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510(k) Data Aggregation

    K Number
    K122393
    Date Cleared
    2013-12-10

    (490 days)

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

    TG-BODY, MI&Body, S-Trainer are intended to stimulate healthy muscles in order to improve or facilitate muscle performance and not intended to be used in conjunction with therapy or treatment of medical diseases or medical conditions of any kind.

    Device Description

    The MIGA Co.,Ltd OTC EMS System . model TG-Body. S-Trainer and Mi&Body are intended for use by healthy adults for the stimulation of healthy muscles in order to improve or facilitate muscle performance; it is not intended as a therapy for any medical condition. Basically the model TG-body, powered by 4.8V, S-Trainer, powered by 3.6V and Mi&Body, powered by 3.7V are muscle stimulation devices and identical to the predicate device -K011880 (Compex Sport) with the following features: It is a portable, battery operated neuromuscular electronic stimulation system. It contains 6 programs as similar to the predicate device; the output waveform is selectable pre-programming change among P1-P6 (in case of TG-body 10) The output strength is adjustable at 0-100mA via regulated voltage, with variable set time 5-60 minutes counting from starting session. The LCD display is provided for the indication of operation status including operation mode, output program mode, output intensity, time to cut-off, and battery low indication.

    AI/ML Overview

    This is an interesting case where the provided document is a 510(k) summary for a powered muscle stimulator, not an AI/ML device. Therefore, many of the requested categories (like sample size for test set, number of experts for ground truth, MRMC study, standalone performance, training set details) are not applicable.

    However, I can extract the acceptance criteria and the methods used to demonstrate the device meets those criteria, primarily through comparison to a predicate device and adherence to industry standards for medical electrical equipment.

    Here's an analysis based on the provided text, indicating where information is not applicable for a non-AI/ML medical device submission:

    Acceptance Criteria and Study Details

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria for "TG-BODY, MI&Body, S-Trainer" are implicitly defined by its substantial equivalence to the predicate device (K011880 Compex Sport Stimulator) and compliance with relevant safety and performance standards. The "performance" is demonstrated by showing that the new devices have comparable characteristics and meet the same standards.

    Feature/Criterion (Implicit Acceptance Criteria: Equivalent to Predicate or Standard)TG-BODY PerformanceMi&Body PerformanceS-Trainer PerformancePredicate Device (K011880 Compex Sport)
    Intended Use (Improve/facilitate muscle performance, not for medical conditions)Same as PredicateSame as PredicateSame as PredicateStimulate healthy muscles
    Technological CharacteristicsEquivalentEquivalentEquivalent-
    Performance PropertiesEquivalentEquivalentEquivalent-
    Power Source(s)4.8V3.7V3.6V7.2V
    Method of Line Current IsolationTransformers isolationTransformers isolationTransformers isolationTransformers isolation
    Patient Leakage Current - Normal Condition2uA2uA2uA2uA
    Patient Leakage Current - Single Fault Condition13uA13uA13uA15uA
    Number of Output Mode1111
    Number of Output Channels4214
    Synchronous or AlternatingSynchronousSynchronousSynchronousSynchronous
    Method of Channel IsolationGalvanicGalvanicGalvanicGalvanic
    Regulated Current or Regulated Voltage?500ohm RMS 26mA/13.0V, 2Kohm RMS 8.4mA/16.8V500ohm RMS 15mA/7.5V, 2Kohm RMS 4.0mA/8.1V500ohm RMS 15mA/7.5V, 2Kohm RMS 4.0mA/8.1V500ohm RMS 21mA/11.8V, 2Kohm RMS 7mA/16V
    Software/Firmware/Microprocessor ControlYesYesYesYes
    Automatic Overload TripYesYesYesYes
    Automatic No-Load TripYesYesYesYes
    Automatic Shut OffYesYesYesYes
    Patient Override ControlYesYesYesYes
    Indicator Display - On/Off StatusYesYesYesYes
    Indicator Display - Low Battery signalYesYesYesYes
    Indicator Display - Voltage/Current LevelNoNoNoNo
    Timer Range (Minutes)1 ~ 6020 ~ 3320 ~ 331 ~ 60
    Compliance with Voluntary StandardsEN 60601-1, -1-1, -1-2, -2-10EN 60601-1, -1-1, -1-2, -2-10EN 60601-1, -1-1, -1-2, -2-10EN 60601-1, -1-1, -1-2, -2-10
    Compliance with 21 CFR 898?YesYesYesYes
    Weight360g120g70g350g
    Dimensions(WHD)10616238.5(mm)64.8103.626(mm)515114(mm)1429936(mm)
    Housing Materials and ConstructionABSABSABSPlastic case
    Name of the output ModeSquare waveSquare waveSquare waveSquare wave
    Clearly labeled amplitude and times axes0~3000~3000~3000~300
    Identification of the amplitude baseline----
    List of all output parameter setting the load resistance----
    WaveformSymmetrical biphasic squareSymmetrical biphasic squareSymmetrical biphasic squareSymmetrical biphasic square
    ShapeRectangularRectangularRectangularRectangular
    Maximum output Voltage100V peak40V peak40V peak100V peak
    Maximum output Current26mA14.4mA13.3mA21mA
    Pulse Width50 ~300150-300150~300200 ~ 400
    Frequency(Hz)4 ~1004~1004~1001 ~ 120
    Beat Frequency(Hz)----
    For multiphasic waveforms only----
    Symmetrical phasesYesYesYesYes
    Phase duration(include units)1 - 0.0050.25 ~ 0.010.25 ~ 0.010.1 - 0.001
    Net charge(mC per pulse)0000
    Maximum Phase charge Density(uC)36242418
    Maximum Current Density(mA/cm2)1.04320.205710.264739.6
    Maximum Power Density(W/cm2)0.062590.010590.008230.046
    Burst mode----
    ON time(seconds)101010-
    OFF time(seconds)101010-

    2. Sample size used for the test set and the data provenance

    This is not an AI/ML device and therefore does not have a "test set" in the context of machine learning. The "testing" involved bench testing to verify performance specifications and compliance with standards. The document does not specify the number of units tested.

    • Data Provenance: Not applicable for this type of device submission. The device is manufactured by Miga Medical Co., Ltd in Korea.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    Not applicable. This device does not rely on interpretation of medical data or images requiring expert ground truth.

    4. Adjudication method for the test set

    Not applicable. There is no "test set" or human interpretation requiring adjudication.

    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. This is not an AI/ML device, nor does it involve human readers or image interpretation.

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

    Not applicable. This is not an AI/ML algorithm.

    7. The type of ground truth used

    Not applicable. The "ground truth" for this device's performance is objective measurement against engineering specifications and compliance with recognized safety and performance standards (e.g., EN 60601 series).

    8. The sample size for the training set

    Not applicable. This is not an AI/ML device and therefore does not have a "training set."

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

    Not applicable. This is not an AI/ML device.


    Summary of the Study Proving Acceptance Criteria:

    The study proving the device meets its acceptance criteria is based on:

    • Substantial Equivalence Comparison: A detailed comparison table ([1], [2]) demonstrates that the new devices (TG-BODY, MI&Body, S-Trainer) have equivalent intended use, technological characteristics, and performance properties to the predicate device (K011880 Compex Sport stimulator). While some specific values (like maximum current, voltage, and pulse width) differ, these differences are presented within the context of demonstrating overall equivalence for safety and effectiveness for the stated intended use.
    • Compliance with Consensus Standards: The devices meet consensus standards EN 60601-1 (general requirements for basic safety and essential performance), EN 60601-2-10 (particular requirements for nerve and muscle stimulators), EN 60601-1-2 (electromagnetic compatibility), and 21 CFR 898 (reports of adverse events). This is a critical component for demonstrating safety and performance.
    • Bench Testing: The summary explicitly states, "Bench testing was also conducted to demonstrate performance specifications." This indicates physical testing was performed on the devices to verify that their measured characteristics (e.g., output parameters, timing, safety features) matched their design specifications and were consistent with the comparison to the predicate device.

    Conclusion:

    The manufacturer concluded that the TG-BODY, MI&Body, and S-Trainer devices are safe and effective and substantially equivalent to the predicate device based on the information provided in the premarket notification, including the comparison table, adherence to recognized standards, and bench testing results. The FDA's letter (K122393) confirms this determination of substantial equivalence.

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