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510(k) Data Aggregation
(504 days)
Jiajian Self-Adhesive Electrode
The Self-adhesive electrode is intended to be used to transmit electrical stimulation current to the patient's skin. Example electrical stimulations for current applications of the electrodes are: TENS and EMS.
The Self-adhesive electrode, lead wire type and snap button type, are non-sterile flexible structures, composed of materials commonly used in this application: First layer: Non-woven fabric tape Second layer: Polyurethane (PU) electrically conductive carbon cloth (Hebei Kangshengda Electronic Technology Co., Ltd) Third layer: Biocompatible conductive hydrogel coupling media (ValueTrode Carbon, K970426), which has passed the required skin sensitivity testing criteria as specified in ISO 10993-10 and cytotoxicity testing criteria as specified in ISO ISO 10993-5. The electrodes are designed for single patient / multiple application use. It can be used for low-frequency or medium-frequency nerve or muscle stimulators, as the conduction film adhered to body skin. There are nine shapes of round, rectangle, elliptical, calabash, butterfly, saddle shape, rhombus, meniscus shape and palm shape. For the electrical connection, Jiajian provides lead wire type and snap button type: Lead wire assembly - at least 40mm long wire with 2mm/2.5mm diameter female socket. Snap button assembly - with 2.5~5mm diameter male socket. The lead wire assembly is in compliance with the requirements of FDA performance standard 21 CFR part 898 by testing under ANSI/AAMI ES60601-1, subclause 8.5.2.3.
The provided document is a 510(k) summary for the Jiajian Self-Adhesive Electrode, which is a medical device. This type of submission is for demonstrating substantial equivalence to a legally marketed predicate device, not for proving a device meets specific performance criteria through clinical studies in the same way a PMA (Premarket Approval) would require.
Therefore, many of the requested points, particularly those related to clinical studies, MRMC studies, training set details, or complex ground truth establishment, are not applicable to this type of regulatory submission (a 510(k)). The manufacturer's conclusion explicitly states: "Clinical data was not including in this submission."
Instead, the submission relies on bench testing and a comparison to an existing predicate device to demonstrate substantial equivalence, focusing on technical specifications, materials, and non-clinical performance.
Here's an analysis based on the available information:
1. Acceptance Criteria and Reported Device Performance (as demonstrated by testing and comparison):
The document doesn't present a formal table of "acceptance criteria" paired with "reported performance" in the way one might expect from a clinical study. Instead, it outlines the tests performed to show the device's adherence to relevant standards and its substantial equivalence to a predicate device. The implicit acceptance criterion is that the device performs as well as or similarly to the predicate device across key parameters and meets relevant safety standards.
Here's a table summarizing the relevant data points and how they compare to the predicate, as presented in the "Substantially Equivalent Comparison Conclusion" table:
Parameter | Acceptance Criteria (Implied / Predicate Value) | Reported New Device Performance (Wuxi Jiajian Self-Adhesive Electrode) | Remark |
---|---|---|---|
Indications for Use | Intended to be used to apply electrical stimulation current to the patient's skin (TENS and EMS). | Intended to be used to transmit electrical stimulation current to the patient's skin (TENS and EMS). | Same |
Target population | Single patient use and multiple application | Single patient use and multiple application | Same |
Type of use | OTC and Prescription use | OTC and Prescription use | Same |
Design (shapes) | Round, Rectangle, Oval, Gourd, Butterfly, Saddle (according to customized specification). | Round, Rectangle, Elliptical, Calabash, Butterfly, Saddle shape, Rhombus, Meniscus shape, Palm shape (according to customized specification). | Similar (More shapes) |
Design (connection) | Lead wire with female socket. | Lead wire with female socket, or snap button with male snap connector. | Similar (Additional) |
Materials | Non-woven fabric tape; Electrically conductive carbon cloth (ValueTrode Carbon, K970426); Biocompatible conductive hydrogel coupling media (Value Trode Carbon. K970426). | Non-woven fabric tape; Polyurethane (PU) electrically conductive carbon cloth (Hebei Kangshengda Electronic Technology Co., Ltd); Biocompatible conductive hydrogel coupling media (ValueTrode Carbon, K970426). | Similar |
Electrode Pad Size | Predicate range specified per shape (e.g., Round: Min.Ø20mm; Max.Ø80mm). | New Device range specified per shape (e.g., Round: Min.Ø20mm; Max.Ø85mm). | Similar (Slightly larger range for some shapes) |
Electrode Impedance | Predicate Round: 290~1000Ω | New Device Round: 302 | Similar (Within predicate range) |
Patient contact area | Predicate range specified per shape (e.g., Round: Min.3.14cm²; Max.50.24cm²). | New Device range specified per shape (e.g., Round: Min.3.14cm²; Max.56.716cm²). | Similar (Slightly larger range for some shapes) |
Max. Current Density | Predicate Round: 3.18mA/cm² (Ø20mm: 3.14cm²) | New Device Round: 3.18mA/cm² (Ø20mm: 3.14cm²). Other shapes also calculated, e.g., 0.24mA/cm² for 90x47mm). Max current density of all electrodes except round shapes does not exceed 2mA/cm² (IEC 60601-2-2). | Similar (Round matches, others are below the general limit) |
Hydrogel Thickness | 35mils ± 5mils (0.89mm ± 0.13mm) | 35mils ± 5mils (0.89mm ± 0.13mm) | Same |
Hydrogel pH | 4.2 ± 1.0 | 4.2 ± 1.0 | Same |
Hydrogel Volume Resistivity | 1500 ohm-cm max | 1500 ohm-cm max | Same |
Standards Met | ISO14971; ISO 13485; EN 980; ANSI/AAMI EC12; IEC 60601-1. | Lead wires test per 8.5.2.3 of AAMI/ANSI ES 60601-1; Impedance test, Conformability test and Fluid tolerance test per 201.15.101.6 and 201.15.101.7 of ANSI AAMI IEC 60601-2-2:2009; Impedance Test (Dispersion Test) per FDA's requirement; Peel strength test according to manufacturer's requirement; Shelf life test per ASTM F1980:2016; Reuse test per FDA's requirement. | Similar (New device tested to more specific relevant standards) |
Biocompatibility | ISO10993-5; ISO10993-10 | ISO10993-5; ISO10993-10 | Same |
Sterility Status | Non-sterile | Non-sterile | Same |
Electrical Safety | Lead wire meets IEC 60601-1 | Lead wire meets Clause 8.5.2.3 of AAMI/ANSI ES60601-1 | Same |
Other Performance | Good electrical conductivity, good adhesive property | Good electrical conductivity, good adhesive property | Same |
2. Sample size used for the test set and data provenance:
- Test Set Sample Size: For the bench tests (e.g., impedance, conformability, fluid tolerance, peel strength, shelf life, reuse), the document states: "All test samples were drawn from batches, with 3 samples for each specification."
- Data Provenance: The tests were conducted internally by Wuxi Jiajian Medical Instrument Co., Ltd. in China, as indicated by the submitter/manufacturer address. The data is retrospective, as it's part of a premarket submission.
3. Number of experts used to establish the ground truth for the test set and qualifications:
- This is Not Applicable (N/A). For a 510(k) submission based on bench testing and substantial equivalence, "ground truth" established by human experts (like radiologists for image analysis) is not relevant. Performance is measured against engineering specifications and industry standards.
4. Adjudication method for the test set:
- N/A. As there are no human experts establishing a "ground truth" for a medical imaging/AI dataset, no adjudication method is performed.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done:
- N/A. The document states "Clinical data was not including in this submission." MRMC studies apply to performance of diagnostic devices often involving human interpretation of results, which is not the case for this external electrode.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- N/A. This device is a passive electrode, not an algorithm or AI. Standalone performance refers to the accuracy of an AI algorithm.
7. The type of ground truth used:
- For the non-clinical tests, the "ground truth" or reference was based on engineering specifications, established industry standards (e.g., AAMI/ANSI ES 60601-1, IEC 60601-2-2), and the performance characteristics of the legally marketed predicate device (K090198). Essentially, the device's performance was compared against these defined benchmarks.
8. The sample size for the training set:
- N/A. This is not an AI/ML device requiring a training set.
9. How the ground truth for the training set was established:
- N/A. This is not an AI/ML device requiring a training set or its associated ground truth establishment.
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(147 days)
JIAJIAN SELF-ADHESIVE ELECTRODE
The self-adhesive electrode is intended to be used to apply electrical stimulation current to the patient's skin. Example electrical stimulations for current applications of the electrodes are: TENS (Transcutaneous Electrical Nerve Stimulation) EMS (Electrical Muscular Stimulation)
Jiajian branded Self-adhesive Electrodes, wire type, are non-sterile flexible structures, composed of materials commonly used in this application: First layer: Nonwoven fabric tape Second layer. Electrically conductive carbon cloth (ValueTrode® Carbon, K970426) Third layer: Biocompatible conductive hydrogel coupling media (ValueTrode GEL, K970426), which has passed the required skin sensitivity testing criteria as specified in ISO 10993-10 and cytotoxicity testing criteria as specifeid in ISO ISO 10993-5. The electrodes are designed for single patient / multiple application use. It can be used for low-frequency or medium-frequency nerve or muscle stimulators, as the conduction film adhered to body skin. There are six shapes of round, rectangle, oval, gourd, butterfly and saddle of the electrodes. For the electrical connection, Jianjian provides wire type: Lead wire assembly - at least 40mm long wire with 2.5mm diameter female socket, connected to one side of the wire. The lead wire assembly is in compliance with the requirements of FDA performance standard 21 CFR Part 898 by testing under IEC 60601-1. subclause 56.3(c).
This document is a 510(k) Premarket Notification for the Jiajian Self-adhesive Electrode. It's a submission to the FDA to demonstrate that the device is substantially equivalent to legally marketed predicate devices, not a study reporting on specific acceptance criteria and device performance in the way a clinical trial or detailed engineering report would.
Therefore, the requested information regarding acceptance criteria, device performance, sample sizes, ground truth, expert qualifications, adjudication methods, MRMC studies, or standalone algorithm performance cannot be directly extracted from this document, as this type of information is generally NOT part of a 510(k) summary for this class of device.
510(k) submissions for devices like a self-adhesive electrode typically focus on demonstrating substantial equivalence in terms of:
- Intended Use: The purpose of the device.
- Technological Characteristics: How the device works and its materials.
- Performance Data: This usually involves non-clinical bench testing (e.g., biocompatibility, electrical performance, adhesive strength) to show it meets recognized standards or performs similarly to the predicate. It does not typically involve extensive clinical trials or human-in-the-loop studies.
- Biocompatibility: Showing materials are safe for human contact.
Based on the provided text, here's what can be gathered, addressing the spirit of your request where possible, and noting what is not available:
1. Table of Acceptance Criteria and Reported Device Performance:
This document does not provide a table of quantitative acceptance criteria with corresponding performance data in the way you might expect from a detailed validation report. Instead, it relies on demonstrating compliance with recognized standards and similarity to predicate devices.
Acceptance Criteria (Implied by Standards/Predicate) | Reported Device Performance |
---|---|
Material Biocompatibility: | |
- Skin sensitivity testing criteria (ISO 10993-10) | - Biocompatible conductive hydrogel coupling media (ValueTrode GEL, K970426) passed the required skin sensitivity testing criteria as specified in ISO 10993-10 |
- Cytotoxicity testing criteria (ISO 10993-5) | - Biocompatible conductive hydrogel coupling media (ValueTrode GEL, K970426) passed the required cytotoxicity testing criteria as specified in ISO 10993-5 |
- Both (predicate and proposed) were established biocompatibility on standards of ISO 10993-5-1999: Tests for cytotoxicity: In vitro methods; ISO 10993-10: 2002: Tests for Irritation and Sensitization. |
| Electrical Lead Wire Conformity: | |
| - FDA performance standard 21 CFR Part 898 | - Lead wire assembly is in compliance with the requirements of FDA performance standard 21 CFR Part 898 by testing under IEC 60601-1. subclause 56.3(c). - Both predicate 2 and proposed device lead wires conform to FDA 21 CFR Part 898. |
| Electrical Current Distribution: | - Both (predicate 1 and proposed) electrodes distribute electrical current evenly. (This is a qualitative statement of similarity, not a measured performance against a specific criterion). |
| Impedance and Adhesive Testing: | - Predicate 2 and proposed device are safe and effective by impedance and adhesive testing. (This indicates that such testing was performed, but specific values or criteria are not detailed in this summary). |
| Intended Use: (Applying electrical stimulation current) | - The device is intended to be used to apply electrical stimulation current to the patient's skin. (Demonstrated through similarity to predicate devices with the same intended use). |
2. Sample Size Used for the Test Set and Data Provenance:
- Sample Size for Test Set: Not specified in this 510(k) summary. For devices of this nature, testing typically involves bench-top studies on a certain number of manufactured units rather than large clinical test sets with human subjects.
- Data Provenance: Not explicitly stated as "country of origin" for tests, but the manufacturer is Wuxi Jiajian Medical Instrument Co., Ltd in China. The testing itself is referenced against international standards (ISO, IEC) and FDA regulations. It is not specified if tests were retrospective or prospective, but typically bench testing would be considered prospective for the submission.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications:
- Experts and Qualifications: Not applicable/not specified in this type of 510(k) submission. "Ground truth" in the clinical imaging or diagnostic sense is not relevant for this device. The assessment is primarily based on engineering and biocompatibility testing against established standards.
4. Adjudication Method for the Test Set:
- Adjudication Method: Not applicable/not specified.
5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study was done:
- MRMC Study: No, this type of study is not relevant or reported for a self-adhesive electrode. An MRMC study is typically for evaluating diagnostic imaging devices or AI algorithms that assist human readers in interpretation.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Standalone Performance: Not applicable. This device is a passive electrode, not an algorithm.
7. The Type of Ground Truth Used:
- Ground Truth: For this device, "ground truth" equates to established international standards (ISO 10993, IEC 60601) and FDA regulations (21 CFR Part 898) for biocompatibility, electrical performance, and safety. The device's performance is measured against the requirements of these standards.
8. The Sample Size for the Training Set:
- Training Set Sample Size: Not applicable. This device is not an AI algorithm that requires a training set. The "design" or "development" of the product is distinct from machine learning training.
9. How the Ground Truth for the Training Set was Established:
- Training Set Ground Truth Establishment: Not applicable, as there is no training set for this device.
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