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510(k) Data Aggregation

    K Number
    K171396
    Device Name
    ODFS Pace XL
    Date Cleared
    2018-01-31

    (265 days)

    Product Code
    Regulation Number
    882.5810
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    ODFS Pace XL

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

    The ODFS® Pace XL is intended to provide ankle dorsiflexion in individuals who have a dropped foot as a consequence of upper motor neuron injury. By detecting the swing phase of gait through a foot switch signal, appropriate electrical stimulation of the leg and ankle muscles may improve gait by flexing the foot of persons who have lost or impaired function. There may be additional benefits from FES such as muscle re-education, prevention/retardation of disuse atrophy, increased or maintained range of joint motion and increase in local blood flow.

    The ODFS® Pace XL is a medical device and should only be used under medical supervision for the treatment of dropped foot following an upper motor neuron injury.

    Device Description

    The ODFS® Pace XL is an external functional neuromuscular stimulator. It consists of a small, body worn, battery powered, single channel stimulator which is triggered by a footswitch worn in the shoe. The footswitch options are:

    1. Shoe insole incorporating wireless transceiver which provides wireless triggering
    2. 'Out of shoe' wireless transceiver with 'in shoe' heel switch. Provides wireless triggering.
    3. Wired 'in shoe' heel switch for where 1 & 2 are not appropriate or to cover an emergency, e.g. loss of battery power in wireless accessory.

    The triggering element and detection is the same across all options and option 3 is common to the ODFS® Pace (predicate device).

    Electrical pulses are generated by the device in order to stimulate muscle contractions in the lower limb. (Neuromuscular stimulation) Triggering with a footswitch permits the stimulation to be varied according to the gait of the user. Stimulation produces contraction of the appropriate muscles to cause dorsiflexion of the ankle in individuals who have impaired or absent ability to pick up their foot during walking as a result of a neurological injury. This paralysis affecting the foot is commonly known as 'drop foot' or 'dropped foot'.

    The electrical stimulation is delivered via self adhesive skin surface electrodes. The electrodes may be flexibly placed according to the optimum response of the patient but typically are located over the common peroneal nerve as it passes near the head of the fibula. The user may be offered the below knee ODFS® Leg Cuff accessory as aid to locating electrodes repeatedly day to day. An additional option is to mount the ODFS® Pace XL upon the ODFS® Leg Cuff.

    For individuals presenting with weakness and/or spasticity a muscle stimulation exercise program can be delivered by the ODFS® Pace XL. In this case the footswitch trigger is not used and the ODFS® Pace functions as a powered muscle stimulator. A clinician would determine the need for this application which can be enabled from a setup option in the ODFS® Pace XL. (Default is to have the exercise disabled)

    AI/ML Overview

    The Odstock Medical Ltd ODFS® Pace XL device is a functional neuromuscular stimulator. The acceptance criteria and the study that proves the device meets the acceptance criteria are described below.

    1. Table of acceptance criteria and the reported device performance:

    The provided document K171396 is a 510(k) premarket notification of intent to market the ODFS® Pace XL. This submission does not define specific "acceptance criteria" in the sense of predefined numerical targets that the device must achieve in a clinical trial. Instead, the submission demonstrates "substantial equivalence" to legally marketed predicate devices by showing that the ODFS® Pace XL has the same intended use and similar technological characteristics, and that any differences do not raise new questions of safety and effectiveness.

    The "performance data" provided focuses on the electrical output specifications of the device and its compliance with recognized standards. The comparison is primarily against the ODFS® Pace (K102115) and ODFS® III v6.2 (K050991) predicate devices.

    Feature / Acceptance CriteriaODFS® Pace XL Reported PerformancePredicate Device (ODFS® Pace) PerformancePredicate Device (ODFS® III v6.2) Performance
    Intended UseSame as predicateSame as predicatePrimary predicate
    WaveformBiphasic (symmetrical and balanced asymmetrical)Biphasic (symmetrical and balanced asymmetrical)Biphasic (symmetrical and balanced asymmetrical)
    Pulsewidth0 - 360 microseconds (±10%)0 - 360 microseconds (±10%)7 - 365 microseconds (±10%)
    FrequencyDefault 40Hz, 20-60Hz in 5Hz stepsDefault 40Hz, 20-60Hz in 5Hz steps40Hz ± 10%
    Max Output Voltage86-140V peak (dependent on resistance)85-150V peak (dependent on resistance)(Not explicitly stated in comparable format)
    Max Output Current172mA @ 500R, 62mA @ 2K, 14mA @ 10K170mA @ 500R, 65mA @ 2K, 15mA @ 10K(Not explicitly stated in comparable format)
    Patient Leakage Current (
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    K Number
    K102115
    Device Name
    ODFS PACE
    Date Cleared
    2011-03-30

    (245 days)

    Product Code
    Regulation Number
    882.5810
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    ODFS PACE

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

    The ODFS® Pace is intended to provide ankle dorsiflexion in individuals who have a dropped foot as a consequence of upper motor neuron injury. By detecting the swing phase of gait through a foot switch signal, appropriate electrical stimulation of the leg and ankle muscles may improve gait by flexing the foot of persons who have lost or impaired function. There may be additional benefits from FES such as muscle re-education, prevention/retardation of disuse atrophy, increased or maintained range of joint motion and increase in local blood flow.

    The ODFS® Pace is a medical device and should only be used under medical supervision for the treatment of dropped foot following an upper motor neuron injury.

    Device Description

    The ODFS® Pace is an external functional neuromuscular stimulator. It consists of a small, body worn, single channel stimulator which is triggered by a wired footswitch worn in the shoe. Electrical pulses are generated by the device in order to stimulate muscles in the lower limb. Triggering with a footswitch permits the stimulation to be varied according to the gait of the user. Stimulation produces contraction of the appropriate muscles to cause dorsiflexion of the ankle in individuals who have impaired or absent ability to pick up their foot during walking as a result of a neurological injury. This partial paralysis affecting the foot is commonly known as 'drop foot' or 'dropped foot'.

    The electrical stimulation is delivered via self adhesive skin surface electrodes. The electrodes may be flexibly placed according to the optimum response of the patient but typically are located over the common peroneal nerve as it passes near the head of the fibula.

    For individuals presenting with weakness and/or spasticity a muscle stimulation exercise program can be delivered by the ODFS® Pace. In this case the footswitch trigger is not used and the ODFS® Pace functions as a powered muscle stimulator. A clinician would determine the need for this application which can enabled from a setup option in the ODFS® Pace. (Default is to have the exercise disabled)

    AI/ML Overview

    The provided text describes a 510(k) submission for the ODFS® Pace, an external functional neuromuscular stimulator. The focus of the submission is to demonstrate substantial equivalence to predicate devices, rather than establishing acceptance criteria based on studies and then proving the device meets those criteria.

    Therefore, many of the requested details about acceptance criteria, study design, expert ground truth, and comparative effectiveness are not applicable or available within this type of regulatory document. This document primarily focuses on technical specifications and regulatory compliance.

    Here's the information that can be extracted or deduced, along with explanations for the missing information:

    1. A table of acceptance criteria and the reported device performance:

    The document does not explicitly state "acceptance criteria" in the way a clinical study or performance study would. Instead, it demonstrates compliance with technical specifications and relevant standards. The "device performance" in this context refers to its ability to meet these technical specifications and legal requirements.

    Acceptance Criteria (Implied)Reported Device Performance
    Functional and output specifications metProduction units pass functional testing of stimulator controls, settings and indicators, stimulus output and timing, footswitch operation, and power consumption. Parameters measured under conditions specified in FDA Guidance Document for Powered Muscle Stimulator 510(k)s.
    Compliance with ISO 60601-1-1:2006 (Basic Safety & Essential Performance)Passed applicable requirements
    Compliance with ISO 60601-1-2:2007 (EMC)Passed applicable requirements
    Compliance with ISO 60601-2-10:2001 (Safety of Nerve & Muscle Stimulators)Passed applicable requirements
    Substantial equivalence to predicate devices for FES indicationsODFS® Pace has identical indications for use as an FES device as ODFS III v6.2 and corresponds to FES functions of EMPI Focus Model 795.
    Substantial equivalence to predicate devices for NMS/NMES indicationsThe exercise function of ODFS® Pace corresponds to and is substantially equivalent to the NMS/NMES indications of the EMPI Focus Model 795.

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):

    • Sample Size for Test Set: Not applicable. This document describes a 510(k) submission, which relies on demonstrating substantial equivalence to existing devices and technical performance testing, not a clinical trial with a "test set" of patients in the way an AI/diagnostic device might have. The "production units" mentioned for functional testing don't represent a patient-based test set.
    • Data Provenance: Not applicable for a typical clinical test set. The technical testing was conducted by Odstock Medical Ltd., which is based in the United Kingdom.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience):

    Not applicable. No "ground truth" established by experts for a test set of patient data is mentioned or required for this type of 510(k) submission for a physical medical device like an FES stimulator. The "truth" is established by compliance with engineering specifications and recognized electrical safety standards.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

    Not applicable. As there is no clinical "test set" of patient cases requiring ground truth establishment, no adjudication method is relevant.

    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. The ODFS® Pace is an external functional neuromuscular stimulator, not an AI-powered diagnostic or decision support system that would involve "human readers" or AI assistance in interpretation. It directly delivers electrical stimulation.

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

    Not applicable. This device is a hardware stimulator and does not describe a standalone "algorithm" in the context of AI or image analysis. Its function is directly related to hardware performance and user-controlled settings.

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

    The "ground truth" in this context is primarily defined by the technical specifications for electrical output, waveform properties, frequency, pulse width, and compliance with international safety and performance standards (ISO 60601 series). There is no "patient ground truth" required for this type of submission.

    8. The sample size for the training set:

    Not applicable. This device does not use machine learning or AI that would require a "training set" of data.

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

    Not applicable, as there is no training set.

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