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510(k) Data Aggregation

    K Number
    K121757
    Date Cleared
    2012-11-20

    (158 days)

    Product Code
    Regulation Number
    882.5890
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    HEALTHMATE INTERNATIONAL, LLC

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    TENS: To be used for temporary relief of pain associated with sore and aching muscles in the shoulder, waist, back, neck, upper extremities (arm), and lower extremities (leg) due to strain from exercise or normal household work activities.
    PMS: It is intended to be used to stimulate healthy muscles in order to improve and facilitate muscle performance.

    Device Description

    Pro-8AB is portable; battery powered (3.7V DC) multi-function device offering both Transcutaneous Electrical Nerve Stimulator (TENS) and Powered Muscle Stimulator (PMS) qualities in one device. Double or single channel that effectively transfer your desired choice of programmed electrical pulses directly through electrode adhesive pads to the suggested area of the body where the electrodes are placed, causing minimal muscle contractions. There are 6 modes of operations.

    AI/ML Overview

    The provided document is a 510(k) summary for the HealthmateForever TENS and Powered Muscle Stimulator device. It describes the device, its intended use, and its substantial equivalence to a predicate device (JQ-5C).

    Here's an analysis of the acceptance criteria and study information based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    The submission does not explicitly state "acceptance criteria" in terms of specific performance metrics that need to be met for the device to be considered safe and effective in a clinical trial. Instead, the submission focuses on demonstrating substantial equivalence to a predicate device. The performance is reported in terms of various electrical output parameters.

    Acceptance Criteria (Implied by Substantial Equivalence Goal)Reported Device Performance (HealthmateForever Models)Predicate Device (JQ-5C) Performance
    Electrical Output Parameters within Safe & Effective Range Compared to Predicate
    Max Voltage over 10kΩ, V10084
    Max. Current over 10kΩ, mA108.4
    Max. Voltage over 2.2KΩ, V9079.2
    Max. Current over 2.2KΩ, mA4539.6
    Max. Voltage over 500Ω, V7062.4
    Max. Current over 500Ω, mA140124.8
    Pulse Width, µseconds90100
    Pulse period, msec10-83616.3-781
    Max. Pulse Frequency, Hz10061.3
    Max Charge per Phase over 500Ω, µC15.6617.92
    Max Current Density over 500Ω, mA/cm2 (Various Modes)See table in Section 79.92
    Max. Average Power Density over 500Ω, mW cm2 (Various Modes)See table in Section 72.72
    Max Current Density over 500Ω, mA/cm2 (Various Modes)See table in Section 79.92
    Max. Average Power Density over 500Ω, mW cm2 (Various Modes)See table in Section 72.72
    Safety Standards ComplianceIEC 60601-1, IEC 60601-1-2, IEC 60601-2-10, ISO 10993-5, ISO 10993-10(Implied for predicate to be cleared)
    Software VerificationCarried out according to FDA Guidance(Not specified for predicate)
    No new safety or effectiveness issues"The differences that exist between the devices are insignificant in the terms of safety or effectiveness."(Implied for predicate to be cleared)
    No adverse events reportedOver 100,000 units sold since 2007 in Europe and Asia with no adverse effects reported.(Not specified for predicate)
    Improved muscle performance and temporary pain reductionSupported by "customer reviews"(Implied for predicate effectiveness)

    2. Sample Size Used for the Test Set and the Data Provenance

    The document does not describe a traditional clinical study with a "test set" of patients or data to evaluate effectiveness. The primary basis for equivalence is non-clinical testing and comparison of technical specifications to a predicate device.

    • Sample Size for Test Set: Not applicable for a traditional clinical study as presented.
    • Data Provenance: The document mentions "over 100,000 units sold without a prescription in Europe and Asia" since 2007 with no adverse events reported. This suggests retrospective market surveillance data for safety. The "customer reviews" for effectiveness are not quantifiable in terms of sample size or provenance.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts

    Not applicable. No clinical test set requiring expert ground truth establishment for effectiveness or diagnosis is described.

    4. Adjudication Method for the Test Set

    Not applicable. No clinical test set requiring adjudication is described.

    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 TENS and PMS device, not an AI-powered diagnostic or interpretive tool. Therefore, MRMC studies are not relevant.

    6. If a Standalone (i.e. algorithm only without human-in-the loop performance) was done

    Not applicable. This device is a physical electrotherapy device; it does not involve algorithms for interpretation or without-human-in-the-loop performance measurement in the context of AI. The "software verification" mentioned is for the device's internal control software, not a standalone diagnostic algorithm.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    For safety, the "ground truth" relies on the absence of reported adverse events from extensive market use in Europe and Asia (outcomes/real-world data).
    For effectiveness, the claim is supported by "customer reviews," which are anecdotal and not considered a rigorous form of ground truth in clinical studies. The primary justification for effectiveness is via substantial equivalence to a predicate device, meaning the predicate's established effectiveness serves as the basis.

    8. The Sample Size for the Training Set

    Not applicable. No training set for an AI/machine learning model is mentioned or described.

    9. How the ground truth for the training set was established

    Not applicable. No training set for an AI/machine learning model is mentioned or described.


    Summary of the Study that Proves the Device Meets Acceptance Criteria:

    The "study" presented here is a 510(k) Premarket Notification which aims to demonstrate substantial equivalence to a previously cleared predicate device (JQ-5C). This is a regulatory pathway that largely relies on comparing the new device's technological characteristics, intended use, and safety profile to a legally marketed device, rather than conducting new, extensive clinical trials for effectiveness in many cases.

    The evidence for meeting acceptance criteria (which are primarily implied by the substantial equivalence framework) includes:

    • Comparison of Technical Specifications: A detailed table (Section 7) is provided comparing various electrical output parameters (voltage, current, pulse width, frequency, charge per phase, current density, power density) of the new HealthmateForever models to the predicate device (JQ-5C). The submission states that the differences are "insignificant in the terms of safety or effectiveness."
    • Compliance with Voluntary Standards: The device underwent non-clinical tests to comply with several IEC and ISO standards related to medical electrical equipment safety, electromagnetic compatibility, and biocompatibility (IEC 60601-1, IEC 60601-1-2, IEC 60601-2-10, ISO 10993-5, ISO 10993-10).
    • Software Verification: Software verification was performed adhering to FDA guidance.
    • Real-world Safety Data (Retrospective Market Surveillance): For safety, the submission highlights the sale of "over 100,000 units" in Europe and Asia since 2007 with "no adverse effects reported." This serves as a retrospective, large-scale safety assessment.
    • Customer Reviews (Effectiveness Support): For effectiveness, the submission briefly mentions "customer reviews" demonstrating improved muscle performance and temporary pain reduction. This is a weak form of evidence and is secondary to the substantial equivalence claim, which assumes effectiveness based on the predicate.
    • Intended Use Alignment: The intended uses for both TENS and PMS functions are identical to those of the predicate device.

    In essence, the "study" is a systematic comparison to a predicate device combined with non-clinical bench testing for safety standards and retrospective real-world safety data, rather than a prospective clinical trial with a defined test set and ground truth established by experts.

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