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510(k) Data Aggregation

    K Number
    K200177
    Date Cleared
    2021-03-25

    (426 days)

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

    KTR-2240,KTR-2250,KTR-2610,KTR-2640,KTR-2650:(TENS, EMS, FITNESS)

    TENS (Mode~20): To be used for temporary relief of pain associated with sore and aching muscles in the shoulder, waist, back, back of the neck, arm, leg, and foot due to strain from exercise or normal household work activities by applying current to stimulate nerve.

    EMS (Mode 2140): It is intended to stimulate healthy muscles in order to improve and facilitate muscle performance. FITNESS (Mode 4150): Improvement of abdominal tone, strengthening of the abdominal muscle development of firmer abdomen.

    KTR-2241,KTR-2251,KTR-2242,KTR-2252,KTR-2611,KTR-2641,KTR-2612,KTR-2612,KTR-2652: (TENS)

    To be used for temporary relief of pain associated with sore and aching muscles in the shoulder, waist, back of the neck, arm, leg, and foot due to strain from exercise or normal household work activities by applying current to stimulate nerve.

    Device Description

    The Low-frequency Multi-function physiotherapy instrument is a portable and battery powered multifunctional device. The low-frequency multi-function physiotherapy instrument (models: KTR-2240, KTR-2250, KTR-2610, KTR-2640, KTR-2650) offering Transcutaneous Electronic Nerve Stimulator (TENS), Electronic Muscle Stimulation. It has 50 operation modes, which can give certain electrical pulse through electrode pads placed on the skin to help users to enjoy body stimulation. And the TENS (Mode 120) is to be used for temporary relief of pain associated with sore and aching muscles in the shoulder, waist, back of the neck, arm, leg, and foot due to strain from exercise or normal household work activities by applying current to stimulate nerve. EMS (Mode 2140) is intended to stimulate healthy muscles in order to improve or facilitate muscle performance. FITNESS (Mode 41~50) is indicated for the improvement of abdominal muscle tone, for the strengthening of the abdominal muscles and for the development of a firmer abdomen.

    The low-frequency multi-function physiotherapy instrument (models: KTR-2241, KTR-2242, KTR-2252, KTR-2611, KTR-2641, KTR-2612, KTR-2612, KTR-2652) offering Transcutaneous Electronic Nerve Stimulator (TENS). It has 15 operation mode, and 6 automatic mode, which can give certain electrical pulse through electrode pads placed on the skin to help users to enjoy body stimulation. The TENS (Mode 1-15) is intended to be used for temporary relief of pain associated with sore and aching muscles in the shoulder, waist, back, back of the neck, arm, leg, and foot due to strain from exercise or normal household work activities by applying current to stimulate nerve.

    The electronic stimulatory module has the operating elements of ON/OFF Key, Display screen, Mode Selection key and Intensity Modification keys.

    The LCD display screen can show selected mode and program, output intensity, stimulate frequency, and time remaining of an application mode.

    The device is equipped with accessories of electrode wires, and batteries. The electrode wire is used to connect the patches to the main unit.

    The electrode pads are complying with the biocompatibility standards ISO 10993-5 (Cytotoxicity) and ISO 10993-10 (Irritation and Sensitization), are interchangeable.

    AI/ML Overview

    The medical device in question is a "Low-frequency Multi-function physiotherapy instrument" that functions as a Transcutaneous Electrical Nerve Stimulator (TENS), Electrical Muscle Stimulation (EMS), and/or a FITNESS device depending on the model. This is a Class II device.

    The provided document describes a 510(k) submission (K200177) where the manufacturer, Shenzhen Kentro Medical Electronics Co., Ltd, aims to demonstrate substantial equivalence to previously cleared predicate devices. The study conducted to prove the device meets acceptance criteria is primarily based on nonclinical (bench) testing and comparison of technical specifications with predicate devices, rather than a clinical trial with human subjects.

    Here's the detailed breakdown of the acceptance criteria and the study that proves the device meets them:

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria for this device are largely implied by compliance with recognized electrical safety and biocompatibility standards, and by demonstrating similar technical specifications to predicate devices. The "reported device performance" is essentially the subject device's specifications and its compliance with stated standards.

    Acceptance Criteria (Implied / Standard)Reported Device Performance (Subject Device K200177)
    Electrical SafetyComplies with IEC 60601-1-11 and IEC 60601-2-10 standards.
    Electromagnetic Compatibility (EMC)Complies with IEC 60601-1-2 standard.
    UsabilityComplies with IEC 62366-1 standard.
    Software Verification and ValidationComplies with FDA "Guidance for Pre-Market Submissions and for Software Contained in Medical Devices."
    Biocompatibility (for body-contacting parts)Electrode pads comply with ISO 10993-5 (Cytotoxicity) and ISO 10993-10 (Irritation and Sensitization). The electrode patches are purchased from a qualified supplier with FDA clearance (K171381).
    Patient Leakage CurrentDC: < 0.01µA (reported as NC for Normal Condition, with the value provided in the detailed comparison). While the predicate device reported DC: 0.5µA, the subject device's performance of < 0.01µA is significantly lower and better, satisfying this safety criterion. SFC (Single Fault Condition): 0.1mA (compared to 0.6µA for predicate, the 0.1mA value is acceptable).
    Average DC current through electrodes (device ON, no pulses)< 0.01µA
    Number of Output Channels2 channels.
    Number of Output ModesModels KTR-2240, KTR-2250, KTR-2610, KTR-2640, KTR-2650: 50 modes. Other models (KTR-2241, etc.): 15 modes.
    Output Intensity Level16 steps.
    Synchronous or Alternating ChannelSynchronous.
    Method of Channel IsolationVoltage Transform Isolation.
    Regulated Current or VoltageVoltage Control.
    Software/Firmware/Microprocessor ControlYes.
    Automatic Overload TripNo. (Consistent with predicate devices, this is not an acceptance criterion that needs to be "Yes").
    Automatic No-Load TripNo. (Consistent with predicate devices).
    Automatic Shut OffYes.
    User Override ControlYes.
    Indicator Display (On/Off Status, Low Battery, Voltage/Current Level)Yes (for all listed).
    Timer Range15, 30, 45 min.
    WaveformPulsed, symmetric, biphasic.
    ShapeRectangular, with interphase interval.
    Maximum Output Voltage @ 500Ω (various modes)Ranges from 20.0V to 46.0V (across different modes). (Within acceptable limits compared to predicates 40-55V). "SE Note 2" indicates these differences do not raise new safety or effectiveness concerns.
    Maximum Output Current @ 500Ω (various modes)Ranges from 40.0mA to 92.0mA (across different modes). (Within acceptable limits compared to predicates 80-110mA). "SE Note 2" indicates these differences do not raise new safety or effectiveness concerns.
    Pulse DurationTENS: 120µs, EMS: 200µs, FITNESS: 200µs.
    Pulse FrequencyTENS: (20-100) Hz, EMS: (1-15) Hz, FITNESS: (2-16) Hz.
    Net Charge (per pulse) @ 500Ω0µC, Method: Balanced waveform.
    Maximum Phase Charge @ 500Ω (various modes)Ranges from 5.33µC to 18.40µC. (Within acceptable limits compared to predicates 12.78-19.2µC). "SE Note 2" indicates these differences do not raise new safety or effectiveness concerns.
    Maximum Average Current @ 500Ω (various modes)Ranges from 0.03mA to 3.20mA. (Within acceptable limits compared to predicates 1.53-1.69mA). "SE Note 2" indicates these differences do not raise new safety or effectiveness concerns.
    Maximum Average Power Density (various modes)Ranges from 0.0001 mW/cm² to 0.2044 mW/cm². (Within acceptable limits compared to predicates 0.056-0.08 mW/cm²). "SE Note 2" indicates these differences do not raise new safety or effectiveness concerns.
    Maximum Average Current Density (various modes)Ranges from 0.0010 mA/cm² to 0.1279 mA/cm². (Within acceptable limits compared to predicates 0.064-0.073 mA/cm²). "SE Note 2" indicates these differences do not raise new safety or effectiveness concerns.
    ON Time0.6s.
    OFF Time0.6s.
    Environment for OperatingTemp: +5°C-+40°C; Humidity: 15%-93%RH; Atmospheric Pressure: 700hPa-1060hPa.
    Environment for StorageTemp: 0°C-+55°C; Humidity: 0-93%RH; Atmospheric Pressure: 700hPa-1060hPa.

    2. Sample Size for the Test Set and Data Provenance

    • Sample Size for Test Set: Not applicable in the context of a clinical test set. The submission relies on bench testing results, comparing the new device's technical specifications and compliance with standards against predicate devices and in vitro tests for biocompatibility. There is no mention of a patient-based "test set" for performance evaluation.
    • Data Provenance: The data comes from nonclinical (bench) testing performed by the manufacturer, or through documentation provided by suppliers for components (e.g., electrode pads). The report does not specify the country of origin for these specific tests, but the manufacturer is based in China. The data is retrospective in the sense that it's reported after the tests were conducted, but it's not "retrospective clinical data" as no clinical trials are described.

    3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Experts

    • Number of Experts: Not applicable. The ground truth, in this context, is established by international standards (IEC, ISO) for electrical safety, EMC, usability, and biocompatibility, as well as FDA guidance for software. These standards themselves are developed by expert consensus within their respective fields, but individual experts are not explicitly cited as establishing ground truth for a discrete test set in this document.
    • Qualifications of Experts: Not applicable in the context of a clinical test set. The underlying expertise is embedded in the standards and regulatory guidance documents.

    4. Adjudication Method for the Test Set

    • Adjudication Method: Not applicable. There is no clinical test set requiring expert adjudication. The "adjudication" here is the FDA's review of the submitted technical documentation and its determination of substantial equivalence based on a comparison to recognized standards and predicate devices.

    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 a physiotherapy instrument (TENS/EMS/FITNESS), not an AI-powered diagnostic imaging device or a device involving "human readers" or AI assistance in interpretation.

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

    • Not applicable. This device does not involve an algorithm generating interpretations or diagnoses that would require standalone performance evaluation. Its "performance" is based on its electrical output characteristics and meeting safety standards.

    7. The Type of Ground Truth Used

    • The "ground truth" used is defined by adherence to international consensus standards for medical device safety and performance (e.g., IEC 60601 series, ISO 10993 series) and technical specifications that fall within the established range of legally marketed predicate devices. For biocompatibility, the ground truth is established by in vitro test results against ISO standards.

    8. The Sample Size for the Training Set

    • Not applicable. This device does not employ machine learning or AI that requires a "training set" of data.

    9. How the Ground Truth for the Training Set was Established

    • Not applicable, as no training set is used.
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