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510(k) Data Aggregation

    K Number
    K171381
    Date Cleared
    2017-12-13

    (216 days)

    Product Code
    Regulation Number
    882.1320
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Adhesive Electrodes are intended to transmit electrical current to patient skin for TENS (Transcutaneous Electrical Nerve Stimulation) and EMS (Electrical Muscular Stimulation) applications. It is for OTC (Over-The -Counter) or Prescription use and is to be used for adults only.

    Device Description

    The Adhesive Electrodes transmit electrical current to patient skin, the electrical current is first transmitted via the snap button then transmitted to the conductive gel which is adhered to patient skin. Adhesive Electrodes are multi-layer reusable, flexible structures, composed of laminated materials commonly used in this application: EVA foam First layer: Insulating backing material: Second layer: Conductive film: Carbon film Third layer: Biocompatible self-adhesive conductive hydrogel Protective liner: PET. The dimension of the adhesive electrode is 40 mm (L) × 70 mm (W) ×3mm (H).

    AI/ML Overview

    The provided text describes ShenZhen Quality Medical Technology Co.,Ltd's "Adhesive Electrodes" (K171381) and indicates its substantial equivalence to predicate devices, rather than outlining a detailed study proving the device meets specific acceptance criteria in the manner requested. The document is a 510(k) summary for a medical device focusing on establishing substantial equivalence to previously cleared devices.

    Therefore, many of the requested categories (sample size, expert qualifications, adjudication, MRMC studies, standalone performance, training set details) are not applicable or cannot be extracted from this type of regulatory submission.

    Here's what can be extracted and inferred based on the provided document:

    1. Table of Acceptance Criteria and Reported Device Performance

    According to the document, the acceptance criteria are largely based on equivalence to predicate devices and adherence to relevant ISO standards.

    Acceptance Criteria CategorySpecific Criteria/StandardReported Device PerformanceRemark on Equivalence
    Intended UseTransmit electrical current for TENS and EMS, OTC/Prescription, adults only. Similar to predicate devices.The Adhesive Electrodes are intended to transmit electrical current to patient skin for TENS and EMS applications. It is for OTC or Prescription use and is to be used for adults only.SE (Substantial Equivalence)
    Material/DesignThree layers: Insulating backing, Conductive film, Conductive hydrogel. Similar in principle to predicates.Three layers: EVA foam (insulation), Carbon film (conductive), Biocompatible self-adhesive conductive hydrogel.SE (Substantial Equivalence)
    Electrical PerformanceA.C. Impedance <300 ohms<300 ohmsSE (Substantial Equivalence)
    BiocompatibilityCompliance with ISO10993-5 (cytotoxicity) and ISO10993-10 (sensitization/irritation). Similar to predicates.All user directly contacting materials are in compliance with ISO10993-5 and ISO10993-10 requirements.SE (Substantial Equivalence)
    Electrode PerformanceElectrical Impedance Performance, Adhesive Performance, Current dispersion, Peel force.Evaluated through these tests. Tested results satisfy the requirements.Implied to meet, based on "as safe, as effective" conclusion.
    Reuse TestingN/A (implied to meet requirements for reusable device)Evaluated through reuse testing. Tested results satisfy the requirements.Implied to meet, based on "as safe, as effective" conclusion.
    Shelf LifeAccording to ASTM F1980 - 16Conducted. Tested results satisfy the requirements.Implied to meet, based on "as safe, as effective" conclusion.
    Non-clinical TestsDemonstrated safety, effectiveness, and performance as well as legally marketed predicate devices.The non-clinical tests demonstrated that the subject device is as safe, as effective, and performs as well as the legally marketed predicate devices.SE (Substantial Equivalence)

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

    • Sample Size for Test Set: Not explicitly stated. The document refers to "bench testing" and "non-clinical tests" which typically involve a number of units for various evaluations (e.g., electrical, mechanical, biocompatibility). However, the specific number of units tested for each criterion is not provided.
    • Data Provenance: The testing was conducted by or on behalf of ShenZhen Quality Medical Technology Co.,Ltd, which is based in Shenzhen, Guangdong, China. This indicates the testing was likely performed in China. The data is retrospective in the sense that it supports a regulatory submission for a device designed and tested prior to the submission date.

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

    • Not Applicable. This device is an adhesive electrode, and the testing described is primarily physical, electrical, and biocompatibility testing. It does not involve interpretation of medical images or data by human experts for establishing ground truth as would be relevant for diagnostic AI/CAD devices. The "ground truth" here is the objective measurement against established standards or predicate device performance.

    4. Adjudication method for the test set

    • Not Applicable. As per point 3, there's no "ground truth" established by human interpretation that would require an adjudication method.

    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

    • No. This is not an AI/CAD/diagnostic device. No MRMC study was conducted or is relevant for this type of medical device (adhesive electrodes).

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

    • Not Applicable. This is a hardware medical device (adhesive electrodes). There is no algorithm in the traditional sense that would have a "standalone" performance. The performance is purely that of the physical device.

    7. The type of ground truth used

    • The "ground truth" for the device's performance is established by objective measurements against recognized industry standards (e.g., ISO, ASTM) and comparison to the performance characteristics of legally marketed predicate devices. For example, "A.C. Impedance <300 ohms" is a measurable standard. Biocompatibility is assessed against ISO 10993.

    8. The sample size for the training set

    • Not Applicable. This device is not an AI/machine learning device; hence, there is no "training set."

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

    • Not Applicable. As there is no training set, this question is not relevant.
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