K Number
K221865
Device Name
BTL-094
Date Cleared
2023-04-14

(291 days)

Product Code
Regulation Number
890.5660
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
BTL-094 is indicated to be used for: - Relief of minor muscle aches and pains. - Temporary increase in local blood circulation. - Activation of connective tissue.
Device Description
The BTL-094 is a non-invasive therapeutic device, which uses acoustic waves in order to stimulate a local biological response in the treated tissue. The BTL-094 generates extracorporeally induced massage pulses to stimulate a local biological response in the treated tissue. The main source of acoustic waves is a piezo transducer inside the applicator. The energy transfer from the piezo transducer to the treated tissue is realized via coupling pad. The main unit is equipped with a color touch screen, which considerably simplifies its operation. The onscreen information guides the user step through the entire therapy process. A secondary screen is placed on the applicator for the presentation of the actual state of main therapy parameters. The therapeutic parameters are adjustable via touch-screen, buttons and knob. The user is able to set following therapy parameters: intensity, frequency and number of shocks.
More Information

Not Found

No
The description focuses on the physical mechanism of action (acoustic waves) and user-adjustable parameters, with no mention of AI or ML technologies.

Yes
The device is explicitly described as a "non-invasive therapeutic device" in the "Device Description" section, and its "Intended Use" clearly outlines therapeutic benefits such as pain relief and increased blood circulation.

No
The device description and intended use indicate that the BTL-094 is a therapeutic device designed to stimulate biological responses and provide pain relief, not to diagnose medical conditions.

No

The device description explicitly details hardware components such as a piezo transducer, applicator, main unit with a touch screen, and a secondary screen on the applicator, which are essential for its function.

Based on the provided information, the BTL-094 device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended uses listed are for therapeutic purposes (relief of muscle aches, increased blood circulation, connective tissue activation). These are treatments applied directly to the patient's body.
  • Device Description: The description clearly states it's a "non-invasive therapeutic device" that uses acoustic waves to stimulate a biological response in the treated tissue. This describes a physical therapy device, not a device used to examine specimens from the body.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples (blood, urine, tissue, etc.), performing tests on these samples, or providing diagnostic information based on such analysis.

IVD devices are used to examine specimens from the human body to provide information for diagnostic, monitoring, or compatibility purposes. The BTL-094 does not fit this description.

N/A

Intended Use / Indications for Use

BTL-094 is indicated to be used for:

  • Relief of minor muscle aches and pains.
  • Temporary increase in local blood circulation.
  • Activation of connective tissue.

Product codes

ISA

Device Description

The BTL-094 is a non-invasive therapeutic device, which uses acoustic waves in order to stimulate a local biological response in the treated tissue.

The BTL-094 generates extracorporeally induced massage pulses to stimulate a local biological response in the treated tissue. The main source of acoustic waves is a piezo transducer inside the applicator. The energy transfer from the piezo transducer to the treated tissue is realized via coupling pad.

The main unit is equipped with a color touch screen, which considerably simplifies its operation. The onscreen information guides the user step through the entire therapy process. A secondary screen is placed on the applicator for the presentation of the actual state of main therapy parameters. The therapeutic parameters are adjustable via touch-screen, buttons and knob. The user is able to set following therapy parameters: intensity, frequency and number of shocks.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies

Non-clinical Testing:
The BTL-094 device has been thoroughly evaluated for electrical safety. The device has been found to comply with the following applicable medical device safety standards:

  • IEC 60601-1:2005/A1:2012 Medical electrical equipment - Part 1: General requirements for basic safety and essential performance
  • IEC 60601-1-2:2014 Medical electrical equipment – Part 1-2: General requirements for basic safety and essential performance - Collateral standard: Electromagnetic disturbances - Requirements and tests
  • IEC 60601-1-6:2010/A1:2013 Medical electrical equipment - Part 1-6: General requirements for basic safety and essential performance - Collateral standard: Usability
  • IEC 60601-2-36:2014 Medical electrical equipment - Part 2-36: Particular requirements for the basic safety and essential performance of equipment for extracorporeally induced lithotripsy
  • IEC 62304:2006/A1:2015 Medical device software – Software lifecycle processes
  • ISO 14971:2019 Medical devices - Application of risk management to medical devices
  • ISO 10993-1:2018 Biological evaluation of medical devices – Part 1: Evaluation and testing within a risk management process
  • ISO 10993-5:2009 Biological evaluation of medical devices - Part 5: Tests for in vitro cytotoxicity
  • ISO 10993-10:2010 Biological evaluation of medical devices – Part 10: Tests for irritation and skin sensitization

Clinical Testing:
Not applicable

Key Metrics

Not Found

Predicate Device(s)

K173692, K220538

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 890.5660 Therapeutic massager.

(a)
Identification. A therapeutic massager is an electrically powered device intended for medical purposes, such as to relieve minor muscle aches and pains.(b)
Classification. Class I (general controls). The device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter, subject to the limitations in § 890.9.

0

Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health and Human Services logo on the left and the FDA logo on the right. The FDA logo is a blue square with the letters "FDA" in white, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue.

April 14, 2023

BTL Industries Inc. David Chmel VP of Operations 362 Elm Street Marlborough, Massachusetts 01752

Re: K221865

Trade/Device Name: BTL-094 Regulation Number: 21 CFR 890.5660 Regulation Name: Therapeutic Massager Regulatory Class: Class I Product Code: ISA Dated: March 20, 2023 Received: March 20, 2023

Dear David Chmel:

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/cdrh/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

1

requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (OS) 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Amber T. Ballard -S

Amber Ballard, PhD Assistant Director DHT5B: Division of Neuromodulation and Physical Medicine Devices OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K221865

Device Name BTL-094

Indications for Use (Describe) BTL-094 is indicated to be used for:

  • Relief of minor muscle aches and pains.
  • Temporary increase in local blood circulation.
  • Activation of connective tissue.
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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

3

Image /page/3/Picture/0 description: The image shows the logo for BTL Industries. The logo consists of a blue geometric design on the left and the text "BTL Industries" on the right. The geometric design is made up of three squares, each nested inside the other.

510(k) Summary

General Information

| Sponsor: | BTL Industries, Inc.
362 Elm Street
Marlborough, MA 01752
Tel: +1-866-285-1656
Fax: +1-888-499-2502 |
|------------------------------|-----------------------------------------------------------------------------------------------------------------|
| Applicant: | BTL Industries, Inc.
362 Elm Street
Marlborough, MA 01752
Tel: +1-866-285-1656
Fax: +1-888-499-2502 |
| Contact Person: | David Chmel
BTL Industries, Inc.
chmel@btlnet.com |
| Summary Preparation
Date: | April 14, 2023 |

Device Name

Trade/Proprietary Name:BTL-094
Primary Classification Name:Therapeutic Massager
Common/Usual Name:Therapeutic Massager
Classification Regulation:21 CFR 890.5660, Class I
Classification Product Code:ISA

4

Legally Marketed Predicate Device

The BTL-094 is a state-of-the-art device substantially equivalent to the following products, which are already cleared for distribution in the USA under the following 510(k) Premarket Notification number:

Product Description

The BTL-094 is a non-invasive therapeutic device, which uses acoustic waves in order to stimulate a local biological response in the treated tissue.

The BTL-094 generates extracorporeally induced massage pulses to stimulate a local biological response in the treated tissue. The main source of acoustic waves is a piezo transducer inside the applicator. The energy transfer from the piezo transducer to the treated tissue is realized via coupling pad.

The main unit is equipped with a color touch screen, which considerably simplifies its operation. The onscreen information guides the user step through the entire therapy process. A secondary screen is placed on the applicator for the presentation of the actual state of main therapy parameters. The therapeutic parameters are adjustable via touch-screen, buttons and knob. The user is able to set following therapy parameters: intensity, frequency and number of shocks.

The mechanism of action and technological similarities and differences between the BTL-094 device and the predicate devices are described below in the comparison table. The differences do not raise any new types of safety or effectiveness questions.

Indications For Use

BTL-094 is indicated to be used for:

  • Relief of minor muscle aches and pains.
  • Temporary increase in local blood circulation.
  • Activation of connective tissue.

5

Image /page/5/Picture/0 description: The image shows the logo for BTL Industries. The logo consists of a blue geometric design on the left and the text "BTL Industries" on the right. The geometric design is made up of three squares, each containing the letters "B", "T", and "L" respectively.

Non-clinical Testing

The BTL-094 device has been thoroughly evaluated for electrical safety. The device has been found to comply with the following applicable medical device safety standards:

| IEC 60601-1:2005/A1:2012
FR Recognition Number: 19-4 | Medical electrical equipment - Part 1: General requirements for
basic safety and essential performance |
|-----------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| IEC 60601-1-2:2014
FR Recognition Number: 19-8 | Medical electrical equipment – Part 1-2: General requirements for
basic safety and essential performance - Collateral standard:
Electromagnetic disturbances - Requirements and tests |
| IEC 60601-1-6:2010/A1:2013
FR Recognition Number: 5-89 | Medical electrical equipment - Part 1-6: General requirements for
basic safety and essential performance - Collateral standard:
Usability |
| IEC 60601-2-36:2014
FR Recognition Number: 9-119 | Medical electrical equipment - Part 2-36: Particular requirements for
the basic safety and essential performance of equipment for
extracorporeally induced lithotripsy |
| IEC 62304:2006/A1:2015
FR Recognition Number: 13-79 | Medical device software – Software lifecycle processes |
| ISO 14971:2019
FR Recognition Number: 5-125 | Medical devices - Application of risk management to medical
devices |
| ISO 10993-1:2018
FR Recognition Number: 2-258 | Biological evaluation of medical devices – Part 1: Evaluation and
testing within a risk management process |
| ISO 10993-5:2009
FR Recognition Number: 2-245 | Biological evaluation of medical devices - Part 5: Tests for in vitro
cytotoxicity |
| ISO 10993-10:2010
FR Recognition Number: 2-174 | Biological evaluation of medical devices – Part 10: Tests for
irritation and skin sensitization |

Clinical Testing

Not aplicable

Technological Characteristics

The BTL-094 is a non-invasive therapeutic device, which uses acoustic waves in order to stimulate a local biological response in the treated tissue.

The BTL-094 generates extracorporeally induced massage pulses to stimulate a local biological response in the treated tissue. The main source of acoustic waves is a piezo transducer inside the applicator. The energy transfer from the piezo transducer to the treated tissue is realized via coupling pad.

6

The mechanism of action and technological similarities and differences between the BTL-094 device and the predicate devices are described below in the comparison table. The differences do not raise any new types of safety or effectiveness questions.

Comparison with the Predicate Device
--------------------------------------------

| 510(k)

numberK221865K173692K220538
Device nameBTL-094D-Actor 200DolorClast®
Radial
Company
nameBTL Industries Inc.Storz MedicalEMS Electro
Medical SA
Indications for
UseRelief of minor
muscle aches and
pains
Temporary increase
in local blood
circulation
Activation of
connective tissue*Relief of minor
muscle aches and
pains
*Temporary increase
in local blood
circulation
*Activation of
connective tissue- Relief of minor
muscle aches and
pains.
  • Temporary
    increase in local
    blood circulation.
  • Activation of
    connective tissue. | None |
    | Product Code
    and
    Regulation | 21 CFR
    890.5660
    ISA | 21 CFR
    890.5660
    ISA | 21 CFR
    890.5660
    ISA | None |
    | Modes of
    Action | Extracorporeally
    induced pressure
    waves. | Radial pressure
    waves, or
    extracorporeal pulse
    activation
    respectively | Radial pressure
    waves, or
    extracorporeal
    pulse activation
    respectively | Not Significantly
    different
    Please see the
    discussion and
    conclusion below. |
    | Mechanisms of
    Action | Vibrations generated
    by electroacoustic
    technology. | Pneumatically
    generated vibrations | Pneumatically
    generated
    vibrations | Not Significantly
    different
    Please see the
    discussion and
    conclusion below. |
    | Maximum and
    Minimum
    intensity
    settings | 5-30%
    alternative output
    power setting scale | 1-5bar | 1-4bar | Not Significantly
    different
    Differences are
    caused by
    alternative
    technology of the
    pressure wave
    generation. |
    | Number and
    size of
    treatment
    applicator
    heads | 2;
    L Pad - 12.2 cm²
    U Pad - 7.3 cm² | 4;
    6mmOD, 15mmOD,
    20mmOD, 35mmOD | 7;
    5mm OD, 10 mm
    OD, 15 mm OD, 25
    mm OD, 40 mm OD | Not Significantly
    different
    The application
    area of the pads in
    contact with the
    patient is within the
    set range of the
    predicate devices.
    All materials in
    contact with the
    patient have been
    assessed for
    biocompatibility |
    | Maximum and
    minimum
    displacements
    of applicator
    heads | N/A | 0.6 - 2.0mm | 0.18 - 0.28 mm | N/A
    The BTL-094
    applicator does not
    have any moving
    parts that come in
    contact with the
    patient. |
    | Type of
    application
    (e.g.,
    continuous
    vibration at a
    fixed
    frequency); | Continuous vibration
    at a fixed frequency
    and single pulse
    mode | Continuous vibration
    at a fixed frequency | Continuous
    vibration at a fixed
    frequency | None |
    | Maximum and
    minimum
    vibration
    frequency | 1-25 Hz | 1-21Hz | 1-25 Hz | Not Significantly
    different |
    | Power Supply | 100 V to 240 V AC
    50 - 60 Hz
    150VA | 500VA | Mains power | None |
    | Maximum
    penetration
    depth | 35 mm | 32.3mm | 40 mm | Not Significantly
    different
    Please see the
    discussion and
    conclusion below. |
    | Energy flow
    density | In the range of
    0.01 - 0.11 mJ/mm2 | Values of ultrasonic
    pulse:
    5bar/0.284mJ/mm2
    3bar/0.176mJ/mm2 | 0.29 mJ/mm2 at 4
    bar
    0.14 mJ/mm2 at 2.4
    bar | Not Significantly
    different |
    | Operating
    mode | Continuous | Continuous | Continuous | None |
    | Projectile
    mass (g) | N/A | 3 | 3.2 | Not applicable
    The BTL-094
    applicator does not
    contain a projectile. |
    | Pulse repeat
    rate (1/s) | 1-25 Hz | 1-21Hz | 1-25 Hz | Not Significantly
    different |
    | Number of
    pulses (min
    and max) | Variable in range
    0 – 9999 | Variable | Variable,
    Max
    5000/treatment | Not Significantly
    different |
    | Maximum
    operating
    temperature | 10 - 35 °C | 10-40°C | 10 - 30 °C | Not Significantly
    different |
    | Type of
    acoustic wave
    generation | Electroacoustic
    technology with
    electroacoustic lens
    system | Pneumatic/ballistic | Pneumatic/ballistic | Not Significantly
    different
    Differences are
    caused by
    alternative
    technology of the
    pressure wave
    generation. |
    | Positive peak
    pressure
    amplitude
    (MPa) | In the range of
    3 - 10 MPa | Values of ultrasonic
    pulse: 5bar/18.5MPa
    3bar/13.4MPa | 17 MPa at 4 bar
    11.24 MPa at 2.4
    bar | Not Significantly
    different
    Please see the
    discussion and
    conclusion below. |
    | Negative peak
    pressure
    amplitude
    (MPa) | In the range of
    3 - 10 MPa | Values of ultrasonic
    pulse: 5bar/6.8MPa
    3bar/5.0MPa | 10 MPa at 4 bar
    7.2 MPa at 2.4 bar | Not Significantly
    different
    Please see the
    discussion and
    conclusion below. |
    | Derived focal
    acoustic pulse
    energy (mJ) | In the range of
    0.1 – 1.4 mJ | Values of ultrasonic
    pulse: 5bar/6.5mJ
    3bar/2.4mJ | 5.9 mJ at 4 bar*
    2.2 mJ at 2.4 bar*
    *Averaged across
    all applicator sizes. | Not Significantly
    different
    Please see the
    discussion and
    conclusion below. |
    | Derived
    pulse-
    intensity
    integral,
    integrated over
    total temporal
    integration
    limits
    (mJ/mm2) | In the range of
    0.01 - 0.11 mJ/mm2 | Values of ultrasonic
    pulse:
    5bar/0.284mJ/mm2
    3bar/0.176mJ/mm2 | 0.29 mJ/mm2 at 4
    bar
    0.14 mJ/mm2 at 2.4
    bar | Not Significantly
    different
    Please see the
    discussion and
    conclusion below. |
    | Rise time (ns) | 10 ns | Ultrasonic pulse:
    2.5µs | 3.2 µs | Not Significantly
    different |
    | | | Sonic pulse: 25µs –
    2.5ms | | Differences are
    caused by
    alternative
    technology of the
    energy generation. |
    | Compressional
    pulse duration
    (μs) | 2µs | Ultrasonic pulse:
    5.0µs Sonic pulse:
    50µs – 5.0ms | 2.6 µs (1st peak)
    62.7 µs (1st phase) | Not Significantly
    different |

7

Image /page/7/Picture/0 description: The image shows the logo for BTL Industries. The logo consists of three interconnected blue squares with the letters "BTL" inside. To the right of the logo, the words "BTL Industries" are written in a modern, sans-serif font. The text is in a dark gray color.

8

Image /page/8/Picture/0 description: The image shows the logo for BTL Industries. The logo consists of three nested squares with the letters "BTL" inside the innermost square. To the right of the logo is the text "BTL Industries" in a sans-serif font.

9

Image /page/9/Picture/0 description: The image shows the logo for BTL Industries. The logo consists of three blue squares nested inside each other, with the letters "BTL" in white inside the innermost square. To the right of the square logo is the text "BTL Industries" in a gray sans-serif font.

Modes of Action, Mechanisms of Action

The technology used in BTL-094 device differs from the predicate device. Nevertheless, the technology creates the same type of acoustic pressure delivered to the tissue. Similar devices that generate a pressure wave based on a different technological principle but with the same or very comparable mechanism of action have already been recognised as substantially equivalent in this device category.

Maximum and Minimum intensity settings

BTL-094 has an alternative type of technology from the predicate device and therefore the BTL-094 device has an alternative power setting scale - in percentage and not in bars as a comparative device has. In addition, for comparability with the predicate devices the BTL-094 device intended for the US market is limited to a maximum power level of 30% of maximum driving power.

Number and size of treatment applicator heads

The number of application pads are different from predicate device but the area of the subjected device pads that is in contact with the patient is comparable within a set range to the contact area of application tips of predicate devices. Additionally all materials in contact with patient have been assessed for biocompatibility and the maximal depth of pressure wave penetration is comparable to the predicate.

Maximum and minimum displacements of applicator heads

The predicate device is generating the pressure wave by the head displacement. Due to an alternative type of technology used for pressure wave generation the BTL-094 device does not have the ability of displacements of applicator heads/pads.

Maximum and minimum vibration frequency

BTL-094 device differs from one predicate device in the value of the maximum frequency, where the frequency value of the BTL-094 device can be up to 4Hz higher than the predicate device, but has available the same frequency range as its second predicate device.

Driving Power

BTL-094 device has an alternative type of technology from the predicate device and therefore the driving power parameter is not applicable. In addition, for comparability with the predicate devices the BTL-094 device intended for the US market is limited to a maximum power level of 30% of maximum driving power.

Energy flow density

BTL-094 device uses alternative technology and is able to better pulse targeting, a maximum driving power of the device has been limited at a maximum power level of 30%. The EFD of our device differs from the predicates but it is lower or within setting range of predicat devices.

10

Image /page/10/Picture/0 description: The image shows the logo for BTL Industries. The logo consists of a geometric design on the left and the text "BTL Industries" on the right. The geometric design is made up of three squares, each rotated 45 degrees and nested inside the other. The text "BTL Industries" is written in a sans-serif font.

Operating mode

The BTL-094 device has two modes of operation: single therapy mode or sequence mode. The two modes differ based on repetition of therapy sections and settings that can be done during the running therapy. Nevertheless, both the modes have a character of continual therapy.

Maximum penetration depth

The BTL-094 device is equipped with two different coupling pad sizes, which allow it to reach up to 35 mm depth. This penetration depth is comparable within setting range of predicate devices.

Pulse repeat rate (1/s)

BTL-094 device differs from one predicate device in the value of the maximum frequency, where the frequency value of the BTL-094 device can be up to 4Hz higher than the predicate device, but has available the same frequency range as its second predicate device.

Number of pulses (min and max)

BTL-094 device allows to set a variable number of pulses according to the user's needs. This parameter is similar as for the predicate device.

Type of acoustic wave generation

The subject device provides the therapy by the application of extracorporeally induced acoustic pressure waves that are generated by means of piezoelectric principle. The device is designed with planar piezoelement and acoustic lens quiding the waves. The generated wave is coupled to biological tissue via the coupling gel pads of the applicator.

This technology creates the same type of acoustic pressure wave with comparable parameters therefore it reach the same mechanism of action as the predicate devices.

Positive peak pressure amplitude (MPa)

A maximum driving power of the BTL-094 has been limited at a maximum power level of 30%. The device with this limitation in maximal output power fits with output parameters within or bellow setting range of predicat devices and is not significantly different from the predicate devices.

Negative peak pressure amplitude (MPa)

A maximum driving power of the BTL-094 has been limited at a maximum power level of 30%. The device with this limitation in maximal output power fits with output parameters within or bellow setting range of predicat devices and is not significantly different from the predicate devices.

Derived focal acoustic pulse energy (mJ)

A maximum driving power of the BTL-094 has been limited at a maximum power level of 30%. The device with this limitation in maximal output power fits with output parameters within or bellow setting range of predicat devices and is not significantly different from the predicate devices.

Derived pulse- intensity integrated over total temporal integration limits (m.J/mm2)

A maximum driving power of the BTL-094 has been limited at a maximum power level of 30%. The device with this limitation in maximal output power parameters within or bellow setting range of predicat devices and is not significantly different from the predicate devices.

Rise time (ns)

BTL-094 has an alternative type of technology from the predicate device and therefore the BTL-094 device is able to reach a faster rise time and shorter compressional pulse duration.

11

Image /page/11/Picture/0 description: The image shows the logo for BTL Industries. The logo consists of three blue interlocking squares on the left, with the letters "BTL" inside the squares. To the right of the squares is the text "BTL Industries" in a gray sans-serif font. The logo is simple and modern, and the use of blue and gray gives it a professional look.

Compressional pulse duration (µs)

BTL-094 has an alternative type of technology from the predicate device and therefore the BTL-094 device is able to reach a faster rise time and shorter compressional pulse duration.

Substantial Equivalence

The BTL-094 is substantially equivalent to the predicate devices D-Actor (K173692) and DolorClast® Radial (K220538). The subject device is safe and effective for its intended use.

Any differences between the predicate devices and BTL-094 have no significant influence on the safety or effectiveness of the subject device. Therefore, the BTL-094 is substantially equivalent to the predicate devices.

Conclusion

Based upon the intended use and known technical information provided in this pre-market notification, the BTL-094 device has been shown to be substantially equivalent to the currently marketed predicate device.