarities between the legally marketed predicate device (K180981), and the Freedom SCS System (this premarket notification submission), Stimwave Technologies Incorporated has leveraged applicable performance testing in addition to completed a number of tests that demonstrates substantial equivalence to the legally marketed predicate device. The Freedom SCS System meets all the requirements for overall design, sterilization, biocompatibility, and electrical safety confirms that the output meets the design inputs and specifications. The Freedom SCS System passed all testing stated above as shown by the acceptable results obtained.
10. Clinical Performance Data
Stimwave submitted clinical performance data supporting substantial equivalence claims of the subject device to the predicate device. A multicenter, prospective, randomized controlled study demonstrated the efficacy of the Stimwaye Freedom SCS System for the treatment of chronic back, or back and leg pain associated with FBSS using stimulation waveforms with therapeutic frequencies at 10,000 Hz in comparison to stimulation waveforms from 50 Hz to 1500 Hz. The primary endpoint was defined as the percentage of subjects who responded (50% or more relief as measured by VAS compared to average baseline pain VAS) to SCS therapy for back pain in both the test and control groups at the end of 6 months follow-up after a one-month initial trial period. The primary endpoint showed a non-inferiority outcome with a p=0.0082, allowing sequential testing of the secondary endpoints for non-inferiority until one of the tests did not pass. The following secondary endpoints also demonstrated non-inferiority:
- A. Percent reduction in severity of back pain (VAS);
- B. Percent reduction in severity of leg pain (VAS);
- C. Change in ODI scores;
- D. Change in PGIC scores.
The most common adverse event reported was migration (15%), which is a known risk for all neurostimulation devices. To mitigate the risk of migration, Stimwave had introduced the SandShark Injectable Anchor (SIA) System (K172644) to market in late 2017, which has virtually eliminated the occurrence of migration for the Freedom SCS System in commercial utilization. The SIA System was not available at the time of the study. Thus, the risk of migration for the Freedom SCS System has been mitigated as far as possible. Procedure-related adverse events and serious adverse events included incision pain (7%) and infection (1%).
Based on these factors, it is concluded that the benefits of the Freedom SCS System in safely and effectively reducing the symptoms of chronic, intractable pain of the truck and/or lower limbs in the appropriate patient population outweigh the risks.
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Image /page/18/Picture/0 description: The image contains the logo for Stimwave Technologies. The logo features the word "stim" in blue, stacked above the word "wave" in green. Below the word "wave" is the word "TECHNOLOGIES" in blue, inside of a black rounded rectangle. To the right of the word "wave" are three curved lines in blue, resembling radio waves.
These results demonstrated that the Freedom SCS System utilizing stimulation waveforms with frequencies at 10,000 Hz, is just as safe and effective as the Freedom SCS System utilizing stimulation waveforms with frequencies in the range of 50 Hz to 1500 Hz as the sole mitigating agent, or as an adjunct to other modes of therapy used in a multidisciplinary approach for chronic, intractable pain of the trunk and/or lower limbs, including unilateral or bilateral pain.
11. Statement of Substantial Equivalence
By definition, a device is substantially equivalent to legally marketed predicate devices when the device has the same intended use and the same technological characteristics as the previously cleared predicate device. The Freedom SCS System has the same intended use as the legally marketed predicates device and is implanted percutaneous into the epidural space ranging from T5 to L5. Performance tested verified that the Freedom SCS System complies with all applicable voluntary standards such as IEC 60601-1, AAMI ANSI ISO 14708-3, and IEC 60529. The Freedom SCS System also meets the design requirements where no applicable standard could be used. This included Receiver/RF Stylet performance testing, stimulator body durability testing, programmable parameters, as well as power and performance of the WAA. There were no recognized performance standards for this device. The materials for the subject device are the same as the legally marketed predicate device. Clinical testing with the subject device demonstrated substantial equivalence to the legally marketed predicate device. No modifications to the Freedom SCS System of K180981 were made in support of this premarket notification submission. The Freedom SCS System was always designed with the widened stimulation parameters for repetition rate and pulse width, but in predicate devices (K180981 and preceding), the software restricted these settings.
It has been shown in this 510(k) submission that the difference between the Freedom SCS System and the legally marketed predicate devices do not raise any questions regarding its safety and effectiveness as compared to legally marketed predicate devices. The Freedom SCS System, as designed and manufactured, is determined to be substantially equivalent to the referenced legally marketed predicate device.