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510(k) Data Aggregation
(382 days)
TensCare Ltd
TENS stands for Transcutaneous Electrical Nerve Stimulation. Unipro TENS is used to provide symptomatic pain relief for chronic, acute or post-operative pain.
EMS stands for Electrical Neuromuscular Stimulation. Unipro EMS is indicated for:
- · Relaxation of muscle spasm
- · Increasing local blood circulation and muscle re-education
- · Prevention or retardation of disuse atrophy
- · Prevention of venous thrombosis of the calf muscles immediately after surgery
- · Maintaining on increasing range of motion
MIC stands for Microcurrent Stimulation. Unipro MIC is used to provide sumptomatic pain relief for chronic intractable pain, post traumatic pain or post surgical pain.
IFT stands for Interferntial Stimulation. Unipro IFT is indicated for symptomatic relief of chronic intractable pain.
Unipro is a non-invasive, non-sterile, reusable medical device which is intended to be used in both the hospital and home healthcare environment. It is a microprocessor controlled, non-implantable, portable neuromuscular electrical stimulator which is powered by a built in Li-ion rechargeable battery.
Unipro is a multitherapy unit that combines the treatment capabilities of TENS (Transcutaneous Electrical Nerve Stimulation), EMS (Electrical Muscle Stimulation), MIC (Microcurrent Stimulation) and IFT (Interferential Therapy). The mode selection button on device will enable the user to switch between different modes (TENS, EMS II, EMS III, or massage). Each time the user changes the mode or program, the intensity level will revert to zero. This is a safety feature to alleviate any sudden feeling of a surge, as each program gives a different sensation.
Unipro Case L (large) features a white ABS case with a white silicone button pad and white power button. Power button is located on the right-hand side of the device. The hardware features a black perimeter border and black LCD display. Charging cable and lead inserts are located on the bottom of the device.
Unipro is supplied with self-adhesive electrodes which attach to the control unit via lead wires. A gentle electrical current is sent to underlying nerves and muscle groups via these electrodes applied on the skin to relieve pain. Placement of the electrode pads of the device depends on the selected device mode (TENS, EMS, IFT2, IFT4, MIC). For TENS, the easiest way is to apply the electrode pads around/near the source of the pain. For EMS, place two electrode pads over the bulk of the muscle, with one electrode over the muscle's motor point. For IFT2, electrodes should be placed either side of the area of pain and for IFT4, the pads need to apply in positions so that the signals from each channel cross over the point to be treated. Finally, for MIC, the electrode pads should be placed in such a way that a straight line between them passes through the problem area.
The TensCare Ltd Unipro (K232441) is a multi-therapy electrical stimulator combining TENS, EMS, MIC, and IFT functionalities. The submission claims substantial equivalence to the predicate device, Ultima NEO (K120054).
Here's a breakdown of the requested information based on the provided text:
1. A table of acceptance criteria and the reported device performance
The provided documentation does not explicitly list "acceptance criteria" for performance metrics in a pass/fail format. Instead, it compares the technical characteristics and indications for use of the Unipro to its predicate device, Ultima NEO, to demonstrate substantial equivalence. The "Comparison" column in the tables serves as a qualitative assessment of whether the Unipro's performance characteristics are similar enough to the predicate.
Characteristic | Acceptance Criteria (Implied: Similar to Predicate) | Reported Device Performance (Unipro) | Comparison |
---|---|---|---|
Indications for Use | Identical to Ultima NEO | TENS, EMS, MIC, IFT for pain relief and muscle stimulation (detailed in text) | Identical |
Intended Population | Similar to Ultima NEO (Male and female patients over 18) | Male and female patients over 21 | Substantially Equivalent (difference in age: 21 vs 18) |
Power Source | Similar to Ultima NEO (Li-ion rechargeable battery) | 3.7V 1500mAh Lithium-ion battery (rechargeable) | No substantial difference |
Average DC current through Electrodes (no pulses) | 0 µA | 0 µA | Identical |
Number of Output Modes | 4 (TENS, EMS, MIC, IFT) | 4 | Identical |
Number of programs/modes | Similar to Ultima NEO (41 programs) | 76 | No substantial difference (Both comply with IEC 60601-1) |
Number of Output Channels | 2 | 2 | Identical |
Timer Range | Similar to Ultima NEO (10-90 minutes, constant) | 5-90 minutes, constant | No substantial difference (Unipro can be set lower) |
Regulated Current or Voltage? | Current and Voltage | Current and Voltage | Identical |
Software/Firmware/Microprocessor Control? | Yes | Yes | Identical |
Automatic No-Load Trip? | Not publicly available for predicate (implied: similar/present) | Yes (TENS/EMS) | - |
Automatic Overload Trip? | Not publicly available for predicate (implied: similar/present) | No | - |
Automatic Shut Off? | Not publicly available for predicate (implied: similar/present) | Yes | - |
User Override Control? | Not publicly available for predicate (implied: similar/present) | Yes | - |
Indicator Display | On/Off, Low battery, Voltage/Current level, Time to cut-off | Yes for all | Identical |
Compliance Voluntary Standards | IEC 60601-1, IEC 60601-1-2, IEC 60601-2-10, etc. | IEC 60601-1, IEC 60601-1-2, IEC 60601-2-10, etc. | Substantial equivalent |
Compliance with 21 CFR regulations | Yes | Yes | Identical |
Dimensions | Similar to Ultima NEO (123 x 61 x 22mm) | 125mm x 62mm x 29.6mm | Different, but does not affect safety/effectiveness |
Weight | Similar to Ultima NEO (160g) | 128.5g | Different, but does not affect safety/effectiveness |
Housing Materials | ABS 757 material | ABS 757 material | Identical |
Sterilization | N/A | N/A | Identical |
Waveform (TENS/EMS) | Bi-phase Symmetrical Rectangular, Asymmetrical Rectangular, Mono-Phase Symmetrical Rectangular (predicate) | TENS/EMS: Symmetrical Rectangular | No substantial difference |
Waveform (Microcurrent) | Symmetrical Rectangular (predicate) | Continuous square unipolar, sawtooth unipolar, symmetrical balanced wave | No substantial difference (Both comply with IEC 60601-1) |
Waveform (IFT) | Symmetrical balanced sine wave | Symmetrical balanced wave | Identical |
Maximum Output Voltage (TENS/EMS) | 73.6V@500Ω, 120V@2 kΩ, 124V@10 kΩ (predicate) | 54V@500Ω, 114 V@2 kΩ, 116 V@10 kΩ | No substantial difference (lower, but proportional to current, complies with IEC 60601-1) |
Maximum Output Voltage (Microcurrent) | 0.54V@500Ω, 2.12V@2 kΩ, 10.2V@10 kΩ (predicate) | 0.4V@500Ω, 1.56 V@2 kΩ, 7.8 V@10 kΩ | No substantial difference (lower, but proportional to current, complies with IEC 60601-1) |
Maximum Output Voltage (IFT) | 17V@500Ω, 30V@2 kΩ, 32 V@10 kΩ (predicate) | 24V@500Ω, 34.4 V@2 kΩ, 40 V@10 kΩ | No substantial difference (complies with IEC 60601-1) |
Maximum Output Current (TENS/EMS) | 147mA@500Ω, 60mA@2 kΩ, 12.4mA@10kΩ (predicate) | 108mA@500Ω (200μs), 80mA @500Ω (400μs), 57mA@2 kΩ, 11.6 mA@10 kΩ | No substantial difference (Unipro features amplitude modulation mode) |
Maximum Output Current (Microcurrent) | 1.08mA, 1.06mA, 1.02mA (predicate) | 0.8mA, 0.78 mA @2 kΩ, 0.78 mA @10 kΩ | No substantial difference (Unipro MIC amplitude smaller, complies with IEC 60601-1) |
Maximum Output Current (IFT) | 34mA@500Ω, 15mA@2 kΩ, 3.2mA@10kΩ (predicate) | 48mA@500Ω, 17.2mA@2 kΩ, 4mA@10 kΩ | No substantial difference (complies with IEC 60601-1) |
Pulse Width (TENS/EMS) | 50-400µs (predicate) | TENS: 50-300 µs, EMS: 100-400 µs | No substantial difference (within recommended output, complies with IEC 60601-2-10) |
Pulse Width (Microcurrent) | 2-200ms (predicate) | 10-200ms | No substantial difference (within recommended output, complies with IEC 60601-2-10) |
Pulse Width (IFT) | 120-125µs (predicate) | 125 µs | No substantial difference (within recommended output, complies with IEC 60601-2-10) |
Frequency (TENS/EMS) | 1-150Hz (predicate) | TENS: 2-150Hz, EMS: 10-120Hz | No substantial difference (Unipro's range is within recommended range, complies with IEC 60601-2-10) |
Frequency (Microcurrent) | 1-150Hz (predicate) | 0.5Hz, 1Hz, 1.5Hz, 2Hz, 3Hz, 4Hz, 5Hz to 50Hz | No substantial difference (within recommended range, complies with IEC 60601-2-10) |
Frequency (IFT) | 4000-4160Hz (predicate) | 2-160Hz (Carrier Frequency: 4000Hz fixed (CH1)) | No substantial difference (Predicate's higher frequency may not offer additional benefit, complies with IEC 60601-2-10) |
Net Charge (µC per pulse) | 0.4µC@ 500 Ω (predicate) | 0.3µC@ 500 Ω | No substantial difference (Charge output dependent on current, complies with IEC 60601-1) |
Maximum Phase Charge (µC) | TENS/EMS: 21.62μC@500Ω, Microcurrent: 220.8μC@500Ω, IFT: 5.16μC@500Ω (predicate) | TENS/ EMS: 22.76μC@500Ω, Microcurrent: 160μC@500Ω, IFT: 2.8μC@500Ω | No substantial difference (Charge used to set pulse width, complies with IEC 60601-1) |
Maximum Current Density (mA/cm²) | TENS/EMS: 5.88mA/cm²@500Ω, Microcurrent: 0.022mA/cm²@500Ω, IFT: 1.65mA/cm²@500Ω (predicate) | TENS/EMS: 0.8mA/cm²@500Ω, Microcurrent: 0.008mA/cm²@500Ω, IFT: 0.82mA/cm²@500Ω | No substantial difference (both comply with IEC 60601-1) |
Maximum Power Density (W/cm²) | TENS/EMS: 0.0086W/cm², Microcurrent: 0.012W/cm², IFT (predicate) | TENS/ EMS: 0.0076 W/cm2, Microcurrent: 0.0001049 W/cm2, IFT | No substantial difference (both comply with IEC 60601-1) |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
The submission indicates that "No clinical testing was considered necessary." Therefore, there is no sample size for a new test set or details on data provenance from a prospective or retrospective study involving the Unipro device. The equivalence claim is based on comparison to the predicate and literature review.
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 on the device to establish a new ground truth. The basis of the submission relies on the established safety and effectiveness of the predicate device and the modes of therapy.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable, as no clinical testing was performed that would require adjudication of a test set.
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 not an AI-assisted diagnostic or interpretative tool, and no MRMC study was conducted.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
Not applicable. This device is a direct-use electrical stimulator, not an algorithm. Its performance is evaluated through bench testing against established standards and comparison to a predicate device.
7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)
The "ground truth" for the Unipro's substantial equivalence claim is based on the established safety and effectiveness of the legally marketed predicate device (Ultima NEO), and recognized international consensus standards (e.g., IEC 60601-1, IEC 60601-2-10). Additionally, it mentions a formal review of published research and clinical evaluation on the use of TENS, EMS, IFT, and MC for pain relief and muscle training, which serves as a form of expert consensus and outcomes data from the broader scientific community.
8. The sample size for the training set
Not applicable, as this is not an AI/machine learning device that requires a training set.
9. How the ground truth for the training set was established
Not applicable, as this is not an AI/machine learning device that requires a training set.
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(256 days)
TensCare Ltd
For Mode 0, Ova+ is indicated for temporary relief of pain associated with dysmenorrhea (menstrual cramps) when used with over-the-counter pain medication.
For Modes 1, 2& 3 Ova+ is indicated 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.
The Ova+ is a non-invasive small and convenient unit that can be worn under clothing to provide safe, continuous, drug-free period pain relief whilst maintaining a normal, active lifestyle.
The device is battery powered, single channel home using Transcutaneous Electrical Nerve Stimulation (TENS).
The device is supplied with self-adhesive electrodes which connect to the control unit by cable and plug and are placed on patients' intact skin by the end user. Electrical stimulation is delivered via these self-adhesive electrodes to superficial nerves.
The unit is intended for home use by the patient and is designed with simplicity and ease of use in mind. It has four preset treatment Modes. The level of electrical stimulation of Ova+ is easily controlled by the end user using manual, push-button controls.
The new device Ova+ uses the same technical principle and substantially equivalent stimulation parameters to the marketed device Livia (K183110) and/or reference predicate device Perfect EMS (K200694)
The Ova+ uses a rechargeable Li-Ion polymer battery and a custom TENS connecting lead with 2mm connecting pins.
The Ova+ is supplied with adhesive electrodes that are similar to those of the predicate devices.
The provided text is a U.S. FDA 510(k) summary for the TensCare Ova+ device, a transcutaneous electrical nerve stimulator (TENS). The document describes the device, its intended use, and a comparison to predicate devices to establish substantial equivalence.
Based on the provided text, the TensCare Ova+ device is not a device that uses AI/ML or requires a complex study for its acceptance criteria. It is a TENS device that relies on established technology and regulatory pathways for electrical medical devices.
Therefore, many of the requested elements (e.g., acceptance criteria for AI performance, sample sizes for AI test/training sets, expert adjudication for ground truth, MRMC studies, standalone AI performance) are not applicable to this specific device submission.
The acceptance criteria for this device are based on its electrical performance, safety, and functional equivalence to legally marketed predicate TENS devices, as demonstrated through non-clinical bench testing and adherence to recognized consensus standards.
Here's an attempt to answer the relevant questions based on the provided document:
1. A table of acceptance criteria and the reported device performance
The document does not present explicit "acceptance criteria" in a table format with pass/fail results for each criterion. Instead, it compares the performance characteristics of the Ova+ device to its predicate devices to demonstrate substantial equivalence. The implication is that if the Ova+ device's performance characteristics are similar enough to the cleared predicate devices and meet relevant safety standards, it is considered acceptable.
Below is a summary of the comparative performance from the document (mostly from "Table 3: Comparison of output specifications" and "Table 2: Basic Unit Characteristics Comparison Table" but also other sections). The "Acceptance Criteria" here are implicitly "Substantially Equivalent to Predicate Device(s)" and "Compliance with relevant standards". The "Reported Device Performance" is the stated characteristic of the Ova+ device.
Characteristic | Acceptance Criteria (Implicit) | Reported Device Performance (Ova+) | Predicate Livia (K183110) Performance | Predicate Perfect EMS (K200694) Performance | Comparison Outcome (Implicit Acceptance) |
---|---|---|---|---|---|
Indications for Use | Substantially equivalent to predicate(s) | Mode 0: Dysmenorrhea (w/ OTC pain med); Modes 1,2,3: Sore/aching muscles (shoulder, waist, back, neck, arm, leg) | Same (including dysmenorrhea and general pain) | TENS for sore/aching muscles | Substantially Equivalent (with Livia) |
Intended Users | Substantially equivalent to predicate(s), home use, 18+ women | Home use, women aged 18 and above | Women aged 18 and above | Keep away from children | Substantially Equivalent (with Livia) |
Power Source | Safe and effective; similar to predicate | 3.7V Lithium ion battery (rechargeable) | 3.7V Lithium ion battery (rechargeable) | 2 x AA alkaline battery | Substantially Equivalent |
Method of Line Current Isolation | Safe and effective; similar to predicate | Not possible to connect patient lead and charger at same time; uses same socket | Electrically disabled output when connected to charger | No connection to Line Current | Substantially Equivalent |
Patient Leakage Current - Normal Condition |
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(197 days)
TensCare Ltd
Unicare is intended to provide electrical stimulation and neuromuscular re-education for the purpose of rehabilitation of weak pelvic floor muscles for the treatment of stress, urge and mixed urinary incontinence in women and to maintain urinary continence in women.
Unicare is battery powered, single-channel, home-use electrical pelvic floor muscle stimulator. The device is supplied with a non-sterile, reusable (single-patient use) vaginal probe and self-adhesive electrodes which connect to the control unit by cable and plugs. The vaginal probe is inserted into the vagina. The optional self-adhesive electrodes is placed on patients' intact skin and is used for the treatment of only urge urinary incontinence in women. Electrical stimulation is delivered via the vaginal probe or the self-adhesive electrodes to the pelvic floor muscles. This electrical muscle stimulation works as a rehabilitation and training for pelvic floor muscles for the treatment of stress, urge and mixed urinary incontinence in women. The level of electrical stimulation of the Unicare can be controlled by the end user using manual push-button controls. This device is intended for over the counter (OTC) use.
The provided document does not contain information related to software-based medical devices that would involve acceptance criteria, study details (sample size, data provenance, expert ground truth, adjudication, MRMC studies, standalone performance), or training set information as typically found for AI/ML-driven diagnostics.
The document is an FDA 510(k) clearance letter for a non-implanted electrical continence device called "Unicare." This device is a hardware product that provides electrical stimulation for pelvic floor muscles. The "Non-Clinical Testing" section lists various engineering and safety tests performed on the device (biocompatibility, electrical safety, electromagnetic compatibility, software verification/validation, battery life), but these are standard engineering tests for hardware and software aspects of a physical device, not performance studies for an AI/ML algorithm or diagnostic tool.
Therefore, I cannot extract the requested information regarding acceptance criteria and studies for device performance in the context of AI/ML or diagnostic accuracy from this document. The information requested (e.g., sample size for test set, data provenance, expert adjudication, MRMC studies, ground truth types) is specific to studies evaluating the performance of diagnostic algorithms, particularly those involving image analysis or similar AI/ML applications, which is not applicable to the "Unicare" device described.
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(127 days)
TensCare Ltd
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(444 days)
TensCare Ltd.
TENS: The 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), lower extremities (leg), abdomen and bottom due to strain from exercise or normal household work activities.
EMS: The device is designed to be used for stimulate healthy muscles in order to improve and facilitate muscle performance.
Perfect EMS is a hand-held, home-use device designed to relief of pain and improve and facilitate muscle performance. Perfect EMS is intended for over-the-counter use.
The device is battery powered, two channels home use neuromuscular stimulation. The device is supplied with self-adhesive electrodes which connect to the control unit by cable and plug and are placed on patients' intact skin by the end user. Electrical stimulation is delivered via self-adhesive electrodes to nerves and muscles.
The level of electrical stimulation is easily controlled by the end user using manual, pushbutton controls.
The unit is intended for home use by the patient, and is designed with simplicity and ease of use in mind. It has six preset treatment programs and four manually adjustable programmes are available.
Accessories: 2 x 1.25m PVC Lead Wires (L-CPT) 50x50mm hydrogel electrode pads (E-CM5050)
Optional accessories: 50x100mm Large hydrogel electrode pads Pack of 4 (E-CM50100)
The provided text describes a 510(k) submission for the Perfect EMS device, asserting its substantial equivalence to a predicate device (HIVOX OTC Electrical Stimulator Model: EM49-2, K190347). The document focuses on demonstrating that the Perfect EMS meets safety and performance criteria by comparing it to the predicate and through compliance with recognized standards.
Here's an analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria for the Perfect EMS device are implicitly defined by its substantial equivalence to the predicate device, EM49-2 (K190347), and adherence to a battery of safety and performance standards. The table above the horizontal line below summarizes the performance attributes of the Perfect EMS (Subject Device) and the predicate device, along with the comparison stating "Substantially equivalent" or "Identical."
Attribute | Acceptance Criteria (Implicitly from Predicate/Standards) | Reported Device Performance (Perfect EMS) | Comparison Conclusion |
---|---|---|---|
Product Code | NUH, NGX | NUH, NGX | Identical; Substantially equivalent |
Regulation No. | 21 CFR 882.5890; 21 CFR 890.5850 | 21 CFR 882.5890; 21 CFR 890.5850 | Identical; Substantially equivalent |
Indications for Use | Same as predicate (TENS: temporary pain relief for sore/aching muscles; EMS: stimulate healthy muscles for improved performance) | Same as predicate | Same indications for use; Substantially equivalent |
Prescriptive or OTC | OTC | OTC | Identical; Substantially equivalent |
Number of output modes | Within acceptable range compared to predicate (predicate had 70 modes) | 10 | Substantially equivalent |
Number of output channels | 2 | 2 | Substantially equivalent |
Timer (minutes) Range | Adjustable, comparable to predicate (predicate 5-100 mins) | Default 20 mins, Adjustable to 10, 20, 30, 45, 60, 90 minutes | Both are adjustable; Substantially Equivalent |
Regulated Current or Regulated Voltage? | None | None | Substantially Equivalent. |
Software/Firmware/Microprocessor Control? | Yes | Yes | Identical control method |
Automatic No-Load Trip? | Yes | Yes | Identical |
Automatic Overload Trip? | Yes | Yes | Identical |
Automatic Shut Off? | Yes | Yes | Identical |
User Override Control? | Yes | Yes | Substantially Equivalent. |
Indicator Display: On/Off status | Yes | Yes | Identical |
Indicator Display: Low battery | Yes | Yes | Identical |
Indicator Display: Voltage/Current level | Yes | Yes | Identical |
Indicator Display: Time to cut-off | Yes | Yes | Identical |
Frequency (Hz) | Within acceptable range compared to predicate (predicate 1-150Hz) | 1-120Hz | Substantially equivalent |
Pulse Width (µs) | Within acceptable range compared to predicate (predicate 50-450µs) | 50-350µs | Substantially equivalent |
Waveform | Bi-phasic | Bi-phasic | Identical |
Shape | Rectangular | Rectangular | Identical |
Maximum Output Voltage (V) | 50V@ 500Ω | 50V@ 500Ω | Substantially equivalent |
Maximum Output Current (mA) | 100mA@ 500Ω | 100mA@ 500Ω | Substantially equivalent |
Maximum Phase Charge (µC) | Within acceptable range compared to predicate (predicate 37.6µC@ 500Ω) | 20.5µC@ 500Ω | Substantially equivalent |
Maximum Current Density, (mA/cm²) | Safe levels, compared to predicate (predicate 0.07426mA/cm²@ 500Ω) | 0.01013mA/cm²@ 500Ω (Area=25cm²) | Substantially equivalent |
Maximum Power Density, (W/cm²) | Safe levels, less than 0.25 W/cm² (predicate 0.0066W/cm²@ 500Ω) | 0.00053W/cm²@ 500Ω (Area=25cm²) | Substantially equivalent |
Power Source | Internal power supply (predicate used AAA batteries) | 2 Alkaline AA 1.5V Batteries | Both are internal power supply source: Substantially equivalent |
Weight | Comparable to predicate (predicate 83g) | 75 g without batteries | Substantially Equivalent. |
Dimensions (mm) [W x H x D] | Comparable to predicate (predicate 132 x 63 x 29.5 mm) | 120 x 60 x 31mm | Substantially Equivalent. |
Housing Materials and Construction | Safe and effective (predicate ABS plastics) | Silicone, ABS plastics | Substantially Equivalent. |
Electrode lead wires and patient cable | Yes (PVC) | Yes (PVC and nylon yarn) | Substantially equivalent |
Compliance with Voluntary Standards | Yes | Yes (See section 1.3/VII for specific standards) | Substantially equivalent |
2. Sample size used for the test set and the data provenance
The document does not specify a "test set" in the context of clinical data or patient outcomes. The performance evaluation is based on engineering and safety testing against recognized standards. Therefore, information regarding sample size and data provenance for a test set in the traditional sense (e.g., patient data) is not applicable here. The provenance for the device is the manufacturing facility in China (EasyMed Instruments Co Ltd).
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This information is not applicable. The evaluation framework is based on compliance with established engineering and safety standards, and a comparison to a predicate device. There is no mention of human expert-established "ground truth" for the performance tests conducted on the device's technical specifications.
4. Adjudication method for the test set
This information is not applicable. As there is no clinical "test set" requiring human interpretation or decision-making, an adjudication method for such a set is not relevant.
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
An MRMC study is relevant for evaluating the performance of AI-assisted diagnostic or decision-making systems. The Perfect EMS is an electrical stimulator for pain relief and muscle performance, not an AI diagnostic tool. Therefore, an MRMC comparative effectiveness study is not applicable and was not reported.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
The Perfect EMS is a physical medical device, not a software algorithm. Therefore, "standalone (algorithm only without human-in-the-loop performance)" is not applicable. Performance was assessed by measuring the device's electrical output and adherence to safety standards.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
The "ground truth" in this context is the pre-defined acceptance criteria set by recognized safety and performance standards (e.g., ANSI AAMI ES60601-1, IEC 60601-1-2, IEC 60601-1-11, IEC 60601-2-10, IEC 62304, ISO 10993-1) and the technical specifications of the legally marketed predicate device (EM49-2 K190347). The device's performance was measured against these established quantitative parameters and qualitative design characteristics.
8. The sample size for the training set
This information is not applicable. The Perfect EMS is a hardware device; it does not explicitly mention any machine learning or AI components that would require a "training set" for an algorithm.
9. How the ground truth for the training set was established
This information is not applicable for the same reason as point 8. There is no mention of a training set or AI algorithm in this context.
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(170 days)
TensCare Ltd.
Perfect PFE is intended to provide electrical stimulation and neuromuscular re-education for the purpose of rehabilitation of weak pelvic floor muscles for the treatment of stress, urge and mixed urinary incontinence in women and to maintain urinary continence in women.
The Perfect PFE is a hand-held, home-use device designed to treat stress, urge and mixed urinary continence in women and maintain urinary continence in women. The device is supplied with a reusable (single-patient use) vaginal, dual-electrode, stimulation probe. The probe connects to the control unit by cable and plug and is inserted into the end user. The probe has a recommended usage duration of 6 months.
The device is battery powered, single channel, home use neuromuscular stimulation. Electrical stimulation is delivered via stainless steel electrodes on the probe to induce a contraction of the pelvic floor muscles. Muscle stimulation is used to train and strengthen the pelvic floor muscles in a controlled manner. Muscle stimulation is used to improve the ability of muscles to hold a contraction for an extended period of time and is a treatment for urinary incontinence. During a session, stimulation is delivered to specific muscles to encourage their contraction. This contraction strengthens the muscles and also helps the end user recognize which muscles to activate during self-directed contractions. The level of electrical stimulation is easily controlled by the end user using manual, push-button controls.
The unit is intended for home use by the patient. It has four preset treatment programs, a preset treatment timer, a compliance monitor, and open circuit detectors.
Accessories: Lead Wire (L-CPT) Liberty Loop vaginal probe (X-VPL)
This document is a 510(k) Premarket Notification from TensCare Ltd. for their device, the "Perfect PFE," a non-implanted electrical continence device. The FDA determined the device to be substantially equivalent to legally marketed predicate devices.
The request asks for details on the acceptance criteria and the study proving the device meets these criteria. However, this document primarily focuses on demonstrating substantial equivalence to existing predicate devices (TensCare KegelFit and Yarlap), rather than presenting a performance study with acceptance criteria in the typical sense for a novel medical device. The 510(k) pathway for medical device clearance in the US does not generally require clinical trials to prove efficacy if substantial equivalence to a legally marketed predicate device can be demonstrated.
Therefore, many of the requested items (e.g., sample size for test set, number of experts for ground truth, MRMC study, standalone performance) are not applicable to this type of submission. The "study" here is primarily a comparison against predicate devices and adherence to recognized safety standards.
Here's how the information maps to your request based on the provided document:
1. Table of Acceptance Criteria and Reported Device Performance
For a 510(k) submission based on substantial equivalence, the "acceptance criteria" are generally met by demonstrating that the new device is as safe and effective as the predicate device. This is primarily done through a comparison of technological characteristics, intended use, and adherence to relevant safety standards. The "performance" is shown by meeting these comparisons and standards.
Acceptance Criterion (Demonstrating Substantial Equivalence) | Reported Device Performance (as demonstrated by comparison/testing) |
---|---|
Similar Intended Use & Indications for Use | Perfect PFE's indications are "to provide electrical stimulation and neuromuscular re-education for the purpose of rehabilitation of weak pelvic floor muscles for the treatment of stress, urge and mixed urinary incontinence in women and to maintain urinary continence in women." This is either identical or substantially equivalent to predicates. |
Similar Technological Characteristics | Perfect PFE's design, function (electrical muscle stimulation, single-channel, battery-powered, home-use), and stimulation parameters (frequency, pulse width, max voltage, max current, max phase charge) are similar or substantially equivalent to the predicate devices (KegelFit and Yarlap) as shown in Table 1, page 6. The differences in specific parameters (e.g., number of output modes, channels, specific frequencies within programs) are argued to not raise new safety/effectiveness concerns. |
Compliance with Safety Standards | The device complies with relevant safety consensus standards: ANSI AAMI ES60601-1 (general safety), IEC 60601-1-2 (EMC), IEC 60601-1-11 (home healthcare), IEC 60601-2-10 (nerve and muscle stimulators), ISO 14971 (risk management), IEC 60601-1-6 (usability - though further usability testing was not done due to similarity), IEC 62304 (software life cycle processes), and ISO 10993-1 (biocompatibility, confirmed by cytotoxicity, sensitization, and irritation tests). |
No New Questions of Safety or Effectiveness | The submission asserts that the information presented and performance testing (standard compliance) demonstrate with reasonable assurance that the device is at least as safe and effective as a legally marketed device and does not raise different questions about safety or effectiveness. |
Probe Substantial Equivalence and Safety | The vaginal probe (Liberty Loop) is "similar in size, materials, and electrode position" to the predicate probe (Liberty vaginal probe), and both are reusable for single-patient use. The difference in shape (oval loop vs. solid) does not impact substantial equivalence for treating incontinence. |
Maximum Power Density | The maximum power density of Perfect PFE is less than 0.25 watts per square centimeter of electrode conductive surface area, which is within the safe range for reducing thermal burns, similar to the predicate devices. |
2. Sample Size Used for the Test Set and the Data Provenance
- Sample Size for Test Set: Not applicable. This submission relies on demonstrating substantial equivalence to predicate devices and compliance with recognized standards, not a specific clinical test set to evaluate performance metrics like sensitivity or specificity.
- Data Provenance: Not applicable in the context of a "test set" for performance evaluation. The data presented is primarily engineering specifications, comparison tables, and adherence to international safety standards.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts
- Number of Experts: Not applicable. "Ground truth" in the context of clinical performance data for a diagnostic/treatment device is not required for this type of 510(k) submission, as it's based on substantial equivalence rather than novel performance claims.
- Qualifications of Experts: N/A
4. Adjudication Method for the Test Set
- Adjudication Method: Not applicable. 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
- MRMC Study: Not applicable. This device is an electrical stimulator for home use, not an AI-assisted diagnostic imaging device that would typically undergo MRMC studies.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Standalone Performance: Not applicable. This is a physical medical device, not a software algorithm that operates in a standalone manner.
7. The Type of Ground Truth Used
- Type of Ground Truth: Not applicable. Clinical "ground truth" (e.g., pathology, outcomes data) is not part of a substantial equivalence demonstration for a device of this type, which is cleared based on its similarity to existing cleared devices and adherence to safety standards.
8. The Sample Size for the Training Set
- Sample Size for Training Set: Not applicable. This device does not use an AI algorithm that requires a training set.
9. How the Ground Truth for the Training Set was established
- How Ground Truth Established: Not applicable.
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(224 days)
TENSCARE LTD.
KegelFit is a non-implanted muscle stimulator designed to treat female stress urinary incontinence. It applies stimulation to the pelvic floor muscles to improve strength and support. The KegelFit is intended for OTC sale.
The KegelFit is a hand-held, home-use device designed to treat female stress urinary incontinence. The device is supplied with a vaginal two electrode stimulation probe (Trainer). The trainer connects to the control unit by cable and plug and is inserted into the vagina by the end user. Electrical stimulation is delivered via stainless steel electrodes on the trainer to induce a contraction of the pelvic floor muscles. Muscle stimulation is used to train and strengthen the pelvic floor muscles in a controlled manner. Muscle stimulation is used to improve the ability of muscles to hold a contraction for an extended period of time and is a treatment for urinary incontinence. During a session, stimulation is delivered to specific muscles to encourage their contraction. This contraction strengthens the muscles and also helps the end user recognize which muscles to activate during self-directed contractions. The level of electrical stimulation is easily controlled by the end user using manual, push-button controls. The device is battery powered single channel home use neuromuscular stimulation. Electrical stimulation is delivered via stainless steel electrodes on the inflatable probe to induce a contraction of the pelvic floor muscles. Muscle stimulation is used to train and strengthen the pelvic floor muscles in a controlled manner. Muscle stimulation is used to improve the ability of muscles to hold a contraction for an extended period of time and is a treatment for urinary incontinence. During a session, stimulation is delivered to specific muscles to encourage their contraction. This contraction strengthens the muscles and also helps the end user recognize which muscles to activate during self-directed contractions. The level of electrical stimulation is easily controlled by the end user using manual, push-button controls. The unit is intended for home use by the patient, and is designed with simplicity and ease of use in mind. It has two preset treatment programs, a preset treatment timer, a compliance monitor, and open circuit detectors.
The provided text does not contain specific acceptance criteria with numerical thresholds, nor does it detail a clinical study with a control group and effect sizes to prove that the Tenscare KegelFit device meets such criteria. Instead, the submission focuses on establishing substantial equivalence to previously cleared predicate devices through comparisons of technological characteristics, intended use, and safety documentation.
Here's an breakdown of the information that can be extracted from the document, organized according to your request:
1. Table of Acceptance Criteria and Reported Device Performance
As mentioned, explicit acceptance criteria with specific numerical targets (e.g., "sensitivity > 90%") for the device's clinical performance are not provided in this document. The document focuses on demonstrating substantial equivalence to predicate devices, rather than meeting novel performance criteria through new clinical endpoints.
Instead of formal "acceptance criteria," the document outlines areas of comparison to establish substantial equivalence. The "reported device performance" is framed in terms of its similarity to predicates and successful safety testing.
Feature/Function (Analogous to Acceptance Criteria) | Tenscare KegelFit Performance (Reported Device Performance) | Comparison to Predicate A (itouch Sure) | Comparison to Predicate C (Apex) |
---|---|---|---|
Intended Use | Non-implanted muscle stimulator for female stress urinary incontinence, applies stimulation to pelvic floor muscles to improve strength and support. | Substantially equivalent (after removing Urge and Mixed incontinence programs, and modifying label for OTC). | Identical |
Indications for Use | Treats female stress urinary incontinence by applying stimulation to pelvic floor muscles. | Substantially equivalent (removed non-stress incontinence indications). | Identical |
Primary Function | Delivery of electrical stimulation. | Identical | Identical |
Safety - Software | "Moderate" level of concern. Passed V&V. | Identical | Identical |
Safety - Electrical | Complies with IEC 60601-1 and IEC60601-1-11. EMC tested to EN60601-1-2:2007. | Identical (to itouch Sure, concerning 21 CFR 898 for cable/lead). | Substantially equivalent (Apex has no leads for comparison). |
Safety - Biocompatibility | Vaginal electrode material (ABS, stainless steel) tested per ISO 10993-5:2009 and ISO 10993-10:2002. | Identical (same electrode as itouch Sure). | Substantially equivalent (different materials, but both cleared). |
Labeling Clarity for OTC Use | Designed for self-diagnosis of SUI and identification of contraindications, and effective use based on instructions. | Substantially equivalent (operating instructions based on itouch Sure, revised for usability). | Substantially equivalent (based on Apex for self-diagnosis, contraindications, warnings). |
Usability/Ease of Use (for OTC) | Instructions easy to follow/device easy to use without training. | Supported by customer reviews of itouch Sure. | Supported by customer reviews of itouch Sure. |
Output Modes | Two (TRAIN / 50Hz Stress, 35Hz Tone). | Substantially Equivalent (Reduced from four in itouch Sure, matching altered Intended Use). | Substantially equivalent (increased from one in Apex). |
Max Output Voltage (500Ω) | 45V | Identical | Substantially equivalent (Apex 34.2V, both deemed safe/effective). |
Max Output Current (500Ω) | 90mA | Identical | Substantially equivalent (Apex 68.2mA, both deemed safe/effective). |
Max Phase Charge (500Ω) | 18.6 μC | Identical | Substantially equivalent (Apex 13.6 μC; Apex is monophasic). |
Max Current Density | 10.46 mA/cm2 | Identical | Substantially equivalent (Apex 11.6 mA/cm2; both deemed safe/effective). |
Max Average Power Density (500Ω) | 5.84 mW/cm2 | Identical | Substantially equivalent (Apex 3.95 mW/cm2; no special requirement for home use). |
2. Sample Size Used for the Test Set and Data Provenance
The "testing" mentioned is not a human clinical trial test set in the traditional sense, but rather a combination of:
- Customer Reviews Analysis:
- Sample Size: 13,758 OTC sales of the predicate device "itouch Sure" through Amazon UK.
- Data Provenance: Retrospective, derived from customer reviews in the UK (EU market at the time).
- Customer Questionnaires:
- Sample Size: 21 responses received from 120 users of "itouch Sure" who purchased OTC through eBay UK.
- Data Provenance: Prospective (questionnaires sent out), with data from UK (EU market).
- Labeling Comparison: Not a "test set" in terms of subject count, but a comparison of documents.
- Clinical Literature Evaluation: Not a specific test set, but a review of existing literature.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts
- Customer Reviews/Questionnaires: No medical experts established "ground truth" for the usability and self-diagnosis aspects derived from customer feedback. The "truth" in this context is the aggregated perception and experience of lay users.
- Labeling Comparison: The comparison was performed by the submission authors (Tenscare Ltd.). The qualifications of these individuals are not specified in the provided text.
- Clinical Literature Review: This implies an expert review, but the number and specific qualifications of the individuals who conducted this review are not stated.
4. Adjudication Method for the Test Set
- Customer Reviews/Questionnaires: There is no mention of a formal adjudication method by experts. The analysis involved reviewing customer feedback.
- Labeling Comparison: This was a direct comparison done by the submitter, not requiring an adjudication panel.
- Clinical Literature Review: No specific adjudication method 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
No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. The device is an electrical muscle stimulator, not an AI-powered diagnostic tool requiring human reader interpretation of images or other data. This type of study is not relevant to this device.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done
The Tenscare KegelFit is a physical medical device (muscle stimulator) intended for home use by patients, not an algorithm. Therefore, a "standalone algorithm performance" study is not applicable. The device's performance is inherently linked to its use by a human operator. Its "standalone" performance might refer to its functional specifications (e.g., electrical parameters) which were tested in electrical safety and EMC tests, but not in a "standalone algorithm" context.
7. The Type of Ground Truth Used
- For safety and effectiveness: The "ground truth" relies on:
- Substantial equivalence to predicate devices: The established safety and effectiveness of the existing itouch Sure and Apex devices (which presumably had their own ground truth established in prior clearances).
- Clinical literature evaluation: Existing medical literature on the efficacy of electrical stimulation for stress urinary incontinence.
- For usability and self-selection for OTC use: The "ground truth" was established by:
- Customer feedback/reviews: Direct user experience and statements regarding ease of use and understanding of instructions and contraindications. This serves as a proxy for "ground truth" in the context of user comprehension for an OTC product.
8. The Sample Size for the Training Set
Not Applicable. The Tenscare KegelFit is not an AI/ML algorithm that requires a "training set" of data. It is a hardware medical device with pre-programmed settings.
9. How the Ground Truth for the Training Set was Established
Not Applicable. As there is no AI/ML algorithm or training set, this question does not apply.
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(183 days)
TENSCARE LTD.
The itouch Sure is intended to provide electrical stimulation and neuromuscular re-education for the purpose of rehabilitation of weak pelvic floor muscles for the treatment of stress, urge, and mixed urinary incontinence in women
The itouch Sure is a small lightweight battery powered single channel neuromuscular stimulation device supplied with a vaginal two electrode stimulation probe. The probe connects to the control unit by cable and plug. The unit is intended for home use by the patient, and is designed with simplicity and ease of use in mind. It has four preset treatment programs, an adjustable treatment timer, a compliance monitor, and open circuit detectors.
The TensCare itouch Sure Pelvic Floor Exerciser (K103698) is a Class II device intended to provide electrical stimulation and neuromuscular re-education for the rehabilitation of weak pelvic floor muscles to treat stress, urge, and mixed urinary incontinence in women.
The submission does not include a separate study that establishes acceptance criteria and proves the device meets them in the way clinical performance studies with specific endpoints would. Instead, the FDA's "substantial equivalence" determination for this 510(k) submission is based on a technological comparison to predicate devices. This means the device is deemed safe and effective because its technological characteristics and intended use are similar to those of devices already legally marketed, and any differences do not raise new questions of safety or effectiveness.
Therefore, the "acceptance criteria" here are inherent to the regulatory process for substantial equivalence, focusing on whether the new device is as safe and effective as its predicates based on a comparison of their features and performance characteristics.
Here’s an interpretation of the requested information based on the provided document:
1. Table of Acceptance Criteria and Reported Device Performance
Since this is a substantial equivalence submission, the "acceptance criteria" are not explicit numerical targets from a performance study but rather the demonstration that the TensCare itouch Sure's technical specifications and safety profile are comparable to the predicate devices.
Acceptance Criteria (Implied by Substantial Equivalence) | Reported TensCare itouch Sure Performance (as stated in the document) |
---|---|
Intended Use Equivalence: Treatment of urinary incontinence | "The itouch Sure is intended to provide electrical stimulation and neuromuscular re-education for the purpose of rehabilitation of weak pelvic floor muscles for the treatment of stress, urge, and mixed urinary incontinence in women." (Same as predicates) |
Technological Equivalence (Key Parameters): | (See detailed comparison table in the "Technological Comparison" section of the 510(k) summary) |
Frequency (Hz) | 10/20/35/50 (Comparable to predicates, e.g., K941911: 12.5/50; K81480: 2-100) |
Pulse Width (uS) | 200/250/300 (Comparable to predicates, e.g., K941911: 300; K81480: 50-450) |
Output Current/Voltage | 0-45V = 0-90mA over 500 Ohm; Constant current 160-500 Ω, Constant voltage 500-1500 Ω (Comparable to predicates, e.g., K941911: 0-60mA (100mA override); K81480: 0-90 mA nominal) |
Waveform Type & Shape | Bi-phasic, Rectangular at positive (Substantially equivalent to Kegel 8; difference in negative phase not clinically significant) |
Biocompatibility: Probe materials are safe for patient contact. | Materials (ABS, Stainless Steel) are the same as Kegel 8 probe. Biocompatibility tests (ISO 10993-5:2009 and -10:2002) showed no cytotoxicity, negligible vaginal irritation, no sensitization. |
Safety: Compliance with relevant safety standards, controlled output energy, no new safety hazards. | Designed to comply with recognized consensus standards. Output energy controlled within safety/effectiveness ranges. Test results, Risk Analysis, FMEA show it is safe. Device controls output at constant voltage > 500 Ω and pseudo-constant current |
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(175 days)
TENSCARE LTD
TENS stands for Transcutaneous Electrical Nerve Stimulation. The itouch TENS system is indicated for:
- Symptomatic relief and management of chronic, intractable pain. .
- Adjunctive treatment for post-surgical and post-trauma acute pain. .
A portable TENS device for pain relief.
Features:
- Innovative design
- Large LCD display
- Dual output isolated channels
- 2 AA Alkaline Batteries
- Adjustable frequency, pulse width, and timing parameters
- 9 different modes
- Timer option
- Doctor lock/unlock facility
- Open circuit detectors
- Non-volatile
The provided 510(k) summary for the Tenscare TENS Model itouch (K082377) does not contain a study that proves the device meets specific acceptance criteria in the way typically found for novel diagnostic algorithms or devices.
Instead, this submission primarily focuses on demonstrating substantial equivalence to predicate devices (EasyMed TENS Unit TN-28C and Gemore GM300T) via technological comparison, labeling comparison, and compliance with recognized safety standards. For TENS devices, the primary "acceptance criteria" are related to safety, electrical output specifications, and efficacy established by existing, legally marketed devices.
Here's an breakdown based on the provided text, addressing your points where information exists:
1. Table of Acceptance Criteria and Reported Device Performance
As per the document, specific, quantifiable acceptance criteria (e.g., target accuracy, sensitivity, specificity) for a clinical study proving device efficacy are not presented for the Tenscare itouch. Instead, the "performance" is implicitly tied to compliance with standards and equivalence to predicate devices which are already accepted as safe and effective.
The closest to "acceptance criteria" are:
Acceptance Criterion (Implicit) | Reported Device Performance/Comparison |
---|---|
Safety: Compliance with relevant recognized consensus standards. | "Design to comply with relevant safety applicable recognized consensus standards;" |
"the output energy is well controlled in the safety and effectiveness ranges specified by relevant FDA guidance's." | |
"Test results, Risk Analysis, and FMEA analysis show that the new unit itouch is safe with no any hazard." | |
Performance: Output characteristics (e.g., constant current). | "Itouch was designed and added the constant current feature based on the design of TN-28C (K040253). The introduction of marketed device Gemore GM300T (K032720) is for the purpose of comparison of the feature of constant current." |
"The new device itouch is of the same range of parameters as those of marketed devices." | |
Post-Market Performance (Europe): Functioning as intended. | "itouch has been marketed in Europe. During this period a review of Customer Complaints, Returned Product and the results of Post Market Feedback, has demonstrated that the product has performed as Intended, to its' Specified Requirements." |
2. Sample size used for the test set and the data provenance
- No specific clinical test set is described. The submission relies on technological comparison and compliance with standards rather than a new clinical performance study with a dedicated test set of patient data.
- The reference to "itouch has been marketed in Europe" and "review of Customer Complaints, Returned Product and the results of Post Market Feedback" suggests retrospective data analysis from real-world usage in Europe. However, no sample sizes for this feedback are provided.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- This is not applicable as there is no described clinical study with a "test set" and associated "ground truth" derived by experts for performance evaluation.
4. Adjudication method for the test set
- This is not applicable as there is no described clinical study with a "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
- This is not applicable. The device is a Transcutaneous Electrical Nerve Stimulator (TENS), not an AI-powered diagnostic tool, and therefore, an MRMC study involving human readers and AI assistance is outside its scope.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done
- This is not applicable. The Tenscare itouch is a medical device for pain relief, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- For the European post-market review, the "ground truth" was implicitly the real-world performance as intended by the device's design and specified requirements, based on customer complaints, returned products, and feedback. This can be considered a form of "outcomes data" related to device function and patient satisfaction, rather than a diagnostic ground truth.
- For the submission to the FDA, the "ground truth" for demonstrating equivalence is the established safety and efficacy profile of the predicate devices and compliance with recognized electrical safety and performance standards.
8. The sample size for the training set
- This is not applicable. The device is not an AI algorithm that requires a "training set." Its design and development are based on established engineering principles for TENS devices and comparison to predicate devices.
9. How the ground truth for the training set was established
- This is not applicable as there is no "training set" for an AI algorithm.
In summary:
The K082377 submission for the Tenscare TENS Model itouch demonstrates substantial equivalence to predicate devices through technical comparisons, adherence to safety standards, and general claims of satisfactory performance in the European market. It does not present a clinical study with specific acceptance criteria, test sets, or ground truth establishment in the manner typically seen for novel diagnostic or AI-driven medical devices. The primary "proof" relies on the device being technologically similar to and meeting the same safety standards as already cleared TENS devices.
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(90 days)
TENSCARE LTD.
For the TENS function: TENS is used for the relief and management of symptomatic intractable pain and/or as an adjunctive treatment in the management of postsurgical and post traumatic acute pain.
For the EMS function: The Ultima NMS/EMS is indicated for: Relaxation of muscle spasm. Prevention or retardation of disuse atrophy. Increasing local blood circulation. Muscle re-education. Prevention of venous thrombosis of the calf. muscles immediately after surgery. Maintaining or increasing range of motion.
For the TENS function: A portable TENS device for pain relief.
For the EMS function: A portable EMS device for the re-education of muscles.
The Ultima NMS/EMS (the "New Device") brings together TENS and Powered Muscle Stimulator functions from two previously cleared for market devices; namely the Ultima TENS (K020846) for the TENS functions and the TensCare XL-Y3 (K011543) for the Powered Muscle Stimulator functions.
The electrical. EMC and software technologies used in the Ultima NMS/EMS (the 'New Device'), are identical to the Ultima TENS (the Predicate device - (K020846), in that the same CPU series is utilised (the difference being that the variant used has increased memory capacity).
In addition, the "New Device" uses the same passive and active electrical components and PCB layout, as the Predicate devices.
The Powered Muscle Stimulator functions are derived from software programmed into the CPU device and are based on and virtually identical to the Predicate device.
The TensCare Ultima NMS/EMS has a Doctor Important anti-Misuse feature: Lock facility, which means that at the Treating Physician's discretion, the patient has no control over the devices outputs; the Programs are pre-set by the Treating Physician.
The use of 'shrouded patient cable connectors' to comply with FDA's Final Rule "Medical Devices: Establishment of Performance Standards for Electrode Lead Wires and Patient Cables" is utilised to further ensure no hazards exist.
Acceptance Criteria and Device Performance for TensCare Ultima NMS/EMS
This document summarizes the acceptance criteria and supporting study information for the TensCare Ultima NMS/EMS device based on the provided text.
1. Table of Acceptance Criteria and Reported Device Performance:
The provided text does not contain explicit, quantitative acceptance criteria for the TensCare Ultima NMS/EMS device in the form of a table. Instead, it relies on demonstrating substantial equivalence to predicate devices and performance in the European market.
The primary "acceptance criteria" appear to be:
- Substantial Equivalence: The electrical, EMC, and software technologies, as well as the passive and active electrical components and PCB layout, are identical or virtually identical to the predicate devices.
- Safety and Effectiveness: Bench testing, VVT (Verification, Validation, and Testing), and Risk Analysis (including FMEA) demonstrate that the device performs as intended with no harm to the user. Also, the device prevents simultaneous use of TENS and EMS functions.
- Post-Market Performance (EU): Review of customer complaints, returned products, and post-market feedback from over two years in the European market (in its TENS form) demonstrates performance as intended.
Acceptance Criteria (Inferred) | Reported Device Performance |
---|---|
Technological Substantial Equivalence to Predicate Devices: | The electrical, EMC, and software technologies (CPU series, passive/active electrical components, PCB layout) are identical or virtually identical to the TensCare Ultima TENS (K020846) for TENS functions and TensCare XL-Y3 (K011543) for EMS functions. EMS functions are software-derived and virtually identical. |
Output Characteristics Substantial Equivalence to Predicate Devices: | Bench testing demonstrates that the output characteristics of the TensCare Ultima NMS/EMS are substantially equivalent to those of the two predicate devices. |
Safety of Combined Functions: | Bench Testing, VVT, and Risk Analysis (including FMEA) demonstrate that the device performs as intended with no harm to the user. It is not possible to use TENS and EMS functions simultaneously due to mechanical integrity. The device includes 'shrouded patient cable connectors' for safety. |
Patient Control Restriction Option: | The device has a Doctor Important anti-Misuse feature: Lock facility, allowing the Treating Physician to pre-set programs, preventing patient control over device outputs. |
Post-Market Performance (European Market - TENS form): | Over two years of data from the European market (for the TENS form) including customer complaints, returned products, and post-market feedback, demonstrated that the product performed as intended to its specified requirements. |
2. Sample Size Used for the Test Set and Data Provenance:
- Sample Size: Not applicable in the context of an AI/algorithm-based device as this device is a physical medical stimulator. The "testing" primarily involved bench testing, VVT, risk analysis, and post-market surveillance.
- Data Provenance:
- Bench Testing, VVT, Risk Analysis: Likely internal company data.
- Post-Market Feedback: European Market data from the TENS form of the product over two years.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts:
Not applicable. The product is a physical device, and its safety and effectiveness were assessed through engineering comparisons, bench testing, and review of existing market performance, rather than through expert-driven ground truth establishment for an AI algorithm.
4. Adjudication Method for the Test Set:
Not applicable. This is not an AI/algorithm-based device requiring an adjudication process for ground truth.
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:
No, an MRMC comparative effectiveness study was not done. The text explicitly states: "Clinical Testing was not necessary as no new or innovative aspects have been introduced." This indicates that the device's performance was not evaluated in a clinical trial comparing it against human performance or AI assistance.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done:
Not applicable. This device is a physical medical stimulator, not an algorithm.
7. The Type of Ground Truth Used:
For the TensCare Ultima NMS/EMS, the "ground truth" for its safety and effectiveness was established through:
- Predicate Device Performance: The primary ground truth is the established safety and effectiveness of the two predicate devices (TensCare Ultima TENS (K020846) and TensCare XL-Y3 (K011543)). The new device's equivalence to these legally marketed devices forms the basis of its clearance.
- Bench Test Results: Objective measurements of electrical output characteristics.
- VVT (Verification, Validation, and Testing): Standard engineering validation processes.
- Risk Analysis (FMEA): Identification and mitigation of potential hazards.
- Post-Market Surveillance Data: Real-world performance data (customer complaints, returned products) from the European market for the TENS functions.
8. The Sample Size for the Training Set:
Not applicable. This is a medical device, not an AI model that requires a training set.
9. How the Ground Truth for the Training Set Was Established:
Not applicable. As noted above, this device does not involve a "training set" for an AI algorithm.
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