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510(k) Data Aggregation

    K Number
    K121578
    Date Cleared
    2012-07-31

    (62 days)

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

    The BRC 2200 is intended for temporary symptomatic relief and management of chronic intractable pain and as an adjunctive treatment in the management of post-surgical and post-traumatic pain.

    Device Description

    The BRC 2200 is a non-invasive, therapeutic device that delivers bipolar electrical current. In order to maintain a neutral charge for each cycle, the device delivers a current of one polarity for the first half of the cycle and then the opposite polarity for the second half of the cycle. The BRC 2200 is a hand-held device with a touch screen designed for ease of the user. The licensed healthcare professional uses a pass code to access screens regarding the treatment options and patient information. The main treatment screen shows the progression of the treatment, date, time, battery level, and gives options to pause the treatment or reduce the power if the patient feels discomfort. The BRC 2200 contains 24 pre-programmed treatments accessible only to the licensed healthcare professional. Using the designated pass code, the licensed healthcare professional selects the treatment and updates the correct patient information to the device before starting the treatment. Once the treatment has started, the patient will be able to pause the treatment or reduce power if he/she feels mild discomfort. Components included with the BRC 2200 contain a pair of single-use electrodes, a pair of electrode cables, a battery charger, and an optional USB cable. The electrodes come in a variety of sizes ranging from extra-small to large and either two inch or three inch widths. The electrodes attach by being circumferentially wrapped around a limb or the trunk of the body and the overlapping ends secured with hook and loop fasteners to maintain circumferential tension during treatment. The electrodes consist of a conductive layer sandwiched between a layer of polyurethane foam and a layer of synthetic neoprene. The foam is in contact with normal, intact skin for up to 3 hours and complies with ISO 10993. The electrode cables attach to the electrodes via a silver metal hook and loop fastener which then attaches to the BRC 2200 using push-pull connectors. The electrode cables used with the electrodes can be multi-use and are available in 40, 50, and 60 inches in length. These three different sizes in electrode cables allow for differences in the placement of electrodes and the different sizes of patients. In order to conduct the current through the body, the electrodes require water as the conducting medium. This is achieved by soaking the electrodes in water or normal saline solution and applying to the location in which current flow should be directed. The BRC 2200 is powered by a Tenergy 3.7V Li-polymer rechargeable battery. The battery is charged by the Tenergy 3.7V Li-ion battery charger model OH-1048A0451500U. The optional USB cable allows the licensed healthcare professional to obtain treatment information and transfer it to a computer. The BRC 2200 is a prescription device and can be used in a healthcare facility or at home.

    AI/ML Overview

    This 510(k) submission (K121578) is for the BRC 2200, a transcutaneous electrical nerve stimulator (TENS) device. The primary claim for substantial equivalence is based on comparing the BRC 2200 to a legally marketed predicate device, the BodiHealth System (K052836). The focus of this submission is on demonstrating similar technical, functional, and performance characteristics, and adherence to relevant safety standards, rather than a clinical study evaluating the device's efficacy against specific acceptance criteria related to patient outcomes or pain relief.

    Therefore, the requested information categories related to clinical studies, ground truth establishment, expert adjudication, multi-reader multi-case studies, and human-in-the-loop performance are not directly applicable or available in this 510(k) summary, as the submission relies on demonstrating substantial equivalence through non-clinical testing and comparison of technical specifications.

    Here's an analysis of the available information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria in this 510(k) summary are implicitly defined by demonstrating that the BRC 2200 device shares "similar technical, functional, and performance characteristics" with the predicate device, BodiHealth System (K052836), and that it complies with relevant non-clinical standards. The predicate device serves as the benchmark for these "acceptance criteria."

    Characteristic / Acceptance Criteria (based on predicate)Reported BRC 2200 Performance
    Intended Use: Temporary symptomatic relief and management of chronic intractable pain and as an adjunctive treatment in the management of post-surgical and post-traumatic pain.Matches the predicate device's intended use.
    Power Source: Rechargeable battery operatedTenergy Li-ion battery 3.7V - 3Ah
    Average DC current through electrodes (device on, no pulses): ≤ 0.002 µA0.002 µA
    Number of Output Modes: Compared to 26 for predicate24
    Number of Output Channels: 11
    Regulated Current or Regulated Voltage?: Regulated currentRegulated current
    Software/Firmware/Microprocessor Control?: YesYes
    Automatic Overload Trip?: YesYes
    Automatic No-Load Trip?: NoNo
    Automatic Shut Off?: (Predicate: No)Yes
    Indicator Display: On/Off Status?: YesYes
    Indicator Display: Low Battery?: YesYes
    Indicator Display: Voltage/Current Level?: (Predicate: No)Yes
    Indicator Display: Open Circuit?: YesYes
    Timer Range (minutes): User-controlled with 23 minute cycles (predicate)92-161 minutes (maximum treatment time)
    Compliance with 21 CFR 898?: YesYes
    Weight: 7 lbs., 3 oz. (predicate)10.5 oz.
    Dimensions: 9 in. x 4.5 in. x 11 in. (predicate)5.9 in. x 3.75 in. x 1.5 in.
    Housing Materials and Construction: Injection-molded plastic caseInjection-molded plastic case
    Waveform: BiphasicBiphasic
    Shape: RectangularRectangular
    Maximum Output Voltage: 1.5V@500 Ω, 6V@2 KΩ, 25V@10kΩ (predicate)1.5V@500 Ω, 6V@2 kΩ, 30V@10kΩ
    Maximum Output Current: 3mA@500 Ω, 3mA@2 kΩ, 2.5mA@ 10 kΩ (predicate)3mA@500 Ω, 3mA@2 kΩ, 3mA@10kΩ
    Pulse duration: 128 ms (predicate)100 ms
    Frequency: 7.8 Hz (predicate)10 Hz
    Net Charge (per pulse): 0 µC @500Ω, Symmetrical waveform0 µC @500Ω, Symmetrical waveform
    Maximum Phase Charge: 4.3 µC @500Ω (predicate)3 µC @500Ω
    Maximum Current Density: 0.0089 mA/cm²@500Ω (predicate)0.0205 mA/cm²@500Ω
    Maximum Average Current (average absolute value): 3mA@500Ω3mA@500Ω
    Maximum Average Power Density: 13.297 μW/ cm² @500Ω (predicate)30.7μW/ cm² @500Ω
    ON Time: User-controlled (predicate)9660 seconds (maximum treatment time)
    Additional Features: (Predicate had none listed)Data-logging
    Non-Clinical Standards Compliance:IEC 60601-1, IEC 60601-1-2, IEC 60601-1-4, IEC 60601-2-10 (electrical safety)
    Biocompatibility Standards Compliance:ISO 10993-1, ISO 10993-5, ISO 10993-10 (skin-contacting materials)

    Note on "Acceptance Criteria": For a 510(k) submission based on substantial equivalence to a predicate device, the "acceptance criteria" are generally met by demonstrating that the new device is as safe and effective as the predicate device. This is often achieved by showing similar technological characteristics and performance, and compliance with recognized safety standards. Direct quantitative "acceptance criteria" for clinical efficacy (e.g., "reduce pain by X%") are typically not part of a 510(k) where substantial equivalence is demonstrated through non-clinical means, as is the case here.

    2. Sample size used for the test set and the data provenance

    Not applicable/provided. This submission relies on non-clinical testing and comparison to a predicate device's technical specifications, not a clinical test set with patient data for assessing performance like accuracy, sensitivity, or specificity. The "test set" here refers to the device itself undergoing various engineering and safety tests.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    Not applicable/provided. No clinical "ground truth" for patient outcomes was established or utilized in this 510(k) for the BRC 2200. The "ground truth" for the non-clinical tests would be the established safety and performance specifications defined by the relevant IEC and ISO standards.

    4. Adjudication method for the test set

    Not applicable/provided. As there was no clinical test set requiring expert interpretation or consensus, no adjudication method was used. Non-clinical tests were likely evaluated against pre-defined engineering and safety specifications.

    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/provided. The BRC 2200 is a TENS device, not an AI-assisted diagnostic or interpretive device. Therefore, MRMC studies and AI assistance are irrelevant to this submission.

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

    Not applicable/provided. The BRC 2200 is a TENS device that delivers electrical current; it does not involve an algorithm with standalone performance in the context of interpretation or diagnosis. It is inherently a human-in-the-loop device in its application (a healthcare professional operates it), but this is not an "algorithm only" scenario.

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

    Non-clinical/Engineering Standards. The "ground truth" for this 510(k) is the adherence to established international and national standards for medical device safety and performance criteria for TENS devices. This includes:

    • Electrical Safety: IEC 60601-1, IEC 60601-1-2, IEC 60601-1-4, IEC 60601-2-10.
    • Biocompatibility: ISO 10993-1, ISO 10993-5, ISO 10993-10.
    • General Performance Characteristics: Comparison against the technical specifications of the predicate device (BodiHealth System K052836) to demonstrate substantial equivalence.

    8. The sample size for the training set

    Not applicable/provided. This device does not use machine learning or AI that would require a "training set" in the conventional sense.

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

    Not applicable/provided. As there is no training set, there is no method for establishing its ground truth.

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