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510(k) Data Aggregation
(190 days)
The WiTouch" Pro Transcutaneous Electrical Nerve Stimulator Device is used for the symptomatic relief and management of chronic intractable back pain and relief of pain of the upper and lower back associated with arthritis. It is also used for adjunctive treatment for post-surgical and post-trauma acute back pain.
The WiTouch™ Pro medical device is a Transcutaneous Electrical Nerve Stimulator (TENS) used to reduce the perception of pain by electrically stimulating peripheral nerves across the skin (transcutaneously). The design consists of a battery powered current generator with integral electrodes and replaceable electrical dispersive hydrogel pads (gel-pads). One side of the adhesive gel-pad adhere to the integral electrode, and the other side adhere the device to the healthy intact skin of the patient's back to provide a transcutaneous analgesic electrical stimulus to the painful area.
The provided 510(k) summary for the WiTouch™ Pro Transcutaneous Electrical Nerve Stimulator (TENS) device does not contain information about acceptance criteria or a dedicated study to prove that the device meets specific performance criteria in the way a diagnostic AI/ML device would.
This 510(k) submission focuses on demonstrating substantial equivalence to predicate devices based on technological characteristics and safety standards, rather than performance metrics related to diagnostic accuracy or clinical outcomes of a new treatment modality.
Here's a breakdown of why many of your requested items cannot be fulfilled from this document:
- Acceptance Criteria & Reported Performance: This document doesn't define quantitative performance acceptance criteria (e.g., sensitivity, specificity, accuracy, F1-score) for the device's efficacy in pain relief. Instead, it compares technical specifications (waveform, current density, power density, physical characteristics) to predicate devices to argue substantial equivalence.
- Sample Size, Data Provenance, Expert Ground Truth, Adjudication, MRMC, Standalone Performance, Ground Truth Type for Test Set: These are all concepts relevant to studies evaluating the diagnostic or therapeutic performance of a device or algorithm, often involving patient data and human expert review. This 510(k) does not describe such a study. The "study" here is essentially the comparison of technical specifications against FDA-recognized safety and electrical standards and existing predicate devices.
- Training Set Sample Size & Ground Truth: These are concepts for AI/ML model development. The WiTouch™ Pro is a hardware TENS device, not an AI/ML diagnostic tool, so these concepts do not apply in this context.
Summary of Information Available from the Document:
1. Table of Acceptance Criteria and Reported Device Performance:
The document does not explicitly state "acceptance criteria" in terms of performance metrics like sensitivity or specificity. Instead, it demonstrates inherent safety and equivalence through compliance with recognized standards and comparison of technical specifications to legally marketed predicate devices. The "reported device performance" is essentially that its electrical output and physical characteristics are within acceptable ranges and comparable to existing TENS devices.
| Acceptance Criteria (Implied by Predicate Comparison & Standards) | Reported Device Performance (WiTouch™ Pro) |
|---|---|
| Maximum average power density of electrodes with gel-pads < 0.25 W/cm² to reduce thermal burn risk (consistent with predicates). | 0.00069 W/cm² @ 500 Ω (using smallest electrode conductive surface area) - Meets criterion. |
| Waveform: Pulsed biphasic (consistent with predicates). | Pulsed biphasic - Meets criterion. |
| Shape: Square (consistent with predicates). | Square - Meets criterion. |
| Phase Duration (Step-1 and Step-3): Comparable to predicates (e.g., 0 to 400µs at 50% peak amplitude, 0 to 300µs for predicates). | 120µs - Comparable/within typical TENS ranges. |
| Phase Duration (Step-2): Comparable to predicates. | 480µs - Comparable/within typical TENS ranges. |
| Maximum Current Density (mA/cm², r.m.s.): Comparable to predicates (<10mA @500 Ω). | 0.12 mA @ 500 Ω - Meets criterion (<10mA). |
| Maximum Average Current (average absolute value), mA: Comparable to predicates (<10mA @500 Ω). | 1.6 mA @ 500 Ω - Meets criterion (<10mA). |
| Compliance with FDA Recognized Standards for safety, EMC, programmable systems, nerve/muscle stimulators, and biocompatibility (e.g., IEC 60601-1, IEC 60601-1-2, IEC 60601-1-4, IEC 60601-2-10, ISO 10993-1, ISO 10993-5, ISO 10993-10). | Declares conformity to all listed standards. - Meets criterion implicitly. |
| Substantial equivalence to predicate device functionalities and intended use. | Demonstrated through comparison table (e.g., TENS device power source, number of output modes, software, automatic shut-off, user override, indicators, timer range, weight, dimensions, housing material). |
2. Sample size used for the test set and the data provenance: Not applicable. This is a technical comparison for substantial equivalence, not a clinical study on a patient test set.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. Ground truth for clinical performance is not established in this type of submission.
4. Adjudication method 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/ML diagnostic or assistive device.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable. This is not an algorithm.
7. The type of ground truth used: For the technical specifications, the "ground truth" is the established electrical and physical properties of the device as measured and tested against recognized standards and the specifications of predicate devices. For biocompatibility, it's compliance with ISO 10993 standards.
8. The sample size for the training set: Not applicable. This is not an AI/ML device requiring a training set.
9. How the ground truth for the training set was established: Not applicable.
In essence, the "study" proving the device meets acceptance criteria (as determined by the FDA for TENS devices in a 510(k) context) is the technical comparison presented in the predicate comparison table and the declaration of conformity to established safety and performance standards. It demonstrates that the WiTouch™ Pro is as safe and effective as previously cleared TENS devices already on the market, based on its electrical characteristics and design.
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