(97 days)
The BTL-899M device is intended to be used under medical supervision for adjunctive therapy for the treatment of medical diseases and conditions.
The BTL-899M device is indicated for use in stimulating neuromuscular tissue for bulk muscle excitation in the legs or arms for rehabilitative purposes.
Indications for Use for Muscle Stimulators:
- Relaxation of muscle spasms
- Prevention or retardation of disuse atrophy
- Increasing local blood circulation
- Muscle re-education
- Immediate post-surgical stimulation of calf muscles to prevent venous thrombosis
- Maintaining or increasing range of motion
The BTL-899M is a non-invasive therapeutic device. The device is comprised of a main unit and an applicator that deliver electromagnetic energy to the targeted tissue. The device's output enables handsfree treatment.
The application of electromagnetic energy to the patient's feeling of magnetic stimulation of underlying muscles, joints and connective tissue accompanied by a pleasant feeling of warming sensation in the application area, which may contribute to increased local blood circulation and help the patient to relax and make the treatment more comfortable.
The BTL-899M is equipped with a large color touch-screen that significantly facilitates the use of the device. The on-screen information guides the user step-by-step through the entire therapy procedure. The therapeutic parameters are easily set using the touch screen of the device. During the therapy, the device displays information about the applied therapy type, remaining therapy time and main therapy parameters on the screen.
This document (K232937) is a 510(k) premarket notification for a medical device called BTL-899M, a Powered Muscle Stimulator. The key takeaway from this document is that the FDA has determined the BTL-899M device is substantially equivalent to a legally marketed predicate device (HPM-6000, K160992).
Therefore, the primary method of proving the device meets acceptance criteria is through demonstrating substantial equivalence to a predicate device by satisfying safety and performance standards for the device type, rather than conducting a separate clinical study with specific acceptance criteria as one might for a novel AI device with new claims.
Here's a breakdown of the requested information based on the provided document:
1. A table of acceptance criteria and the reported device performance
Since this is a substantial equivalence submission for a traditional medical device (Powered Muscle Stimulator) and not an AI/ML diagnostic tool, the "acceptance criteria" are primarily related to safety, electrical performance, and functional equivalence to the predicate device, demonstrated through non-clinical testing and comparison. There are no specific "performance metrics" in the sense of accuracy, sensitivity, or specificity as there would be for an AI-driven diagnostic.
| Acceptance Criteria Category | Specific Criteria (Implicitly Met) | Reported Device Performance (Summary from Document) |
|---|---|---|
| Intended Use | Identical to predicate device | Yes, BTL-899M has identical Indications for Use as HPM-6000. |
| Technological Characteristics | Similar to predicate device; differences do not raise new safety/effectiveness questions. | See detailed comparison table (pages 8-9). Key features like basic operation, energy type (electromagnetic), pulse repetition rate, magnetic field intensity, pulse duration, and pulse shape are same or comparable. Minor differences (screen size, number of applicators, therapy time) are deemed not to raise new safety/effectiveness questions. |
| Electrical Safety | Compliance with relevant IEC standards | Complies with IEC 60601-1, IEC 60601-1-2 (EMC), IEC 60601-1-6 (Usability). |
| Software Safety | Compliance with software lifecycle processes | Complies with IEC 62304. |
| Risk Management | Application of risk management principles | Complies with ISO 14971. |
| Biocompatibility | Evaluation for biological safety | Complies with ISO 10993-1, ISO 10993-5 (cytotoxicity), ISO 10993-10 (irritation/sensitization). |
| Performance (Functional) | Delivers expected magnetic and RF energy outputs within acceptable ranges. | Magnetic field intensity, pulse duration, pulse amplitude, and shape of stimulation pulse are within the range and type demonstrated by the predicate device. Addition of RF energy for warming sensation is confirmed to be subtherapeutic and monitored by a temperature sensor, and does not "raise any unacceptable risks or questions related to safety or effectiveness." |
| Therapy Time | Functionality for prescribed therapy duration | Adjustable up to 30 minutes (predicate up to 60 min). Justified that repeated use can achieve similar dosage and it does not raise safety/efficacy concerns. |
| Applicators | Delivers intended therapy output and is safe. | Single applicator (AP-C-1) with similar max output parameters to predicate's 299-1 applicator. Deemed not to raise safety/efficacy concerns. |
| Environmental | Operates within specified environmental conditions. | Meets operating ambient temperature and relative humidity criteria. |
2. Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)
The document explicitly states "Clinical Testing: Not applicable" (page 7). This means there was no clinical test set or associated data provenance (e.g., country, retrospective/prospective) in the traditional sense for evaluating device performance against a diagnostic or therapeutic outcome. The testing was primarily non-clinical (bench testing) to ensure safety and functional equivalence.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
Since there was no clinical testing or a "test set" in the context of diagnostic performance, there were no experts used to establish ground truth in this manner. The ground truth, in a regulatory context, for this type of device, is established by its compliance with recognized safety and performance standards and its comparison to an already cleared device.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set
Not applicable, as no clinical test set requiring adjudication was performed.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
Not applicable. This device is a powered muscle stimulator, not an AI-assisted diagnostic or therapeutic device that would involve human readers or AI assistance in interpretation.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This is not an AI/algorithm-driven device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
The "ground truth" for this submission is compliance with recognized standards for electrical safety, software safety, risk management, biocompatibility, and functional equivalence to the legally marketed predicate device. There is no "ground truth" related to disease diagnosis or treatment outcomes in the way one would describe it for an AI/diagnostic device.
8. The sample size for the training set
Not applicable. This is not an AI/ML device that requires a training set.
9. How the ground truth for the training set was established
Not applicable.
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Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: a symbol on the left and the FDA name and title on the right. The symbol on the left is a stylized representation of a human figure, while the text on the right reads "FDA U.S. FOOD & DRUG ADMINISTRATION" in blue letters.
December 26, 2023
BTL Industries, Inc David Chmel Official Correspondent 362 Elm Street Marlborough, Massachusetts 01752
Re: K232937
Trade/Device Name: BTL-899M Regulation Number: 21 CFR 890.5850 Regulation Name: Powered Muscle Stimulator Regulatory Class: Class II Product Code: IPF Dated: November 27, 2023 Received: November 27, 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 (the 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 available 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.
Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device"
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(https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).
Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30. Design controls; 21 CFR 820.90. Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review. the OS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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.
Heather L. Dean -S
for CDR Jitendra Virani, MS, MBA Assistant Director DHT5B: Division of Neuromodulation and Rehabilitation Devices OHT5: Office of Neurological and Physical Medicine Devices
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Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known) K232937
Device Name BTL-899M
Indications for Use (Describe)
The BTL-899M device is intended to be used under medical supervision for adjunctive therapy for the treatment of medical diseases and conditions.
The BTL-899M device is indicated for use in stimulating neuromuscular tissue for bulk muscle excitation in the legs or arms for rehabilitative purposes.
Indications for Use for Muscle Stimulators:
- · Relaxation of muscle spasms
- · Prevention or retardation of disuse atrophy
- Increasing local blood circulation
- Muscle re-education
- · Immediate post-surgical stimulation of calf muscles to prevent venous thrombosis
- · Maintaining or increasing range of motion
| 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/4/Picture/0 description: The image shows the logo for BTL Industries. The logo consists of three blue squares that are nested inside of each other. To the right of the squares is the text "BTL Industries" in a gray sans-serif font.
510(k) Summary
K232937
General Information
| Sponsor: | BTL Industries, Inc.362 Elm StreetMarlborough, MA 01752Tel: +1-866-285-1656Fax: +1-888-499-2502 |
|---|---|
| Applicant: | BTL Industries, Inc.362 Elm StreetMarlborough, MA 01752Tel: +1-866-285-1656Fax: +1-888-499-2502 |
| Contact Person: | David ChmelBTL Industries, Inc.chmel@btlnet.com |
| Summary PreparationDate: | 21 December 2023 |
Device Name
| Trade/Proprietary Name: | BTL-899M |
|---|---|
| Regulation Number: | 21 CFR 890.5850 |
| Regulation Name: | Powered Muscle Stimulator |
| Regulatory Class: | Class II |
| Product Code: | IPF |
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Image /page/5/Picture/0 description: The image shows the logo for BTL Industries. The logo consists of two parts: a geometric symbol on the left and the text "BTL Industries" on the right. The geometric symbol is made up of three nested squares, each rotated 45 degrees, and the letters "BTL" are placed inside the innermost square. The text "BTL Industries" is written in a sans-serif font and is gray in color.
Legally Marketed Predicate Device
The BTL-899M is a state-of-the-art device with accessories using the electromagnetic energy for therapeutic purposes and is substantially equivalent to the current product that is already cleared for distribution in the USA under the following 510(k) Premarket Notification number:
- HPM-6000 (K160992)
Product Description
The BTL-899M is a non-invasive therapeutic device. The device is comprised of a main unit and an applicator that deliver electromagnetic energy to the targeted tissue. The device's output enables handsfree treatment.
The application of electromagnetic energy to the patient's feeling of magnetic stimulation of underlying muscles, joints and connective tissue accompanied by a pleasant feeling of warming sensation in the application area, which may contribute to increased local blood circulation and help the patient to relax and make the treatment more comfortable.
The BTL-899M is equipped with a large color touch-screen that significantly facilitates the use of the device. The on-screen information guides the user step-by-step through the entire therapy procedure. The therapeutic parameters are easily set using the touch screen of the device. During the therapy, the device displays information about the applied therapy type, remaining therapy time and main therapy parameters on the screen.
Indications for Use
The BTL-899M device is intended to be used under medical supervision for adjunctive therapy for the treatment of medical diseases and conditions.
The BTL-899M device is indicated for use in stimulating neuromuscular tissue for bulk muscle excitation in the legs or arms for rehabilitative purposes.
Indications for Use for Muscle Stimulators:
- Relaxation of muscle spasms
- Prevention or retardation of disuse atrophy
- Increasing local blood circulation ●
- . Muscle re-education
- Immediate post-surgical stimulation of calf muscles to prevent venous thrombosis
- Maintaining or increasing range of motion
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Image /page/6/Picture/0 description: The image shows the logo for BTL Industries. The logo consists of three nested squares on the left side, with the letters "BTL" inside the innermost square. To the right of the squares is the text "BTL Industries" in a sans-serif font. The logo is in a dark blue color.
Non-clinical Testing (Performance, Bench Testing)
The BTL-899M 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 | Medical electrical equipment – Part 1: General requirements for basic safetyand essential performance |
|---|---|
| IEC 60601-1-2 | Medical electrical equipment - Part 1-2: General requirements for basic safetyand essential performance - Collateral standard: Electromagnetic compatibility– Requirements and tests |
| IEC 60601-1-6 | Medical electrical equipment - Part 1-6: General requirements for basic safetyand essential performance – Collateral standard: Usability |
| IEC 62304 | Medical device software - Software life cycle processes |
| ISO 14971 | Medical devices – Application of risk management to medical devices |
| ISO 10993-1 | Biological evaluation of medical devices – Part 1: Evaluation and testing withina risk management process |
| ISO 10993-5 | Biological evaluation of medical devices – Part 5: Tests for in vitro cytotoxicity |
| ISO 10993-10 | Biological evaluation of medical devices - Part 10: Tests for irritation and skinsensitization |
Clinical Testing
Not applicable
Technological Characteristics
The BTL-899M device has the same intended use and identical technological characteristics and principles of operation to its predicate device. The BTL-899M device and its predicate are comprised of a system console and an applicator. The system console consists of the generators, computer, and the touch-screen control panel.
The mechanism of action and technological similarities and differences between the BTL-899M device and the predicate device are described below in the comparison table. The differences do not raise any new types of safety or effectiveness questions.
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Image /page/7/Picture/0 description: The image shows the logo for BTL Industries. The logo consists of three overlapping squares with the letters B, T, and L inside them. The text "BTL Industries" is written to the right of the logo in a sans-serif font.
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Image /page/8/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" inside the innermost square. To the right of the logo is the text "BTL Industries" in a gray sans-serif font.
Comparison with the Predicate Device
| 510(k) number | K232937 | K160992 |
|---|---|---|
| Device name | BTL-899M | HPM-6000 |
| Company name | BTL Industries, Inc. | BTL Industries, Inc. |
| Product Codeand Regulation | Physical Medicine21 CFR 890.5850IPF - Stimulator, Muscle, Powered | Physical Medicine21 CFR 890.5850IPF - Stimulator, Muscle, Powered |
| Indications for Use | The BTL-899M device is intended tobe used under medical supervision foradjunctive therapy for the treatment ofmedical diseases and conditions.The BTL-899M device is indicated foruse in stimulating neuromusculartissue for bulk muscle excitation in thelegs or arms for rehabilitativepurposes.Indications for Use for MuscleStimulators:• Relaxation of muscle spasms• Prevention or retardation of disuseatrophy• Increasing local blood circulation• Muscle re-education• Immediate post-surgical stimulationof calf muscles to prevent venousthrombosis• Maintaining or increasing range ofmotion | The HPM-6000 device is intended tobe used under medical supervision foradjunctive therapy for the treatment ofmedical diseases and conditions.The HPM-6000 device is indicated foruse in stimulating neuromusculartissue for bulk muscle excitation in thelegs or arms for rehabilitativepurposes.Indications for Use for MuscleStimulators:• Relaxation of muscle spasms• Prevention or retardation of disuseatrophy• Increasing local blood circulation• Muscle re-education• Immediate post-surgical stimulationof calf muscles to prevent venousthrombosis• Maintaining or increasing range ofmotion |
| Electrical Protection | Class II, BF | Class II, BF |
| Interface | Touch screen | Touch-screen |
| Type of Energy | Electromagnetic energy for magneticstimulation and application of warmingsensation through radiofrequency | Magnetic field |
| Type of Applicator | Single magnetic coil | Single magnetic coil |
| Number of Magneticcoils in theApplicators | 1 | 1 |
| Number ofApplicators | 1 | 2 |
| Color Touch Screen | 15.6 in39.6 cm1920 x 1080 px. | 8.4 in21.3 cm800x400 pixel |
| Type of Operation | Continuous | Continuous |
| Pulse RepetitionRate - supported bythe device | 1 - 150 Hz | 1-150 Hz |
| Magnetic FieldIntensity | AP-C-1 - 0.5 to 1.8 T | 299-1 applicator: 0.5-1.8 T299-2 applicator: 0.7-2.5 T |
| Pulse Duration | AP-C-1 - 280 µs ± 20% | 299-1 applicator: 280 µs ± 20%299-2 applicator: 280 µs ± 20% |
| Pulse Amplitude | 0–100 % | 0-100 % |
| Shape ofStimulation Pulse | Sine, biphasic | Sine, biphasic |
| RF Type | bipolar | N/A |
| Max. RF Power | 30 W | N/A |
| RF Frequency | 27.12 Mhz | N/A |
| Temperature Sensor | Yes | N/A |
| Therapy Time | Up to 30 min | Up to 60 min |
| Application | Hands-free, applicator fixed by fixationbelt | Hands-free, applicator fixed in applicationarm |
| ExternalExchangeable Fuse | Yes | Yes |
| Energy Source | 100 - 240 V AC, 50-60 Hz | 100 - 240 V AC, 50-60 Hz |
| System Dimensions( $W×H×D$ ) | 23 x 39 x 29 in(592 x 985 x 730 mm) | 20×38×23 in(500 x 970 x 580 mm) |
| System Weight | 70 kg | 33 kg |
| Operating AmbientTemperature | +10°C to +30°C | +10°C to +30°C |
| Operating RelativeHumidity | 30% to 75% | 30% to 75% |
| EnvironmentalSpecifications | For indoor use onlyIn vertical position - On castors | For indoor use onlyIn vertical position - On castors |
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Image /page/9/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 interlocking squares, each with the letters "BTL" inside. The text "BTL Industries" is written in a simple, sans-serif font.
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Image /page/10/Picture/0 description: The image shows the logo for BTL Industries. The logo consists of three blue squares, each containing the letters "BTL" inside. 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.
Therapy Time
The subject device has a standard adjustable therapy duration of up to 30 minutes, which differs from the predicate device, which allows therapy to be set for up to 60 minutes. However, the device has the same output parameters as the predicate device in terms of maximum frequency, duty factor, maximum magnetic field intensity and pulse duration. If the operator deems it necessary to provide longer therapy to a patient, the subject device can be used repeatedly and the final dosage of energy delivered per the same time will be the same as for the predicate device. Therefore, this difference does not raise any unacceptable risks or unacceptable questions in relation to safety or efficacy.
Number of applicators
The applicator AP-C-1 is intended to be used with the subject device to achieve the intended purpose whereas the predicate device allows the use of one of two available applicators 299-1 or 299-2 to achieve the intended purpose of the device. The AP-C-1 applicator intended to be used with the subject device has the same maximum output parameters in terms of maximum magnetic field intensity and pulse duration as the predicator 299-1. Therefore, this difference does not raise any unacceptable risks or unacceptable questions in relation to safety or efficacy.
Weight & Dimensions
These parameters do not have any significant effect on the efficiency or safety of the device.
Additional energy and its parameters
BTL-899M incorporates application of the warming sensation on subtherapeutic level (up to 40°C) at the patient application site to increase patient convenience, soothe, and relax them during therapy. This application of additional energy does not raise any unacceptable risks or questions related to safety or effectiveness.
Temperature sensor
BTL-899M incorporates application of the warming sensation on subtherapeutic level (up to 40°C) at the patient application site to increase patient convenience, soothe and relax them during therapy. Based on this additional energy presence, there is a temperature sensor to monitor and regulate this additional modality. This application of additional energy does not raise any unacceptable risks or questions related to safety or effectiveness.
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Image /page/11/Picture/0 description: The image shows the logo for BTL Industries. The logo consists of three nested squares on the left side of the image. The text "BTL Industries" is on the right side of the image in a sans-serif font.
Substantial Equivalence
The BTL-899M device has the same intended use as its predicate device. The technological characteristics of the predicate device are similar to the BTL-899M device. Any differences between the predicate device and BTL-899M have no significant influence on safety and effectiveness of the BTL-899M device. Therefore, the BTL-899M is substantially equivalent to the predicate device.
Conclusion
Based upon the intended use and the known technical and clinical data provided in this pre-market notification, the BTL-899M device has been shown to be substantially equivalent to the currently marketed predicate device.
§ 890.5850 Powered muscle stimulator.
(a)
Identification. A powered muscle stimulator is an electrically powered device intended for medical purposes that repeatedly contracts muscles by passing electrical currents through electrodes contacting the affected body area.(b)
Classification. Class II (performance standards).