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510(k) Data Aggregation

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

    The Neurological Theray Devices - Accessories including Garment electrodes which are intended to be used with legally marketed electrical stimulating devices such as transcutaneous electrical nerve stimulators or powered muscle stimulators. The cutaneous electrodes will deliver the stimulation signals generated by the stimulator to the body surface with which they are in contact. The Garment electrodes including glove, socks, sleeve, knee belt and back belt which are made up of silver or conductive silicone rubber.

    Device Description

    The Neurological Therapy Devices - Accessories -Conductive fiber(Model:Electrotherapy device Electrode for Knee, Electrotherapy device Electrode for Elbow, Electrotherapy device Electrotherapy device Electrode socks.Neurological physiotherapy devices-accessories), are conductive garments that are made from material which is knitted from primarily nylon yarn with minor amounts of lycra, spandex to achieve a stretch fabric for a snug garment fit polyester for tactile qualities and polyester sheathed carbon yarn and pure silver coated nylon fibers to provide conductivity. The knitting follows standard knitting procedures with the conductive knitted material being fabricated into Neurological Therapy Devices - Accessories garments which are provided in multiple sizes of various garment configurations including; gloves, bands, socks, and sleeves.

    The Neurological Therapy Devices - Accessories-conductive silicone rubber(Model:Electrotherapy device Electrode belt for back of body, Electrotherapy device Electrode belt for Abdominal Muscle TrainerToning, Electrotherapy device Electrode belt for Body joints,Electrotherapy device Electrode belt for arm of body,Electrotherapy device Electrode belt for back of body,Electrotherapy device Electrode belt for shoulder of body,Neurological physiotherapy devices-accessories), is made of conductive silicone rubber coated in conductive garments material, has excellent conductive performance and good flexibility and plasticity, can adapt to the needs of different shapes and sizes of electrodes.

    The stretch characteristics of the material provide sufficient elasticity to ensure firm surface contact with the skin. The design of the devices is such that they can be used skin by reversing the surface contacting the skin.

    The Neurological Therapy Devices - Accessories utilize conductive silicone rubber as a conduit for current transmission. When current passes through the garment electrodes, the conductive silicone rubber transmit the current to the surface of the body, thus enabling the transmission of current. The entire surface of the Neurological Therapy Devices - Accessories is very conductive having a resistance of less than 7 ohms per inch. This provides low current density with uniform current distribution to enable efficient use of these Neurological Therapy Devices - Accessories for use in TENS (transcutaneous electrical nerve stimulators) and NMES (powered muscle stimulator devices).

    The Neurological Therapy Devices - Accessories are non- sterile external devices which are designed for single patient, for multiple uses and are intended for Prescription Use and/or OTC use with FDA Cleared TENS and NMES class II devices.

    AI/ML Overview

    The provided FDA 510(k) summary (K232995) describes the acceptance criteria and the study conducted to demonstrate that the Neurological Therapy Devices - Accessories meet these criteria.

    Here's a breakdown of the requested information:

    1. A table of acceptance criteria and the reported device performance

    Acceptance Criteria CategorySpecific CriteriaReported Device Performance
    Material (Biocompatibility)Compliant with ISO 10993-5:2009 (Cytotoxicity)Compliant
    Compliant with ISO 10993-23:2021 (Skin Sensitization)Compliant
    Compliant with ISO 10993-10:2021 (Skin Irritation)Compliant
    Electrical PerformanceResistivity less than 7 ohms per inchLess than 7 ohms per inch (through multiple washings)
    Uniform delivery of low doses of current to the skinAchieved during bench testing
    Durability/ReusableMaintain inherent conductivity with multiple washingsBench testing confirmed no significant adverse effect on conductivity after multiple washings
    Intended UseTo be used with legally marketed electrical stimulating devices (TENS/NMES) to deliver stimulation signalsThe device is designed and demonstrated to work with such devices.

    2. Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)

    • Sample Size for Test Set: The document explicitly states "No clinical testing was performed" (Section 8). Therefore, there isn't a "test set" in the context of human subjects or clinical data. The performance was evaluated through non-clinical bench testing. The sample sizes for the materials tested in biocompatibility and electrical performance bench tests are not specified in this summary.
    • Data Provenance: The company is Shenzhen Roundwhale Technology Co., Ltd. in China. The testing would presumably have been conducted in China or by laboratories contracted by the company, adhering to international standards. The data is non-clinical (bench testing).

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g., radiologist with 10 years of experience)

    Not applicable. As no clinical testing was performed, there was no "test set" requiring expert ground truth establishment in a clinical context. The performance was assessed against technical specifications and international standards in a laboratory setting.

    4. Adjudication method (e.g., 2+1, 3+1, none) for the test set

    Not applicable. There was no clinical test set requiring adjudication.

    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 an accessory (an electrode) for electrotherapy devices, not an AI-powered diagnostic or assistive tool. Therefore, an MRMC study related to human reader performance with or without AI assistance is irrelevant and was not conducted.

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

    Not applicable. This is not an algorithm-only device. It is a physical accessory (electrode). The "standalone" performance refers to the device's electrical conductivity and biocompatibility, which were assessed via bench testing as described.

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

    The "ground truth" for this device's performance is based on:

    • International Standards: Specifically, ISO 10993 series for biocompatibility testing (ISO 10993-5, ISO 10993-10, ISO 10993-23).
    • Technical Specifications: Defined electrical performance criteria (e.g., resistivity less than 7 ohms per inch).
    • Comparison to Predicate Devices: Demonstrating similarity in design, materials, function, and performance to legally marketed devices.

    8. The sample size for the training set

    Not applicable. As this device is a physical cutaneous electrode and not an AI/machine learning model, there is no "training set."

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

    Not applicable, as there is no training set for this device.

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    K Number
    K231440
    Date Cleared
    2023-11-03

    (169 days)

    Product Code
    Regulation Number
    890.5850
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Model:R-C101W:

    • For TENS/IF/MIC mode
      1. Symptomatic relief of chronic intractable pain
      1. Post traumatic pain
      1. Post surgical pain
    • For EMS/RUSS mode
      1. Relaxation of muscle spasm.
      1. Increase of local blood flow circulation
      1. Prevention or retardation of disuse atrophy
      1. Muscle re-education
      1. Maintaining or increasing range of motion.
      1. Immediate post-surgical stimulation of muscles to prevent venous thrombosis

    Model:R-C101A

    • For TENS/IF mode
      1. Symptomatic relief of chronic intractable pain.
      1. Post traumatic pain.
      1. Post surgical pain.
    • For EMS/RUSS mode
      1. Relaxation of muscle spasm.
      1. Increase of blood flow circulation.
      1. Prevention or retardation of disuse atrophy.
      1. Muscle re-education.
      1. Maintaining or increasing range of motion.
      1. Immediate post-surgical stimulation of muscles to prevent venous thrombosis

    Model:R-C101B
    For TENS/IF mode

      1. Symptomatic relief of chronic intractable pain
      1. Post traumatic pain
      1. Post surgical pain
    • For EMS/RUSS mode
      1. Relaxation of muscle spasm.
      1. Increase of local blood flow circulation
      1. Prevention or retardation of disuse atrophy
      1. Muscle re-education
      1. Maintaining or increasing range of motion.
      1. Immediate post-surgical stimulation of muscles to prevent venous thrombosis

    Model:R-C101E
    For IF mode

      1. Symptomatic relief of chronic intractable pain
      1. Post traumatic pain
      1. Post surgical pain
        For RUSS mode
      1. Relaxation of muscle spasm.
      1. Increase of local blood flow circulation
      1. Prevention or retardation of disuse atrophy
      1. Muscle re-education
      1. Maintaining or increasing range of motion.
      1. Immediate post-surgical stimulation of muscles to prevent venous thrombosis

    Model:R-C101H
    For TENS and IF mode

      1. Symptomatic relief of chronic intractable pain.
      1. Post traumatic pain.
      1. Post surgical pain.

    Model:R-C101D
    For TENS mode

      1. Symptomatic relief of chronic intractable pain
      1. Post traumatic pain
      1. Post surgical pain

    Model:R-C101G
    For TENS mode

      1. Symptomatic relief of chronic intractable pain.
      1. Post traumatic pain.
      1. Post surgical pain.
        For EMS mode
      1. Relaxation of muscle spasm.
      1. Increase of local blood flow circulation
      1. Prevention or retardation of disuse atrophy
      1. Muscle re-education
      1. Maintaining or increasing range of motion.
    1. Immediate post-surgical stimulation of muscles to prevent venous thrombosis
    Device Description

    The Combo Electrotherapy Device (Models: R-C101W, R-C101B, R-C101E, R-C101H, R-C101D, and R-C101G) is a Transcutaneous Electrical Nerve Stimulator. The device features two independent output channels and four selfadhesive electrode gel pads. The stimulator sends a gentle electrical current to the underlying nerves and muscle groups via electrodes applied on the skin. Users can choose from pre-set programs or specify their own to suit their individual needs. All controls and indicators are controlled by software which also controls waveform characteristics. The 7 models have similar housing with a viewable LCD display and an accessible keypad. The LCD is located on the upper half of the rectangular face of the device above the keypad. It is used to display system information to the user. The device is battery-powered but can be connected to an external power supply its internal battery which is a non-user serviceable or accessible 3.7V D.C., Li-ion battery. There are only two external connections on the device - power input and electrode connector - with no connection to any other devices. The Battery Charger is not included in the package; however, users can choose adapters that meet IEC 60601-1 medical stardards.

    AI/ML Overview

    The provided document is a 510(k) Premarket Notification for a "Combo Electrotherapy Device." It establishes substantial equivalence to a predicate device, K171978. The document primarily focuses on non-clinical performance and safety data, as no clinical data was performed.

    Here's a breakdown of the acceptance criteria and the study that proves the device meets them, based solely on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria for this device are largely based on demonstrating equivalence to the predicate device (K171978) in technical characteristics and compliance with relevant safety standards. The reported device performance is presented as a comparison to the predicate device.

    Acceptance Criteria CategorySpecific Criteria (Implicitly based on Predicate Device)Reported Device Performance (New Device K231440)Discussion
    Indications for UseSame indications as predicate: Symptomatic relief of chronic intractable pain, post-traumatic pain, post-surgical pain (TENS/IF/MIC); Relaxation of muscle spasm, increased local blood flow, prevention/retardation of disuse atrophy, muscle re-education, maintaining/increasing range of motion, immediate post-surgical stimulation to prevent venous thrombosis (EMS/RUSS).Primarily the same across all models (R-C101W, R-C101A, R-C101B, R-C101E, R-C101H, R-C101D, R-C101G), with some models having subsets of the modes. For example, R-C101E only has IF and RUSS modes for the specified indications.Same. The document states, "The proposed device has the same intended use... as the predicate device." While some models have fewer modes, the indications for the available modes are identical.
    Power Source3.7V Li-ion Battery Charger output: 5.0V DC, 300mA3.7 V Li-ion battery Charger Output: 5V DC, 300mASame.
    Patient Leakage CurrentNormal condition: 5 uA; Single fault condition: 5 uANormal condition: 5 uA; Single fault condition: 5 uASame.
    Number of Output Channels22Same.
    Channel IsolationBy enclosureBy enclosureSame.
    Current/Voltage ControlConstant Current: Yes; Constant Voltage: NoConstant Current: Yes; Constant Voltage: NoSame.
    Software/Firmware ControlYesYesSame.
    Safety FeaturesAutomatic Overload Trip: Yes; Automatic Over Current Trip: Yes; Automatic No-Load Trip: Yes; Automatic Shut-off: Yes; Patient Override Control: NoAll "Yes" for trip/shut-off features, "No" for patient override control.Same.
    Indicator DisplayOn/Off Status: Yes; Voltage/Current Level: Yes; Low Battery: YesAll "Yes".Same.
    Waveform TypeBiphasic for TENS, EMS, Interferential, Russian; Monophasic for Microcurrent. Shapes are all Square.Bi-phase for all except MIC (Mono-phase). All shapes are Square.Same.
    Max Output Voltage (V) ±20% (Various Loads)Ranges provided for Predicate (e.g., TENS 500Ω: 50V, 2kΩ: 102V)Ranges provided for New Device (e.g., TENS 500Ω: 45V, 2kΩ: 96V).Different, but the discussion notes these parameters passed IEC 60601-2-10 tests and do not exceed safety limits (calculated max current density and average power density). No new safety/effectiveness issues.
    Max Output Current (mA) ±20% (Various Loads)Ranges provided for Predicate (e.g., TENS 500Ω: 100mA, 2kΩ: 51mA)Ranges provided for New Device (e.g., TENS 500Ω: 90mA, 2kΩ: 48mA).Different, but the discussion notes these parameters passed IEC 60601-2-10 tests and do not exceed safety limits (calculated max current density and average power density). No new safety/effectiveness issues.
    Pulse Width RangeRanges provided for Predicate (e.g., TENS: 50-400uS; EMS: 200~400uS)Ranges provided for New Device (e.g., TENS/EMS: 50 to 450 μs; IF: 50µs/100µs; MIC: 2ms - 500ms; RUSS: 200μs).Different, but noted as minor and compliant with 60601-2-10, thus not raising safety/effectiveness issues.
    Frequency RangeRanges provided for Predicate (e.g., TENS: 1150Hz; EMS: 1100Hz)Ranges provided for New Device (e.g., TENS/EMS: 2 to 150 Hz; IF Carrier F 5KHz/10KHz Beat F1Hz -200Hz; MIC: 0.1Hz - 150Hz; RUSS Carrier F 2.5KHz Burst F10Hz -70Hz).Different, but noted as minor and compliant with 60601-2-10, thus not raising safety/effectiveness issues.
    Beat Frequency (IF)1-200Hz1-200HzSame.
    Maximum Phase Charge (uC, 500Ω)TENS: 2.40; EMS: 2.40; IF: 0.79; MIC: 0.48; RUSS: 3.5TENS: 2.73; EMS: 2.73; IF: 0.75; MIC: 0.42; RUSS: 9Different, but stated to have passed IEC 60601-2-10 tests and safety limits (current density < 2 mA/cm², power density < 0.25 W/cm²). No new safety/effectiveness issues.
    Maximum Current Density (mA/cm², 500Ω, r.m.s)TENS: 0.24; EMS: 0.24; IF: 0.63; MIC: 0.01; RUSS: 0.7TENS: 0.24; EMS: 0.24; IF: 0.6; MIC: 0.01; RUSS: 1.8Mostly similar or within acceptable limits. The RUSS mode is higher but within the stated IEC limit of <2 mA/cm².
    Maximum Average Current (mA)TENS: 6; EMS: 6; IF: 15.75; MIC: 0.24; RUSS: 17.5TENS: 6.075; EMS: 6.075; IF: 15; MIC: 0.21; RUSS: 45Different, explained by calculations showing compliance with safety limits. RUSS is significantly higher but justified by remaining within safety limits (Note 3).
    Maximum Power Density (mW/cm², 500Ω, r.m.s)TENS: 0.72; EMS: 0.72; IF: 4.96; MIC: 0.01; RUSS: 6.13TENS: 0.74; EMS: 0.74; IF: 4.5; MIC: 0.01; RUSS: 40.5Different, explained by calculations showing compliance with safety limits. RUSS is significantly higher but justified by remaining within safety limits (<0.25 W/cm² Guidance Document).
    ON/OFF TimeNot publicly available for predicate.TENS: N/A; EMS: 1-90 S; IF: N/A; MIC: N/A; RUSS: 1-90 S.Different from predicate (likely), but compliant with FDA Guidance Document and not impacting safety/effectiveness.
    Electrode Area (cm²)2525Same.
    Timer Range (minutes)5-90 minutes5-90 minutesSame.
    Compliance with Voluntary StandardsIEC60601-1, IEC60601-1-2, IEC60601-2-10IEC60601-1, IEC60601-1-2, IEC60601-2-10Same.
    Compliance with 21 CFR 898YesYesSame.
    Weight (lbs.)0.28About 140 grams (0.31lbs)Different, but noted as not raising different questions of safety & effectiveness.
    Dimensions H x W x L4.6x2.36x0.9 inch120.5 mm (L) x 69.5 mm (W) x 27mm (H)Different, but noted as not raising different questions of safety & effectiveness.
    Housing Materials & ConstructionEnclosure: ABSEnclosure: ABSSame.
    Burst Mode CharacteristicsNot publicly available for predicate.TENS: Pulses per burst: 7; Bursts per second: 0.5, 1, 2, 3, 4, 5; Burst duration: 70mS; Duty Cycle: 3.5% - 35%. Other modes N/A for these parameters.Different from predicate (likely), but noted as not adversely impacting safety and effectiveness.
    AccessoriesAll listed accessories (electrode, conductive medium, lead wires, batteries) are the same as predicate. Battery charger not included.All listed accessories (self-adhesive electrode (50mm x 50mm), conductive media (gel), electrode lead wires, 3.7V D.C., Li-ion batteries) are the same as predicate. Battery charger not provided.Same. The electrodes are explicitly stated to have been previously cleared (K22252, same manufacturer).
    BiocompatibilityAcceptable for skin contact.The same Self-Adhesive Electrode (K22252) used for the device was evaluated based on ISO10993 for intact skin contact (max 10-15 uses) and submitted to FDA.Met. Reference to existing cleared accessories and ISO10993 compliance.
    Electrical Safety and EMCCompliance with IEC 60601-1:2012 and IEC 60601-1-2:2014.The system complies with IEC 60601-1: 2012 and IEC 60601-1-2: 2014 standards.Met. Testing conducted and compliance confirmed.
    Bench TestingCompliance with IEC 60601-1-11:2015 and IEC 60601-2-10:2016.The system complies with IEC 60601-1-11: 2015 and IEC 60601-2-10: 2016 standards.Met. Testing conducted and compliance confirmed.
    Software Verification and ValidationCompliance with FDA "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices" for "Moderate" level of concern.Software verification and validation testing conducted, documentation provided as recommended by FDA guidance. Software considered "Moderate" level of concern.Met. V&V conducted and documented per FDA guidance.

    Study Proving Acceptance Criteria:

    The studies proving the device meets the acceptance criteria are non-clinical tests, as indicated in Section 7 of the 510(k) summary: "No clinical testing was performed."

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

    • Test Set Sample Size: The document does not specify a quantitative sample size for the "test set" in terms of number of devices or data points beyond stating that "Non-clinical tests were conducted to verify that the proposed device met all design specifications." The testing appears to be primarily laboratory-based bench testing on the device itself.
    • Data Provenance: The data provenance is from bench testing and laboratory evaluations conducted by the manufacturer, Shenzhen Roundwhale Technology Co., Ltd. (China), or their contracted testing facilities. It is not retrospective or prospective clinical data in the traditional sense, as no clinical studies were performed.

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

    This information is not applicable in the context of this 510(k) submission. The ground truth for electrical muscle stimulators in a 510(k) premarket notification is established through:
    * Comparison to a legally marketed predicate device.
    * Adherence to recognized safety and performance standards (e.g., IEC 60601 series).
    * Bench testing to demonstrate the device performs according to its specifications and within acceptable safety limits.

    There are no "experts" establishing a "ground truth" on patient data for this type of submission because no clinical data was submitted.

    4. Adjudication Method for the Test Set

    Not applicable. Since no clinical data or expert evaluations of patient outcomes were performed, there is no need for an adjudication method. The compliance is demonstrated via engineering and safety tests.

    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/TENS unit, not an AI-powered diagnostic or assistive tool for human readers. Therefore, an MRMC comparative effectiveness study involving human readers or AI assistance is irrelevant to this submission.

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

    Not applicable in the context of AI/algorithms affecting diagnostic performance. While the device does contain software/firmware (item 9 in the comparison table indicates "Software/Firmware/Microprocessor Control? Yes"), the performance testing detailed (Section 7) is related to the device's electrical safety, EMC, and bench performance according to standards, not the diagnostic accuracy of an algorithm. The software verification and validation are for the operational integrity and safety of the device's control system, not for an independent diagnostic capability.

    7. The Type of Ground Truth Used

    The ground truth for this submission is established by:
    * Predicate Device Equivalence: The primary ground truth is the performance and safety profile of the legally marketed predicate device (K171978). The new device aims to be substantially equivalent in design and performance.
    * Consensus Standards: Adherence to recognized national and international consensus standards (e.g., IEC 60601-1, IEC 60601-1-2, IEC 60601-1-11, IEC 60601-2-10). These standards define acceptable performance and safety limits for such devices.
    * Bench Test Results: Direct measurements and calculations from bench testing that demonstrate the device's electrical characteristics (output voltage, current, pulse width, frequency, current density, power density, etc.) remain within acceptable limits defined by the standards and are comparable to the predicate.

    8. The Sample Size for the Training Set

    Not applicable. This device is not an AI/machine learning model that requires a training set of data. The "training" of this device refers to its engineering design and manufacturing to meet specified parameters.

    9. How the Ground Truth for the Training Set Was Established

    Not applicable. As stated above, there is no "training set" for this type of medical device submission.

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    K Number
    K222252
    Date Cleared
    2023-01-19

    (176 days)

    Product Code
    Regulation Number
    882.1320
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Self-Adhesive Electrode is intended for use as a reusable, conductive adhesive interface between the patient's skin and the marketed electrical stimulators (i.e.TENS (Transcutaneous Electrical Nerve Stimulation), EMS (Electrical Muscular Stimulation), IF or IFC(Interferential current) or PGF (Pulsed Galvanic Stimulation) for transmitting electrical current, for OTC (Over-The-Counter) or Prescription use.

    Device Description

    Self-Adhesive Electrode are composed of conductive carbon film and adhesive Electrodes composed of Aluminum foil film,Adhesive Electrodes manufactured by Roundwhale are multi-layer reusable, flexible structures composed of laminated materials commonly used in this application:

    1. Top layer: Fabric/Foam/ Tan fabric
    2. Middle layer: Conductive film (Silver coated Carbon Film/Carbon film/Aluminum foil film)
    3. Bottom layer: Biocompatible self-adhesive conductive hydrogel
    4. Connection: Leadwire/snap button/magnetic button
    5. double sides adhesive tape: Which is used for attaching the non-woven fabrics and conducting film
    6. Release film: Release film is a protective layer for the hydrogel.
      The electrodes are designed for single-patient/multiple application use. Because of the adhesive nature of the biocompatible conductive hydrogel, no securing materials are required to secure the device to the patient's skin.
      For the electrical connection, Roundwhale provides lead wire type and snap button/Magnetic button type:
    • Leadwire assembly: The electrode is connected to the electrical stimulator by lead wire, at least 40 mm long wire with a standard connector: 0.08"/0.1"(2mm/2.5mm) diameter female socket connector with insulating outer.
    • Snap button/Magnetic button assembly: With 2.5~5mm diameter male socket.
    AI/ML Overview

    This document is an FDA 510(k) summary for the Shenzhen Roundwhale Technology Co., Ltd. "Self-adhesive Electrode" device. It outlines the device's indications for use, its comparison to predicate devices, and the performance testing conducted to demonstrate substantial equivalence.

    Here's the breakdown of the acceptance criteria and the study that proves the device meets them, based on the provided text:

    Important Note: This document pertains to a cutaneous electrode, which is a relatively simple medical device. Therefore, the "acceptance criteria" and "study" described are focused on physical and electrical performance and biocompatibility, not on complex diagnostic accuracy metrics like those for AI-powered imaging devices (e.g., sensitivity, specificity, AUC). The request's points regarding MRMC studies, expert concensus for ground truth, and training data are typically applicable to AI/ML device submissions, which are not relevant to this electrode device.


    Acceptance Criteria and Reported Device Performance

    The acceptance criteria for this device are primarily based on established industry standards and comparisons to legally marketed predicate devices. The "reported device performance" demonstrates that the proposed device meets or is comparable to these criteria.

    Table of Acceptance Criteria and Reported Device Performance:

    Acceptance Criteria (from Predicate/Standard)Reported Device Performance (Subject Device)Study/Section Proving Compliance
    Material/Composition:
    Biocompatibility (ISO 10993)Complies with ISO109937.2 Biocompatibility testing
    Physical Characteristics:
    Adhesion Testing (Peel Strength) ≥ 7N≥ 7N6. Technical and Performance (Comparison Table), 10. NE adhesion
    Force to remove wire from electrode > 6 poundsMore than 6 pounds of force6. Technical and Performance (Comparison Table)
    Electrical Characteristics:
    A.C. Impedance < 300 ohms< 300 ohms6. Technical and Performance (Comparison Table), 9. Electrical & Impedance Tests
    Safety and EMC:
    ANSI AAMI ES60601-1 (General req. for basic safety and essential performance)Complied with requirements of ANSI AAMI ES60601-17.3 Safety and EMC
    IEC 60601-2-2:2017 (Specific req. for NE contact impedance)Complied with requirements of IEC 60601-2-2:2017 section 201.15.101.69. Electrical & Impedance Tests
    IEC 60601-2-2:2017 (Specific req. for NE adhesion)Complied with requirements of IEC 60601-2-2:2017 section 201.15.101.710. NE adhesion
    Product Lifecycle:
    Shelf Life (Storage conditions: 41°F to 80.6°F)Tested for storage conditions12. Packaging tests
    Accelerated Aging (Expiration date)Tested for accelerated aging13. Accelerated Aging

    Study Details:

    1. Sample Size used for the test set and data provenance:

      • The document does not specify exact sample sizes (e.g., number of electrodes tested) for each non-clinical test. It generally states that "The submitted sample(s) complied..." However, based on the nature of bench testing for these types of devices, standard engineering practices would involve testing multiple units to demonstrate conformity.
      • Data Provenance: The tests are "Non-Clinical Data" and "Bench Testing," implying in-house lab testing or third-party lab testing. The document does not specify country of origin for the testing itself, but the company is based in Shenzhen, China. The data is retrospective in the sense that it was generated prior to submission.
    2. Number of experts used to establish the ground truth for the test set and qualifications of those experts:

      • This question is not applicable to this type of device submission. For a cutaneous electrode, "ground truth" is established by direct physical, electrical, and chemical measurements against industry standards (e.g., resistance, adhesion force, material composition, cytotoxicity tests). There are no "experts" in the radiological interpretation sense involved in establishing this type of ground truth.
    3. Adjudication method (e.g., 2+1, 3+1, none) for the test set:

      • This question is not applicable. Adjudication methods are relevant for subjective interpretations, particularly in medical imaging or clinical trials where expert consensus resolves disagreements. For bench testing of an electrode, results are objective measurements derived from direct testing.
    4. 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:

      • This question is not applicable to this device. MRMC studies are used for AI/ML-enabled diagnostic devices where human readers (e.g., radiologists) interact with an AI system. This submission is for a physical electrode, not a diagnostic AI tool.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • This question is not applicable to this device. "Standalone performance" refers to the performance of an algorithm without human intervention, typically in AI/ML diagnostic tools. This device is not an algorithm.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

      • The "ground truth" for this device is based on industry standards and objective physical, electrical, and chemical measurements.
        • Physical/Mechanical: E.g., measured peel strength (adhesion) against a specified Newton (N) threshold, measured force to remove wires against a specified pound-force threshold.
        • Electrical: E.g., measured AC impedance against a specified ohm threshold.
        • Biocompatibility: Results of specific ISO 10993 tests (Cytotoxicity, Skin Sensitization, Skin Irritation) which have defined pass/fail criteria based on biological reactions.
        • Safety/EMC: Compliance with well-defined performance requirements in standards like ES60601-1 and IEC 60601-2-2.
    7. The sample size for the training set:

      • This question is not applicable. This device does not involve machine learning or AI, and therefore, there is no "training set."
    8. How the ground truth for the training set was established:

      • This question is not applicable for the same reason as above; there is no training set.
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    K Number
    K192087
    Date Cleared
    2019-11-01

    (88 days)

    Product Code
    Regulation Number
    882.5890
    Reference & Predicate Devices
    N/A
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Over-The-Counter Use:

    TENS mode::

    It is used for temporary relief of pain associated with sore and aching muscles in the neck, shoulder, back, upper extremities (arm) and lower extremities (leg) due to strain from exercise or normal household work activities.

    EMS mode:

    This mode is designed to be used for stimulate healthy muscles in order to improve and facilitate muscle performance.

    Prescription Use:

    For TENS mode:

      1. Symptomatic relief of chronic intractable pain:
      1. Post traumatic pain: 3) Post surgical pain;

    For EMS mode:

      1. Relaxation of muscle spasm;
      1. Increase of local blood flow circulation;
      1. Prevention or retardation of disuse atrophy;
      1. Muscle re-education;
      1. Maintaining or increasing range of motion;
      1. Immediate post-surgical stimulation of calf muscles to prevent venous thrombosis.
    Device Description

    Not Found

    AI/ML Overview

    This document is a 510(k) clearance letter from the FDA for a Combo Electrotherapy Device. It does not contain information about acceptance criteria or a study proving the device meets those criteria in the way a clinical study report for an AI/ML device would. The letter primarily confirms the device's substantial equivalence to predicate devices and lists the indications for use.

    Therefore, I cannot extract the requested information regarding acceptance criteria, device performance, sample sizes, ground truth establishment, or multi-reader multi-case studies from the provided text. This document is a regulatory clearance, not a performance study report.

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    K Number
    K181688
    Date Cleared
    2018-09-07

    (73 days)

    Product Code
    Regulation Number
    890.5850
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    R-C1 TENS and EMS Stimulator

    For TENS mode:

      1. Symptomatic relief of chronic intractable pain;
      1. Post traumatic pain;
      1. Post surgical pain;

    For EMS mode:

      1. Relaxation of muscle spasm;
      1. Increase of local blood flow circulation;
      1. Prevention or retardation of disuse atrophy;
      1. Muscle re-education;
      1. Maintaining or increasing range of motion;
      1. Immediate post-surgical stimulation of calf muscles to prevent venous thrombosis.
    • R-E1 EMS Stimulator
      1. Relaxation of muscle spasm;
      1. Increase of local blood flow circulation;
      1. Prevention or retardation of disuse atrophy;
      1. Muscle re-education;
      1. Maintaining or increasing range of motion;
      1. Immediate post-surgical stimulation of calf muscles to prevent venous thrombosis.
    • R-T1 TENS Stimulator
      1. Symptomatic relief of chronic intractable pain;
      1. Post traumatic pain;
      1. Post surgical pain.
    Device Description

    The RW Series A Electrical Stimulator, which includes models R-C1, R-E1 and R-T1, are Transcutaneous Electrical Nerve Stimulator and muscle stimulator for pain relief and/or Electrical Muscle Stimulator sends gentle electrical current to underlying nerves and muscle group via electrodes applied on the skin. The parameters of units are controlled by the press buttons. Its intensity level is adjustable according to the needs of patients.

    The device unit of R-C1 was portable device, battery powered (6.0V DC) multi-function device offering both Transcutaneous Electrical Nerve Stimulator(TENS) and Powered Muscle Stimulator (EMS) qualities in one device.

    The stimulator is used with electrodes. For the electrodes are provided by the manufacturer Top-Rank Health Care Equipment Co. Ltd, cleared under K070612.

    The three models of R-C1, R-E1 and R-T1 have the same appearance, structure, display, electrical principle and critical components, the main differences are software and color. The R-C1 have TENS mode (12 programs), EMS mode (9 programs). The R-E1 only have EMS mode (9 programs) and R-T1 only have TENS mode (12 programs). The R-C1 was combination the function of R-E1 and R-T1.

    AI/ML Overview

    The provided document is a 510(k) summary for the Shenzhen Roundwhale Technology Co., Ltd. R-C1 TENS and EMS Stimulator, R-E1 EMS Stimulator, and R-T1 TENS Stimulator. This document focuses on demonstrating substantial equivalence to a predicate device rather than presenting a study to prove acceptance criteria for a novel device or algorithm.

    Therefore, much of the requested information regarding acceptance criteria and studies (especially for AI/ML performance) is not applicable or cannot be directly extracted from this type of regulatory submission. The document explicitly states: "No clinical test data was used to support the decision of substantial equivalence."

    However, I can extract information related to non-clinical testing and performance standards used to demonstrate safety and performance.

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria for this type of device are primarily compliance with recognized consensus standards for safety and performance. The performance reported is that the device "meets the requirements of its pre-defined acceptance criteria and intended uses."

    ItemAcceptance Criteria (Applicable Standard)Reported Device Performance
    SafetyIEC 60601-1:2005+A1:2012 (Medical electrical equipment – General requirements for basic safety and essential performance)Conform
    Electromagnetic Compatibility (EMC)IEC 60601-1-2:2014 (Medical electrical equipment – Electromagnetic disturbances – Requirements and tests)Conform
    Home Healthcare EnvironmentIEC 60601-1-11:2015 (Medical electrical equipment – Requirements for medical electrical equipment and medical electrical systems used in the home healthcare environment)Conform
    PerformanceIEC 60601-2-10:2012+A1:2016 (Medical electrical equipment – Particular requirements for the basic safety and essential performance of nerve and muscle stimulators)Conform
    SoftwareIEC 62304:2006 (Medical device software – Software life cycle processes)Conform
    UsabilityIEC 62366-1:2015 (Medical devices – Application of usability engineering to medical devices)Conform
    Risk ManagementISO 14971:2007 (Medical devices – Application of risk management to medical devices)Conform
    Shelf lifeN/A (Internal company specification)Meets requirements
    Software ValidationN/A (Internal company specification)Meets requirements
    Electrical Safety (Patient Leakage Current)IEC 60601-1 requirements (e.g., limits for normal and single fault conditions)Normal condition: 11.4 uA; Single fault condition: 9.6 uA (Meets requirements)
    Average DC current through electrodesIEC 60601-2-10 requirements (0 when no pulses applied)0 (for TENS and EMS modes, when no pulses applied)
    Electrode Pads BiocompatibilityISO 10993-1 (Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process)Compliance claimed

    Study Proving Acceptance Criteria

    The study performed was a series of non-clinical safety and performance tests conducted on the subject device (RW series A Electrical stimulator: R-C1, R-E1 and R-T1). The document states: "All the test results demonstrate RW series A Electrical stimulator (R-C1, R-E1 and R-T1) meets the requirements of its pre-defined acceptance criteria and intended uses, and is substantially equivalent to the predicate devices."

    The specific types of non-clinical tests mentioned are:

    • Shelf life
    • Software validation
    • Electromagnetic compatibility and electrical safety (verified against IEC 60601-1, IEC 60601-1-2, IEC 60601-1-11, IEC 60601-2-10)
    • Function test
    • Usability (verified against IEC 62366-1)
    • Risk management (verified against ISO 14971)

    2. Sample Size for Test Set and Data Provenance

    • Sample Size for Test Set: Not explicitly stated, however, for non-clinical engineering and performance testing as described, it typically involves a small number of devices (e.g., 3-5 units) undergoing specific tests to demonstrate compliance with standards. It does not refer to a "test set" in the context of clinical trials or AI/ML validation data.
    • Data Provenance: The tests were performed on the devices manufactured by Shenzhen Roundwhale Technology Co., Ltd. The document refers to "non-clinical laboratory studies and safety testing data." This implies the data was generated internally as part of the device development and validation process, likely in China where the manufacturer is based. It is retrospective in the sense that these tests were performed on the final device design to support regulatory submission.

    3. Number of Experts and Qualifications for Ground Truth

    • Number of Experts: Not applicable. This submission relates to a physical medical device (electrical stimulator) which demonstrates safety and performance through engineering tests against recognized standards, not through clinical data where expert-established ground truth would be required.
    • Qualifications of Experts: Not applicable.

    4. Adjudication Method for Test Set

    • Adjudication Method: Not applicable. This is not a clinical study involving ambiguity or subjective assessments. Compliance with engineering standards is typically determined by objective measurements and pass/fail criteria.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    • MRMC Study: No. This is not an AI/ML device or an imaging device for which an MRMC study would be relevant. The document explicitly states: "No clinical test data was used to support the decision of substantial equivalence."
    • Effect Size of Human Readers with/without AI: Not applicable.

    6. Standalone (Algorithm Only) Performance Study

    • Standalone Study: No. This is a hardware medical device; it does not involve a standalone algorithm for diagnostic or prognostic purposes.

    7. Type of Ground Truth Used

    • Type of Ground Truth: The "ground truth" here is compliance with established international and FDA-recognized consensus standards (e.g., IEC 60601 series, ISO 14971, IEC 62304, IEC 62366-1) and internal design specifications for the device's electrical characteristics and functionality. These standards define the acceptable range of performance and safety parameters.

    8. Sample Size for the Training Set

    • Sample Size for Training Set: Not applicable. This device does not use an AI/ML model that requires a training set.

    9. How Ground Truth for Training Set Was Established

    • How Ground Truth for Training Set Was Established: Not applicable.
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    K Number
    K180956
    Date Cleared
    2018-06-07

    (56 days)

    Product Code
    Regulation Number
    882.5890
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    R-C1 TENS and EMS Stimulator

    TENS: This mode is designed 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.

    EMS: This mode is designed to be used for stimulate healthy muscles in order to improve and facilitate muscle performance.

    R-E1 EMS Stimulator

    This device is designed to be used for stimulate healthy muscles in order to improve and facilitate muscle performance.

    R-T1 TENS Stimulator

    This device is designed 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.

    Device Description

    The RW Series A Electrical Stimulators, which includes models R-C1 TENS and EMS stimulator, R-E1 EMS stimulator and R-T1 TENS stimulator, are Transcutaneous Electrical Nerve Stimulator and muscle stimulator for pain relief and/or Electrical Muscle Stimulator. The stimulator sends gentle electrical current to underlying nerves and muscle group via electrodes applied on the skin. The parameters of units are controlled by the press buttons. Its intensity level is adjustable according to the needs of patients.

    The device unit of R-C1 was portable device, battery powered (6.0V DC) multi-function device offering both Transcutaneous Electrical Nerve Stimulator(TENS) and Powered Muscle Stimulator (EMS) qualities in one device.

    The electrode size is 50*50mm, the manufacturer is Top-Rank Health care Equipment Co., Ltd. The electrode is OTC use and cleared with 510(K), the cleared number is K132588. It has been evaluated and tested according to ISO 10993-1/-5 and -10 standards.

    The three models of R-C1, R-E1 and R-T1 have the same appearance, structure, display, electrical principle and CDF, the main differences are software and color. The R-C1 have TENS mode (18 programs), EMS mode (15 programs). The R-E1 only have EMS mode (15 programs) and R-T1 only have TENS mode (18 programs). The R-C1 was combination the function of R-E1 and R-T1.

    AI/ML Overview

    The provided document is a 510(k) Summary for a medical device (Electrical Stimulator - Model R-C1 TENS and EMS stimulator, Model R-E1 EMS stimulator, Model R-T1 TENS Stimulator). It describes the device, its intended use, comparison to predicate devices, and non-clinical testing performed to demonstrate substantial equivalence.

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

    1. A table of acceptance criteria and the reported device performance

    The document provides a table outlining compliance with recognized consensus standards for safety and performance (page 6). This effectively acts as the acceptance criteria for the non-clinical tests.

    ItemDescriptionFDA recognized consensus standardsReported Device Performance
    SafetyIEC 60601-1:2005+A1:2012YesConform
    EMCIEC 60601-1-2:2014YesConform
    Home healthcare environmentIEC 60601-1-11:2015YesConform
    PerformanceIEC 60601-2-10:2012+A1:2016YesConform
    SoftwareIEC 62304:2006YesConform
    UsabilityIEC 62366-1:2015(Blank)(Blank)
    Risk managementISO 14971:2007YesConform

    The document also provides a detailed comparison table (pages 8-9) with the predicate devices for various technical characteristics. For each characteristic, the comparison indicates "Same," "Different but does not adversely impact safety and effectiveness," or similar justifications, implying that these characteristics meet the acceptance criteria established by the predicate devices or are otherwise deemed safe and effective. Specific numerical values are provided for many parameters, such as maximum output voltage, maximum output current, pulse width range, and frequency.

    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: "No clinical test data was used to support the decision of substantial equivalence." (page 6). The evaluation was based solely on non-clinical (laboratory) testing. Therefore, there is no sample size for an effectiveness test set, nor is there data provenance in the context of clinical studies.

    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 no clinical studies were performed and the substantial equivalence determination was based on non-clinical, laboratory testing and comparison to predicate devices, this information is not applicable. The "ground truth" for the device's acceptable performance was established by demonstrating compliance with recognized safety and performance standards (e.g., IEC standards) and showing equivalence to legally marketed predicate devices through technical specifications and testing.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Not applicable, as no clinical test set requiring expert adjudication was used.

    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. The device is an electrical stimulator, not an AI-powered diagnostic or assistive tool for human readers. No MRMC study was performed.

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

    Not applicable. The device is an electrical stimulator, not an algorithm. However, the non-clinical tests (e.g., electrical safety, performance, software validation) represent an evaluation of the device's standalone performance against established engineering and safety standards.

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

    For this device, the "ground truth" for demonstrating safety and effectiveness was based on:

    • Compliance with recognized international consensus standards: Such as IEC 60601 series, ISO 14971, and IEC 62304. These standards define the acceptable performance and safety characteristics for medical electrical equipment.
    • Comparison to legally marketed predicate devices: The predicate devices (MT9001, LT3060; K130802) serve as the established "ground truth" for a device of this type being safe and effective for its indicated use. The extensive comparison table (pages 8-9) outlines how the new device's technical specifications either match or differ in ways that do not adversely impact safety and effectiveness compared to these predicates.

    8. The sample size for the training set

    Not applicable. The device is an electrical stimulator that performs physical functions, not a machine learning model that requires a training set.

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

    Not applicable, as there is no training set for this type of device.

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