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510(k) Data Aggregation

    K Number
    K162744
    Date Cleared
    2017-08-03

    (307 days)

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

    Everyway OTC EMS is intended to stimulate healthy muscles in order to improve or facilitate muscle performance. The various types of muscle work that Everyway OTC EMS can impose on the stimulated muscles are able to improve or facilitate muscle performance. Everyway OTC EMS may therefore be considered a technique of muscle training.

    Device Description

    The Everyway OTC EMS, model EV-805 is a dual channel powered muscle stimulator intended to stimulate healthy muscles in order to improve or facilitate muscle performance. The various types of muscle work that Everyway OTC EMS can impose on the stimulated muscles are able to improve or facilitate muscle performance by applying an electrical current to electrodes, which are attached on the user's skin.

    The device measures 101mm(H)x 68mm(W)x21.5mm(D). Its outer housing is made of injection molded thermoplastic resin with the output contact probes consist of chrome-plated spheres. The device is powered by a 9-Volt battery to generate output pulses that is discharged through the two adhesive electrode placed on the patient's skin for treatment and muscle training.

    The device is operated in such a way that turn on the intensity control knob and adjust the intended intensity or turn off the device during operation through the same control knob. While device is turned on for operation. User then follow the instruction for use to get appropriate stimulation treatment and/or training on the healthy muscles.

    AI/ML Overview

    This document describes the 510(k) premarket notification for the Everyway OTC EMS, Model EV-805, a powered muscle stimulator. The purpose of this submission is to demonstrate substantial equivalence to a predicate device (K102926: Gemore Muscle Conditioner/Model GM320PE).

    Here's an analysis of the provided information concerning acceptance criteria and supporting studies:

    1. Table of Acceptance Criteria and Reported Device Performance

    The core of the acceptance criteria for this device, as presented in the document, is demonstrating substantial equivalence to a predicate device. This is achieved through a comparison of key parameters, with "Substantial Equivalence (SE)" being the reported performance. The table below summarizes the comparison:

    ParameterAcceptance Criteria (Predicate Device)Reported Device Performance (Everyway OTC EMS, Model EV-805)Substantial Equivalency
    Product CodeNGXNGXIdentical
    Prescription (Rx) or OTCOTCOTCIdentical
    Indication for Use (IFU)Intended to stimulate healthy muscles in order to improve or facilitate muscle performance. May be considered a technique of muscle training. (Includes additional contraindications related to injured/ailing muscles).Intended to stimulate healthy muscles in order to improve or facilitate muscle performance. The various types of muscle work that Everyway OTC EMS can impose on the stimulated muscles are able to improve or facilitate muscle performance. Everyway OTC EMS may therefore be considered a technique of muscle training.SE*
    WaveformBiphasicBiphasicIdentical
    ShapeRectangularRectangularIdentical
    Maximum Output Voltage (volts) (+/-20%)7.5V @500Ω
    18.0V @2KΩ
    23V @10KΩ7.66V @500Ω
    8.2V @2KΩ
    8.2V @10KΩSE*
    Maximum Output Current (mA) (+/-20%)15.0mA @500Ω
    9.0mA @2KΩ
    2.3mA @10KΩ15.3mA @500Ω
    4.1mA @2KΩ
    0.82mA @10KΩSE*
    Duration of primary phase (usec)200-300us (single phase)210us (single phase)SE*
    Pulse Duration (usec)600us420usSE*
    Frequency (Hz) [or Rate (pps)]2~99Hz2~99HzIdentical
    For multiphasic waveforms only: Symmetrical phases?YesYesIdentical
    Maximum Charge (Microcoulombs per pulse)22.5uC15.75uCSE*
    Maximum Phase Charge (uC)22.5uC15.75uCSE*
    Maximum Current Density0.0716mA/cm20.0624mA/cm2SE*
    Maximum Average Current4.455 mA3.119mASE*
    Maximum Average Power Density2.685mW/cm22.34mW/cm2SE*
    Pulse per burstNo burst modeNo burst modeIdentical
    Burst Mode (i.e. pulse trains)No burst modeNo burst modeIdentical
    Burst durationNo burst modeNo burst modeIdentical
    Duty CycleNo burst modeNo burst modeIdentical
    On Time (Second)0s, 5s, 6s, All time0s, 5s, 6s, All timeIdentical
    Off Time (second)0s, 1s, 5s, 10s0s, 1s, 5s, 10sIdentical

    *SE = Substantially equivalent

    The document states that "through the detailed calculation comparison of stimulation output energy for each operation mode (in particular the output current density and power density), we found the output level in each operation mode for our OTC EMS, Model EV-805 and predicate device are very close and within the acceptable range. So we believe the difference in detailed output parameters does not affect the determination of substantial equivalence."

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

    The presented document does not describe a test set with a sample size in the context of clinical performance evaluation for this device. The submission relies entirely on non-clinical tests (compliance to standards) and a comparison to a predicate device to establish substantial equivalence.

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

    As there was no clinical performance test set, there were no experts used to establish ground truth in this context. The determination of substantial equivalence is based on engineering and performance criteria compared to the predicate through non-clinical testing.

    4. Adjudication Method for the Test Set

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

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

    No, an MRMC comparative effectiveness study was not done. The submission is focused on demonstrating substantial equivalence to a predicate device through non-clinical testing and comparison of technical specifications, not on evaluating the improvement of human readers with or without AI assistance.

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

    N/A. This device is a powered muscle stimulator, not an algorithm or AI system. Therefore, the concept of "standalone performance" for an algorithm doesn't apply. Its performance is evaluated based on its electrical output characteristics and compliance with safety standards.

    7. Type of Ground Truth Used

    The "ground truth" implicitly used for this submission is the established safety and effectiveness of the legally marketed predicate device (K102926), and compliance with recognized national and international safety standards. The assessment is that the new device's technical specifications and non-clinical test results are comparable or fall within acceptable limits of the predicate.

    8. Sample Size for the Training Set

    The document does not mention a training set. This type of device (powered muscle stimulator) typically does not involve machine learning algorithms or AI that would require a training set.

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

    Not applicable, as there was no training set.

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