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510(k) Data Aggregation
(345 days)
TONE-A-MATIC
Tone-A-Matic is indicated to be used for
- · Russian and EMS for:
- o Relaxation of muscle spasms
- Prevention or retardation of disuse atrophy o
- Increase local blood circulation o
- Muscle re-education o
- Maintaining or increasing range of motion o
- Immediate postsurgical stimulation of calf muscles to prevent venous 0 thrombosis.
- TENS for: ●
- Symptomatic relief of chronic, intractable pain. o
- o Management of pain associated with post-traumatic or post-operative conditions.
The Tone-A-Matic is a Tone-A-Matic Device is Non-TRANSIT-OPERABLE and PORTABLE micro-controller operated device not to be Worn by patient. It generates electrical impulses and effectively transfers your desired choice of these pre-programmed electrical impulses directly through the electrode adhesive pads to the suggested area of the body where the electrodes are placed. Tone-A-Matic was developed based on physics, electro biology and modern micro-electronic technology. You will be more than pleased with this state-of-the-art device.
The Tone-A-Matic is very user friendly with a large liguid crystal display (LCD) screen that displays the treatment mode in use, a countdown timer and battery indicator. The intensity of the treatment can be increased or decreased by Keypads. User can set the time of the treatment from available choice of 1 min. to 60 min.
It is a clinical model with easy user interface and versatility to treat different body areas simultaneously. This aesthetically designed clinical model has 3 selectable modes(Russian, TENS, EMS) and treatment parameters. The state of the art Tone-A-Matic is light weight (1.78 Kg), small in size (10.3" X 7.5" X 3.5", LxWxH) and battery powered which allows it to be easily moved to any location for immediate use.
Here's an analysis of the provided text regarding the Acceptance Criteria and Study to prove the device's adherence:
Based on the provided 510(k) Summary for the Tone-A-Matic device, there is a fundamental misunderstanding in your request. A 510(k) submission for this type of device (Powered Muscle Stimulator / TENS) does not typically involve the kind of acceptance criteria, clinical studies with ground truth established by experts, or MRMC comparative effectiveness studies that you are asking about.
This document is a Premarket Notification (510(k)), which demonstrates "substantial equivalence" to a legally marketed predicate device, not necessarily proof of meeting performance acceptance criteria from a clinical study in the way you've outlined for an AI/CAD-type device.
Therefore, I cannot fill out your requested table and information points as they pertain to a different type of medical device evaluation. Instead, I will describe the approach used in this 510(k) submission to demonstrate equivalence, which relies heavily on non-clinical tests and direct comparison of technical specifications and intended use.
Explanation of TONE-A-MATIC 510(k) Submission Approach
The Tone-A-Matic device is a Powered Muscle Stimulator and Transcutaneous Electrical Nerve Stimulator (TENS). For devices like this, the demonstration of safety and effectiveness for a 510(k) clearance typically involves showing that the new device is substantially equivalent to a legally marketed predicate device in terms of:
- Intended Use: The new device is intended for the same uses as the predicate.
- Technological Characteristics: The new device has technological characteristics that are similar to the predicate, or if they are different, the differences do not raise new questions of safety or effectiveness.
The provided document does not contain information about clinical studies with human readers, ground truth established by experts, or AI performance metrics because such studies are generally not required for this type of device to demonstrate substantial equivalence.
The "proof" the device meets acceptance criteria is primarily through:
- Comparison of Technical Specifications: Directly comparing the electrical output parameters (voltage, current, waveform, net charge, phase charge, current density, power density) of the new device to the predicate device.
- Compliance with Recognized Standards: Demonstrating adherence to relevant electrical safety and electromagnetic compatibility standards (e.g., IEC 60601-1, IEC 60601-1-2, IEC 60601-2-10, ISO 14971).
- Software Verification: If applicable, verification activities for embedded software (though the summary states "software verification has been carried out," specific details are not provided beyond adherence to FDA guidance).
- Risk Analysis: A comprehensive risk analysis to address safety and effectiveness concerns.
Re-interpretation for the Context of the Provided Document
Given the nature of the provided document, here's how I can address your request, acknowledging that the criteria and studies described are for substantial equivalence rather than the clinical performance metrics you've requested for an AI/CAD device.
1. A table of acceptance criteria and the reported device performance
The "acceptance criteria" here are points of comparison to the predicate device that demonstrate substantial equivalence. The "reported device performance" is the comparison against the predicate's specifications and the device's compliance with safety standards.
Acceptance Criterion (Basis for Substantial Equivalence) | Reported Device Performance (as compared to Predicate Device Winstim, K102190) |
---|---|
Intended Use Equivalence: Same indications for use (Russian/EMS & TENS modes). | Met: The Tone-A-Matic has the exact same listed indications for use as the predicate device Winstim for both Russian/EMS (relaxation of muscle spasms, prevention of disuse atrophy, increase local blood circulation, muscle re-education, maintaining/increasing range of motion, immediate postsurgical stimulation of calf muscles) and TENS (symptomatic relief of chronic, intractable pain, management of pain associated with post-traumatic or post-operative conditions). |
Technological Characteristics Equivalence (General): Similar design & functionality. | Met: Both are micro-controller operated, non-transit-operable, portable devices that generate electrical impulses. Both have user-friendly interfaces with LCDs, adjustable intensity, and treatment timers. The Tone-A-Matic is light weight, small, and battery-powered, similar to the predicate's portable nature. Accessories provided are of "same quality and standards" as the predicate. |
Technical Specifications (Electrical Output): Comparable waveform, voltage, current, charge, density. | Met/Justified as Equivalent: While there are some differences, the document asserts these are "insignificant in the terms of safety or effectiveness." |
- Waveform: Tone-A-Matic uses Square Wave for all 3 modes; Winstim uses Sinusoidal for Russian and Square Wave for TENS/EMS. (This difference is deemed acceptable, likely due to similar physiological effect or within acceptable electrical safety limits).
- Max Output Voltage: Tone-A-Matic: Russian 50Vpp@500Ω, 60Vpp@2KΩ; TENS/EMS 57Vpp@500Ω, 90Vpp@2KΩ. Winstim: Russian 50Vpp@500Ω; TENS/EMS 57Vpp@500Ω, 225Vpp@2KΩ. (Tone-A-Matic's 2KΩ TENS/EMS voltage is lower, which would be safer, not raising new safety questions).
- Max Output Current: Tone-A-Matic: Russian 100mA@500Ω, 30mA@2KΩ; TENS/EMS 114mA@500Ω, 45mA@2KΩ. Winstim: Russian 100mA@500Ω; TENS/EMS 114mA@500Ω, 112.5mA@2KΩ. (Tone-A-Matic's 2KΩ TENS/EMS current is lower, implying safety).
- Net Charge: Both 0µC for all modes.
- Maximum Phase Charge: Both 20/22.5µC for respective modes.
- Max Current Density: Similar values for both devices.
- Max Power Density: Tone-A-Matic provides specific values for all modes; Winstim shows some differences, but these are likely considered within acceptable limits for equivalence (e.g., Tone-A-Matic TENS/EMS 0.251 W/cm² vs Winstim TENS/EMS 0.064 W/cm² - if the higher value is still safe, it's considered equivalent).
- Treatment Time: Tone-A-Matic (1-60 min) vs Winstim (1-100 min). (The shorter maximum duration would also be considered safe).
- Number of Output: Tone-A-Matic: 8; Winstim: not specified but implies multiple channels. |
| Electrical Safety and EMC Compliance: Conformity to international standards. | Met: Tone-A-Matic complies with IEC 60601-1 (Ed3.0), IEC 60601-1-2, IEC 60601-2-10, IEC 60601-1-11, and ISO 14971:2007. |
| Software Verification: Compliance with FDA guidance. | Met: Software verification has been carried out according to the FDA Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices. (No specific test results are detailed in this summary). |
| Risk Analysis: Comprehensive analysis carried out. | Met: A comprehensive risk analysis has been carried out regarding safety and effectiveness. (No specific details provided in this summary). |
Regarding the other information points, these are not applicable to the provided 510(k) submission for a non-AI/CAD device:
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Not applicable as this is a comparison to a predicate device based on technical specifications and standards compliance, not a clinical study with a test set of data.
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. There's no "ground truth" establishment by experts in the context of a diagnostic dataset for this submission. The "ground truth" for the device's performance is its adherence to internal specifications and relevant safety standards.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable.
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/CAD diagnostic device.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not applicable. This is not an AI device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- Not applicable in the AI/CAD sense. The "ground truth" for this device's safety and effectiveness relies on its measured electrical output parameters aligning with specified ranges and its design conforming to established national and international safety standards.
8. The sample size for the training set
- Not applicable. This device does not use machine learning, so there is no training set.
9. How the ground truth for the training set was established
- Not applicable.
In summary, the Tone-A-Matic 510(k) submission successfully demonstrated substantial equivalence to its predicate device, Winstim, through a detailed comparison of its intended use, technological characteristics, and technical specifications, alongside compliance with relevant safety and performance standards. It did so without conducting the types of clinical studies involving expert readers, ground truth establishment through consensus/pathology, or AI performance metrics as typically seen for AI/CAD devices.
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