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510(k) Data Aggregation
(110 days)
Therapeutic Ultrasound:
- Pain relief
- Reduction of muscle spasm
- Localized increase of blood flow
- Increase range of motion of contracted joints using heat and stretch techniques
Neuromuscular Stimulation:
- Symptomatic relief of chronic intractable pain, acute post traumatic pain or acute surgical pain
- Temporary relaxation of muscle spasm
- Prevention of post-surgical phlebo-thrombosis through immediate stimulation of calf muscles
- Increase of blood flow in the treatment area.
- Prevention or retardation of disuse atrophy in post-injury type conditions
- Muscle re-education
- Maintaining or increasing range of motion
Therapeutic Massager:
- Relieves muscle spasms
- Provides temporary relief of minor muscle aches and pains
- Temporarily improves local blood circulation
- Temporarily reduces the appearance of cellulite
The TNN-DU810 Non-Invasive Subdermal Therapy System is comprised of the following main components:
A system console including software and control electrodes;
A control and display panel: .
Device accessories including muscle stimulator electrodes (ME2221, Mettler Corp., K#013192) and cables, ultrasound transducers (applicators) (ME7513, Mettler Corp.) acoustic gel (Sonigel, Mettler Corp), and cables. The electrodes. ultrasound transducers and acoustic gel have all been cleared under the Mettler Electronics Corp. 510(k). Also included is a Dermosonic vacuum treatment roller head, cleared under the Dermosonic device. K024307.
The TNN-DU810 device has dual frequencies ultrasound therapy, muscle stimulator systems and therapeutic vacuum massager.
The user friendly interface comprises keyboard, touch screen and audio feedback. The screen provides operator information about operation mode and signal intersities. Large control knobs on the touch screen make adjusting power for ultrasound and muscle stimulation.
The system consists of the Alfatech DU857 device (K#052340) and the Dermosonic Therapeutic Vacuum Applicator, a component cleared in the Dermosonic K#024307 ..
The frequency Ultrasound Therapy, Muscle Stimulator System is identical to the DU857. It is important to note that there is no electric connection between the ultrasound therapy, muscle stimulator system and the therapeutic vacuum massager.
Each of the two components of the system (ultrasound plus neuromuscular stimulation) and the therapeutic massager function independently and have no connection between them.
Here's an analysis of the provided text regarding the acceptance criteria and study for the TNN-DU810 Non-Invasive Subdermal Therapy System:
Summary of Device Performance and Acceptance Criteria:
The provided document is a 510(k) summary for a medical device. In this context, "acceptance criteria" and "device performance" are typically demonstrated by showing substantial equivalence to a legally marketed predicate device, rather than explicit quantitative performance metrics against pre-defined thresholds. The device aims to achieve similar functionality and safety as the predicate devices.
The "acceptance criteria" can be inferred from the comparison table (Table 1) and the overall conclusion of substantial equivalence. The device is 'accepted' if it can demonstrate equivalent characteristics and performance to the predicate device.
1. Table of Acceptance Criteria and Reported Device Performance:
| Item for Comparison | Acceptance Criteria (Predicate Device) | Reported Device Performance (TNN-DU810) |
|---|---|---|
| Intended Use | Therapeutic vacuum Massager and Ultrasonic Diathermy, including: temporarily improvement local blood circulation and temporarily reduction the appearance of cellulite. | Therapeutic vacuum Massager, Ultrasonic Diathermy and neuromuscular stimulation, including: temporarily improvement local blood circulation and temporarily reduction the appearance of cellulite. (Note: Added neuromuscular stimulation to intended use compared to Predicate 2) |
| Design | 1 model, 1 ultrasound applicators, 3 vacuum treatment roller head | 1 model, 2 ultrasound applicators, 4 conductive electrodes, 1 vacuum treatment roller head |
| Specifications | Not specified | Ground current leakage <40 micamp. |
| Performance (User Interface) | Use friendly interface, easy to operate | Use friendly interface, easy to operate |
| Frequency | 1 MHz±3%, 3 MHz±3% | 1 MHz±5%, 3 MHz±5% (Note: Slightly wider tolerance than Predicate 2) |
| Modes (Ultrasound) | Continuous, Pulsed - 5% duty cycle, Pulsed - 10% duty cycle, Pulsed - 20% duty cycle | Continuous (Note: Fewer pulsed modes than Predicate 2) |
| Maximum Intensity | 2 W/cm² | 1.5 W/cm² (Note: Lower maximum intensity than Predicate 2) |
| Maximum Treatment Time | 30 minutes - ultrasound therapy, 99 minutes - suction treatment | 30 minutes - ultrasound, 30 minutes - electrical stimulation, 40 minutes - suction treatment (Note: Added electrical stimulation time, shorter suction time than Predicate 2) |
| Classification | Protective Class I Equipment | Protective Class I Equipment |
| Type of Applied Part | BF type | BF type |
| Vacuum Treatment Mode | Continuous or pulsed | Continuous or pulsed |
| Depression Level | Pulse mode -820 mbar maximum, continuous mode- 125-210mbar | Pulse mode -820 mbar maximum, continuous mode- 125-210mbar |
| Vacuum Treatment Roller Head | 61.452 - Dermasonic | 61.452 - Dermasonic |
| Component Independence | Each of the two components of the system (ultrasound) and the Therapeutic Massager function independently and have no connection between them. | Each of the two components of the system (ultrasound + Neuromuscular Stimulation) and the Therapeutic Massager function independently and have no connection between them. (Note: Added Neuromuscular Stimulation to independent components) |
| Relaxation Time | 0.36, 0.72, 1.08 or 1.44 sec | 0.36, 0.72, 1.08 or 1.44 sec |
| Suction Time | 0.36, 0.72, 1.08, 1.44, 1.80. 2.16, 2.52, 2.88 or 3.24 sec | 0.36, 0.72, 1.08, 1.44, 1.80. 2.16, 2.52, 2.88 or 3.24 sec |
| Vacuum Pressure | Ranges from 55 to 820 Mbar (20 distinct values) | Ranges from 55 to 820 Mbar (20 distinct values) |
| Air Flow | 3500 l/hour | 3500 l/hour |
| Treatment Time - Therapeutic Vacuum Massager | 1 to 99 minutes | 1 to 99 minutes |
Rationale for "Acceptance": The document concludes that the TNN-DU810 device is "substantially equivalent" to the predicate device (K#024307) in design and function, particularly noting the use of the predicate's rollers and vacuum suction components to achieve increased blood flow and temporarily reduce the appearance of cellulite. The FDA accepted this submission (K063728) based on this demonstration of substantial equivalence.
2. Sample Size Used for the Test Set and Data Provenance:
- Sample Size for Test Set: Not applicable in the context of this 510(k) submission. This is a premarket notification based on substantial equivalence, not a clinical trial with a defined test set of patients or images. The "test set" here refers to the performance characteristics compared with the predicate device.
- Data Provenance: Not applicable. The "data" consists of the device's technical specifications and a comparison to predicate devices, along with non-clinical testing results. There is no mention of patient data, clinical images, or country of origin for such data.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:
- Number of Experts: Not applicable. This submission does not involve expert-established ground truth for a clinical test set.
- Qualifications of Experts: N/A.
4. Adjudication Method for the Test Set:
- Adjudication Method: Not applicable. There was no clinical test set requiring adjudication.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done:
- MRMC Study: No. The document explicitly states "Discussion of Clinical Tests Performed: Not Applicable." This device's clearance was based on substantial equivalence to predicate devices and non-clinical performance testing, not a comparative effectiveness study involving human readers or AI assistance.
- Effect Size of AI Improvement: Not applicable.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- Standalone Performance: Not applicable. This device is a physical therapy system, not an AI algorithm.
7. The Type of Ground Truth Used:
- Type of Ground Truth: Not applicable. In the context of a 510(k) for substantial equivalence, the "ground truth" is typically the established safety and effectiveness of the legally marketed predicate devices, as demonstrated through their own prior clearances and regulatory compliance. For the TNN-DU810, the "ground truth" for its performance claims (e.g., vacuum pressure, frequency) would be verified through non-clinical laboratory testing against its own specifications, which are compared to the predicate's specifications.
8. The Sample Size for the Training Set:
- Sample Size for Training Set: Not applicable. This device does not involve machine learning algorithms that require a training set.
9. How the Ground Truth for the Training Set was Established:
- Ground Truth for Training Set: Not applicable.
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