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510(k) Data Aggregation

    K Number
    K090717
    Device Name
    FLEX-TENS
    Manufacturer
    Date Cleared
    2009-05-08

    (51 days)

    Product Code
    Regulation Number
    882.5890
    Reference & Predicate Devices
    N/A
    Why did this record match?
    Device Name :

    FLEX-TENS

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use
    Device Description
    AI/ML Overview
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    K Number
    K961141
    Manufacturer
    Date Cleared
    1996-05-10

    (50 days)

    Product Code
    Regulation Number
    882.1320
    Reference & Predicate Devices
    N/A
    Why did this record match?
    Device Name :

    EASY FLEX TENS/FES/MNS ELECTRODES 2 ROUND MODEL 8200/2X2 MODEL 8220

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

    Repositionable TENS and EMS Electrodes with RG-60 Series Gel

    Device Description

    Transcutaneous Electrical Nerve (TENS) and Muscle Stimulation (NMS/FES) electrodes

    AI/ML Overview

    Here's an analysis of the provided text regarding the acceptance criteria and study for the Uni-Patch Repositionable TENS and EMS Electrodes:

    Please note that the provided text is a 510(k) Premarket Notification Summary of Safety and Effectiveness from 1996. This type of document predates many of the standardized AI/ML study reporting requirements. As such, some of the requested information (especially regarding AI-specific details like MRMC or standalone algorithm performance, and detailed ground truth provenance for training sets) is not applicable or not present in this document, as the device described is not an AI/ML device but a medical electrode.


    Acceptance Criteria and Study for Uni-Patch Repositionable TENS and EMS Electrodes with RG-60 Series Gel

    The Uni-Patch electrodes are deemed safe and effective by demonstrating substantial equivalence to predicate devices (Medtronic, 3M, and LMI electrodes). The safety and effectiveness are established through specific criteria and testing.

    1. Table of Acceptance Criteria and Reported Device Performance

    Criteria CategorySpecific Acceptance CriteriaReported Device Performance
    SafetyNo skin irritation caused by the gel.The RG-60 Series gels used in these electrodes have passed the required skin sensitivity testing criteria as specified in the Tripartite Biocompatibility Guidance For Medical Devices. These tests include: - Cytotoxicity - Dermal Sensitization Study (Buehler Patch Test) - Repeat Insult Patch Test - Primary Skin Irritation Test. The gels have also been previously used in other cutaneous electrodes manufactured by Uni-Patch. Uni-Patch considers the gels acceptable for short-term skin contact.
    EffectivenessElectrode impedance values comparable to predicate devices when driven at 1k-Hz.When measuring the electrode impedance, driven at 1k-Hz, the electrode impedance values were determined to be comparable to all the tested predicate electrodes (Medtronic, 3M, and LMI TENS/EMS Electrodes).
    Substantial EquivalenceAs safe and effective as identified predicate devices (Medtronic, 3M, LMI electrodes).Based on the comparable impedance levels (effectiveness) and the successful skin sensitivity testing of the gel (safety), Uni-Patch considers its TENS and Muscle Stimulation electrodes to be as safe and effective as the Medtronic Comfort-Ease, 3M Myocare, and LMI TENS/EMS Electrodes, which were previously found substantially equivalent via 510(k) notifications.

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

    • Skin Irritation Tests: The document states that the RG-60 Series gels "have passed the required skin sensitivity testing criteria." It lists the types of tests (Cytotoxicity, Dermal Sensitization Study, Repeat Insult Patch Test, Primary Skin Irritation Test). However, the specific sample sizes for these tests are not disclosed in this summary.
    • Impedance Testing: The document states "we have determined that the electrode impedance values were comparable to all the electrodes tested." The sample size of electrodes tested for impedance (both Uni-Patch and predicate devices) is not disclosed.
    • Data Provenance: The document does not specify the country of origin for the data or whether the studies were retrospective or prospective. Given the nature of biocompatibility and electrical performance testing, these would typically be prospective laboratory and/or animal/human studies conducted to specific protocols.

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

    • Not Applicable in the context of this device. The "ground truth" for the skin irritation tests would be derived from standardized biological test results (e.g., cell viability in cytotoxicity, observed reactions in sensitization tests) as per the Tripartite Biocompatibility Guidance. The "ground truth" for impedance would be objective measurements from electrical test equipment. There is no mention of experts establishing ground truth in the way it's understood for diagnostic imaging or clinical outcomes.

    4. Adjudication Method for the Test Set

    • Not Applicable. Since the "ground truth" is based on objective biological and electrical measurements rather than subjective human assessment, there is no need for an adjudication method as would be used for image interpretation, for example.

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

    • No. This is not an AI/ML device designed for human interpretation assistance. Therefore, an MRMC study is not relevant to this submission.

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

    • No. This is not an AI/ML device. "Standalone performance" in this context would refer to the physical and electrical characteristics of the electrodes themselves, which were indeed tested (e.g., impedance, biocompatibility).

    7. The Type of Ground Truth Used

    • Biocompatibility Tests: The ground truth for safety (skin irritation) was established by standardized biological assays (Cytotoxicity, Dermal Sensitization, Repeat Insult Patch Test, Primary Skin Irritation Test) as outlined in the Tripartite Biocompatibility Guidance For Medical Devices. These tests have defined pass/fail criteria.
    • Impedance Tests: The ground truth for effectiveness (impedance) was objective electrical measurements (driven at 1k-Hz) compared against measurements from predicate devices.

    8. The Sample Size for the Training Set

    • Not Applicable in the context of this device. This device is not an AI/ML system that requires a "training set" in the computational sense. The product development and validation rely on engineering design, material science, and performance testing, not AI model training.

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

    • Not Applicable. As there is no "training set" for an AI/ML model, this question is not relevant to this device. The development and prior use of the RG-60 series gels in other Uni-Patch cutaneous electrodes could be thought of as a form of "prior experience" or "historical data" informing the current submission, but it's not a formal "training set" for an algorithm.
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