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510(k) Data Aggregation

    K Number
    K220524
    Date Cleared
    2022-08-04

    (162 days)

    Product Code
    Regulation Number
    882.5890
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Intended for temporary relief of pain associated with sore and aching muscles in the upper and lower extremities (arm and/or leg) due to strain from exercise or normal household and work activities.

    Device Description

    Well-Life Mini TENS Stimulator (WL-23XXC/WL-23XXE Series) provides a transcutaneous electrical nerve stimulation (TENS) for temporary relief of pain associated with sore and aching muscles due to strain from exercise, normal household chores and work-related activities. The output port transmits the output signal to the electrode, which is attached to the user's skin; with the combination of the Stimulator device parts, the device can be placed on the treatment locations as recommended in the user manual for temporary relief of pain associated with sore and aching muscles in the low back, arthritis as well as upper and lower extremities (arm and/or leg) due to strain from exercise or normal household and work activities.

    The Well-Life Mini TENS Stimulator (WL-23XXC/WL-23XXE Series) is design changed from OTC MINI PATCH K121353 (Model WL-2301A/WL-2301B).

    The main differences between the two are disposable battery change to reusable battery, aside from battery changes, the appearance of the devices is also differnt. Also, minor changes include PCBA component placement changes, frame size changes, and new accessories to improve convenience.

    The definition of model name: WL is abbreviation of Well-Life Healthcare Limited. 23 is symbol of device series which are wireless, no monitor and operated by buttoning only. XX is the symbol for different program and output electrical signal in this device. The last English alphabet is the symbol of the appearance of this device, For C, it is oval shape and for E, it is round shape. The model of Stimulator device are WL-2301C, WL-2301E, WL-2306C and WL-2306E, which include operating elements, such as the ON/OFF button, intensity increase button, and intensity decrease button, and could be attached and detached to electrodes. The Stimulator device offers several different preset programs, and will switch automatically, with 21 minutes per session and will turn off automatically after each session. The Stimulator device could be operated through its buttons to manually realize its functions, such as turning on/off and increasing/decreasing intensity.

    The accessories of Well-Life Mini TENS Stimulator (WL-23XXC/WL-23XXE Series) are electrode which can be patch or garment. 3 models of patches and 5 models of garments are recommended. There are CM7257, CM169100, CM13070 for electrode patch and Well-Life Garment Electrode -Arm (GM-AM-O-X00), Well-Life Garment Electrode -Elbow (GM-EB-O-X00). Well-Life Garment Electrode -Back Strech Belt (EW-BK-00IE), Well-Life Garment Electrode - Wrist (EW-WR-00IE) and Well-Life Garment-Knee (EW-KN-002E).

    The electrode Pad composed of non-woven fabric, conductive layer and conductive gel, it is connected to the stimulator through buttons or wires, and is in contact with the skin through conductive gel to transmit electrical signal to the skin to achieve therapeutic effects.

    The Well-Life Garment Electrode series are blending by Non-conductive textile and conductive textile, from the name of the conductive garment the user can identify the applicable body part, and the textile technology is adjusted to make the product fit on the skin. It is connected to the stimulator through buttons or wires, and is in contact with the skin through conductive textile to transmit electrical signal to the skin to achieve therapeutic effects.

    The Stimulator device can connect to a specified external IEC 60601-1 compliant power supply for charging of the internal lithium-ion battery. The accessories must comply with AAMI/ ANSI/ES60601- 1, IEC 60601-1-2 and IEC 60601-2-10. The accessories include: An external power adaptor, an electrode cord I cable attached to electrodes pads and battery.

    AI/ML Overview

    This document is a 510(k) summary for the Well-Life Mini TENS Stimulator, which is a Transcutaneous Electrical Nerve Stimulator (TENS) for pain relief. The purpose of this summary is to demonstrate substantial equivalence to a legally marketed predicate device, not to present a de novo clinical study with specific acceptance criteria in the typical sense for an AI/ML device.

    Therefore, the requested information regarding "acceptance criteria" and "study that proves the device meets the acceptance criteria" in the context of AI/ML performance metrics (such as sensitivity, specificity, or AUC) is not applicable to this submission. This 510(k) summary is for a medical device that relies on established TENS technology and demonstrates substantial equivalence through non-clinical bench testing, biocompatibility testing, and comparisons to predicate devices based on technical specifications and safety standards.

    The document explicitly states: "No clinical testing was conducted for this device." This means there was no study performed to measure the device's performance against clinical endpoints or to assess how it might improve human reader performance with AI assistance. As such, there are no acceptance criteria, sample sizes, expert ground truth establishment, or adjudication methods as would be found in a study for an AI/ML algorithm requiring such validation.

    Instead, the "acceptance criteria" for this device's clearance were its adherence to relevant electrical safety, biocompatibility, and performance standards for TENS devices, and its demonstrated substantial equivalence (based on design, intended use, energy type, etc.) to already cleared predicate devices.

    Here's a breakdown of the information that is available in the document, framed against your request, highlighting why some points are not applicable:

    1. Table of Acceptance Criteria and Reported Device Performance:

    Since this is a TENS device relying on substantial equivalence to predicates, the "acceptance criteria" are compliance with relevant safety and performance standards for TENS devices and demonstrating that its specifications are similar to or justify differences from the predicate. The "reported device performance" are the results of non-clinical bench testing and adherence to these standards.

    Acceptance Criteria (based on standards & predicate comparison)Reported Device Performance / Compliance
    Biocompatibility (ISO 10993-1, -5, -10)In compliance, no concerns
    Electrical Safety (IEC 60601-1, -1-2, -1-11, -2-10)Met all design specifications
    Battery Safety (IEC 62133)Met all design specifications
    Performance Bench Testing (IEC 60601-2-10, ANSI AAMI NS4)Met all design specifications
    Usability Engineering (IEC 60601-1-6, IEC 62366-1)Met all design specifications
    Risk Management (ISO 14971)Applied
    Device Specifications vs. Primary Predicate (K121353)(See tables on pages 9-13)
    Regulation Number (882.5890)Same
    Product Code (NUH)Same
    OTC/RxSame (OTC)
    Indication for useSame
    Method of Line current Isolation (Type BF)Same
    Patient Leakage Current (Normal <0.1μA, Single Fault <0.5μA)Same (Under 0.1, Under 0.5)
    Average DC current through electrodes (when device on but no pulses)Same (Not applicable)
    Number of Output channels (Synchronous)Same
    Method of Channel Isolation (Output Coil Voltage)Same
    Software/Firmware/Microprocessor controlSame (Yes)
    Automatic Overload/No-Load TripSame (No, Yes)
    Automatic Shut OffSame (Yes)
    User Override controlSame (No)
    Indicator (On/Off, Low Battery, Voltage/Current Level)Same (Yes for all)
    Timer Range (Minutes)Same (20)
    Compliance with Voluntary StandardsSame (ES60601-1, IEC60601-1-2, IEC60601-2-10, IEC 60601-1-11)
    Compliance with 21 CFR 898Same (Yes)
    Output Signal Specification vs. Primary Predicate (K121353)(See tables on pages 11-13)
    WaveformBia-phasic (consistent with TENS)
    Number of Output Modes (WL-2301C/E)Same as primary predicate (3)
    Number of Output Modes (WL-2306C/E)Different from primary, same as secondary predicate (8)
    Shape (Rectangular)Consistent
    Max Output Voltage (WL-2301C/E, WL-2306C/E)Same as primary predicate
    Max Output Current (WL-2301C/E, WL-2306C/E)Same as primary predicate
    Pulse Duration (WL-2301C/E)Same as primary predicate (250MAX)
    Pulse Duration (WL-2306C/E)Consistent with secondary predicate (260MAX)
    Frequency (WL-2301C/E)Same as primary predicate (60MAX)
    Frequency (WL-2306C/E)Consistent with secondary predicate (120MAX)
    Symmetrical phasesSame (No)
    Max output charge per pulse (uC)15 (WL-2301C/E), 15.6 (WL-2306C/E)
    Max average current (mA)0.9 (WL-2301C/E), 1.87 (WL-2306C/E)
    Max output power (W)0.027 (WL-2301C/E), 0.056 (WL-2306C/E)
    Max Current Density (< 2 mA/cm²)All reported values below threshold
    Max Power Density (< 0.25 W/cm²)All reported values below threshold

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

    • Sample Size: Not applicable. No clinical testing with human subjects was conducted. Non-clinical bench testing was performed on device units.
    • Data Provenance: Not applicable in the context of clinical data. The data stems from internal laboratory testing of the device and comparison of its specifications to predicate devices. The country of origin for the submitter is Taiwan.

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

    • Not applicable. There was no "test set" requiring ground truth established by medical experts in the context of diagnostic or prognostic performance. The device is a therapeutic TENS stimulator.

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

    • Not applicable. No test set requiring expert adjudication was used.

    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 device is not an AI/ML diagnostic or assistive tool, and no MRMC study was performed.

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

    • Not applicable. This is not an AI algorithm.

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

    • Not applicable. In the context of performance testing for substantial equivalence, the "ground truth" is compliance with established engineering and safety standards (e.g., IEC 60601 series, ISO 10993 series, ANSI AAMI NS4) and demonstrating that the device's technical specifications fall within acceptable ranges as compared to its predicate devices.

    8. The sample size for the training set:

    • Not applicable. There is no AI/ML algorithm in this device that requires a training set.

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

    • Not applicable. No training set was used.
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