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510(k) Data Aggregation

    K Number
    K210877
    Manufacturer
    Date Cleared
    2021-07-19

    (117 days)

    Product Code
    Regulation Number
    878.4400
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Evolve System with the T3 Applicator employs RF technology or EMS-TENS technology for the treatment of selected medical conditions.

    The T3 Applicator in RF mode is intended for the temporary relief of minor muscle aches and pain, temporary relief of muscle spasm, and temporary improvement of local blood circulation.

    The T3 Applicator in EMS mode is intended for:

    • Relaxation of muscle spasms
    • Prevention or retardation of disuse atrophy
    • Increasing local blood circulation
    • Muscle re-education
    • Maintaining or increasing range of motion
    • Immediate post surgical stimulation of calf muscles to prevent venous thrombosis

    The T3 Applicator in TENS mode is intended for:

    • Symptomatic relief and management of chronic, intractable pain
    • Post-surgical acute pain
    • Post-trauma acute pain

    The RF treatment mode and EMS/TENS mode should not be used in combination or sequentially.

    Device Description

    The Evolve System with the T3 Applicator is designed to deliver non-thermal RF energy and electro-muscle and transcutaneous nerve stimulation for the treatment of different body areas for various medical applications. The Evolve System software controls and regulate the different applied energies in accordance with the user system preprograming and treatment settings. The subject device platform system is identical to the FDA-Cleared Evolve System platform (a.k.a EmBody System and the subject of K183450). The same platform system was recently FDA-Cleared for the use with the Tone Applicator (subject of K201285).

    The Evolve System supports the placement of the following components:

    • LCD display touch screen,
    • Audio loudspeaker,
    • 48V AC/DC power supply,
    • Real time controller, distributor card and 2 RF generators,
    • Fans

    The System operates while connected to the T3 Applicator.

    AI/ML Overview

    The Evolve System with the T3 Applicator is intended for temporary relief of minor muscle aches and pain, muscle spasm, and improved local blood circulation (RF mode), as well as relaxation of muscle spasms, prevention of disuse atrophy, increased local blood circulation, muscle re-education, maintaining/increasing range of motion, and immediate post-surgical stimulation of calf muscles to prevent venous thrombosis (EMS mode), and symptomatic relief of chronic, intractable, post-surgical, and post-trauma acute pain (TENS mode).

    Here's an analysis of the acceptance criteria and the study that proves the device meets them:

    1. Table of Acceptance Criteria and Reported Device Performance:

    CharacteristicAcceptance Criteria (Subject Device, EVOLVE System with T3 Applicator)Reported Device Performance (as per document)
    RF Mode
    Maximal Output Power75 W75 W
    Frequency1 MHz1 MHz
    Pulse Duration2 sec2 sec
    EMS Mode
    WaveformSymmetrical BiphasicSymmetrical Biphasic Waveform
    Pulse ShapeRectangularRectangular
    Max Output VoltageUp to 50 intensity level (=54 Vpeak)Up to 50 intensity level (=54 Vpeak)
    Pulse Width20 to 400 µs20 to 400 µs
    Frequency3 to 200 Hz3 to 200 Hz
    Net Charge @ 500Ω0 µC/pulse @ 500Ω0 µC/pulse @ 500Ω
    Max Phase Charge24 µC @ 500Ω24 µC @ 500Ω
    Max Current Density0.74 mA/cm²0.74 mA/cm² (Surface = 6.46cm²)
    Max Power Density22.2 mW/cm² @500Ω22.2 mW/cm² @500Ω
    Burst ModeYes: a. 3-200, b. 1, c. 1-60 sec, d. Time on / offYes: a. 3-200, b. 1, c. 1-60 sec, d. Time on / off
    On Time1 - 60 sec1 - 60 sec
    Off Time1 - 60 sec1 - 60 sec
    Treatment TimeUp to 60 min.Up to 60 min.
    TENS Mode
    WaveformSymmetrical BiphasicSymmetrical Biphasic Waveform
    Pulse ShapeRectangularRectangular
    Max Output VoltageUp to 15 intensity level (=19 Vpeak)Up to 15 intensity level (=19 Vpeak)
    Pulse Width20 to 400 µs20 to 400 µs
    Frequency3 to 200 Hz3 to 200 Hz
    Net Charge @ 500Ω0 µC/pulse @ 500Ω0 µC/pulse @ 500Ω
    Max Phase Charge15.2 µC @ 500Ω15.2 µC @ 500Ω
    Max Current Density0.47 mA/cm²0.47 mA/cm² (Surface = 6.46cm²)
    Max Power Density8.9 mW/cm² @500Ω8.9 mW/cm² @500Ω
    Burst ModeYes: a. 3-200, b. 1, c. 1-60 sec, d. Time on / offYes: a. 3-200, b. 1, c. 1-60 sec, d. Time on / off
    On Time1 - 60 sec1 - 60 sec
    Off Time1 - 60 sec1 - 60 sec
    Treatment TimeUp to 60 min.Up to 60 min.
    General Safety/Design
    BiocompatibilityMaterials are biocompatibleMaterials are biocompatible
    Complies with standardsANSI AAMI ES 60601-1, IEC 60601-1-2, IEC 60601-2-10, IEC 60601-1-6, IEC 60601-2-2Yes, tested and complies with listed standards
    Software ValidationYesYes
    Electrical/Mechanical SafetyYes (IEC 60601-1)Yes (IEC 60601-1)
    Electromagnetic CompatibilityYes (IEC 60601-1-2)Yes (IEC 60601-1-2)
    Nerve/Muscle Stimulator SafetyYes (IEC 60601-2-10)Yes (IEC 60601-2-10)
    High-Frequency Surgical Equip. SafetyYes (IES 60601-2-2)Yes (IES 60601-2-2)

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

    The document states that Non-Clinical (Bench) Performance Data was conducted to demonstrate the device performs as expected and meets design requirements. This included various bench tests (e.g., accuracy of RF output, electrode temperature sensors, thermal build-up, ex-vivo tissue thermal profile, safety and thermal profile testing, EMS/TENS output specifications).

    However, the document explicitly states "Clinical Performance Data: Non-Applicable." This implies that there was no clinical test set using human subjects or patient data. The evaluation for substantial equivalence relies on non-clinical bench testing and comparison to predicate devices, rather than a clinical study with a test set of patient data. Therefore, questions regarding sample size, data provenance (e.g., country of origin, retrospective/prospective) for a clinical test set are not applicable here.

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

    Since no clinical test set was conducted, the concept of "ground truth" derived from expert consensus on patient data (e.g., from radiologists, pathologists) is not applicable to this submission. The "ground truth" for the non-clinical bench tests would be the established engineering and safety standards and design specifications against which the device's performance was measured.

    4. Adjudication Method for the Test Set:

    Not applicable, as no clinical test set was conducted.

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

    No, an MRMC comparative effectiveness study was not done. The submission explicitly states "Clinical Performance Data: Non-Applicable," making any evaluation of human reader improvement with or without AI assistance irrelevant in this context. The device is a physical therapeutic system, not an AI-assisted diagnostic tool.

    6. Standalone (Algorithm Only) Performance Study:

    Not applicable. This device is a physical therapeutic system, not an algorithm or AI. Its performance is tied directly to its hardware functionality and energy delivery.

    7. Type of Ground Truth Used:

    For the non-clinical performance data, the "ground truth" was based on:

    • Engineering and Design Requirements: The device was tested to verify that its performance meets its own design requirements.
    • Consensus Standards: The device's performance was evaluated against recognized consensus standards for medical electrical equipment, such as ANSI AAMI ES 60601-1, IEC 60601-1-2, IEC 60601-2-10, IEC 60601-1-6, and IEC 60601-2-2.
    • Predicate Device Specifications: The device's technical specifications and performance characteristics were compared directly to those of legally marketed predicate devices to establish substantial equivalence.

    8. Sample Size for the Training Set:

    Not applicable. This device is not an AI/ML algorithm that requires a training set. Its functionality is based on established physical principles of RF and EMS/TENS technology.

    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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