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510(k) Data Aggregation

    K Number
    K202159
    Device Name
    actiTENS
    Manufacturer
    Date Cleared
    2020-12-22

    (141 days)

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

    actiTENS is intended to be used as:

    • Transcutaneous Electrical Nerve Stimulator (TENS), used for the following indications:
    • Symptomatic relief and management of chronic, intractable pain
    • Adjunctive treatment for post-surgical and post-trauma acute pain
    • Temporary relief of pain associated with sore and aching muscles due to strain from exercise or normal household and work activities
    • Relief of pain associated with arthritis
      Programs P1, P2, P3, P4, P5, P6, P7, P8, P10, P11, P12 and P13 correspond to TENS mode.
    • Electrical Muscle Stimulation (EMS), used for the following indications:
    • Temporary relaxation of muscle spasms
    • Prevent or retard disuse atrophy
    • Increase of local blood flow in the treatment area
    • Re-educate muscles
    • Maintain or increase the range of motion
    • Prevention of venous thrombosis of the calf muscles immediately after surgery
      Program P9 corresponds to EMS mode.
    Device Description

    actiTENS is a transcutaneous electrical nerve stimulation (TENS) medical device designed to manage chronic pain in people ages 22 and older.
    The compact design and flexible shape of the actiTENS electrical impulse generator allows to fix it for daily use directly to the body of the patient.
    The impulse generator is delivered with a separate cradle which allows safely recharging its nonremovable battery.
    The actiTENS is compatible with a selection of disposable electrodes and compatible connector cables transmit the electrical stimulation impulses to the targeted nerves according to the selected therapy. The electrical stimulation waveforms are biphasic and asymmetric.
    The actiTENS is controlled via a downloadable mobile app for iPhone which allows the comfortable and simple selection of the adequate stimulation program.
    The actiTENS is intended to be used by the patient at home and also for therapeutic application by medical professionals.

    AI/ML Overview

    The provided text describes the acceptance criteria and performance data for the actiTENS device, primarily focusing on its substantial equivalence to a predicate device (JKH Stimulator Plus - K182203).

    Here's the breakdown of the information requested:

    1. A table of acceptance criteria and the reported device performance

    The document does not explicitly present a "table of acceptance criteria" in the format of a requirement with a corresponding "reported device performance" that unequivocally meets that criterion for clinical efficacy or specific diagnostic accuracy. Instead, it demonstrates substantial equivalence to a predicate device by comparing technological characteristics and performance metrics. The underlying acceptance criterion for this 510(k) submission is that the device is "as safe and effective as the predicate device."

    The comparison table (Table 1: Comparison of actiTENS with JKH Stimulator Plus (K182203) and Table 2: Comparison of actiTENS with JKH Stimulator Plus (K182203) with regards to TENS and EMS performance) serves as the primary evidence. Here's a summary derived from those tables and surrounding text:

    Acceptance Criterion (Implicitly based on Predicate)Reported actiTENS Performance
    Indications for Use (TENS)Symptomatic relief and management of chronic, intractable pain; Adjunctive treatment for post-surgical and post-trauma acute pain; Temporary relief of pain associated with sore and aching muscles due to strain from exercise or normal household and work activities; Relief of pain associated with arthritis. Programs P1-P8, P10-P13.
    Indications for Use (EMS)Temporary relaxation of muscle spasms; Prevent or retard disuse atrophy; Increase of local blood flow in the treatment area; Re-educate muscles; Maintain or increase the range of motion; Prevention of venous thrombosis of the calf muscles immediately after surgery. Program P9.
    Prescription or OTC UsePrescription only. (Predicate was OTC and Prescription. This is noted as eliminating risks associated with OTC use.)
    Power SourceRechargeable (lithium-ion battery). (Predicate was rechargeable or non-rechargeable. Noted as not introducing new risks.)
    Functions and DesignElectrical stimulation only. (Predicate included electrical stimulation and heat. This is noted as eliminating risks associated with the heat function.)
    Maximum Output Voltage (Volts +/- 20%) at 500ΩRanges from 29.1V (P10) to 30.2V (multiple programs). (Compared to predicate's 30.2V to 57.6V. Noted as in range or below predicate, not raising new safety/effectiveness questions.)
    Maximum Output Voltage (Volts +/- 20%) at 2KΩ57.9V (all programs). (Compared to predicate's 57.9V to 96.0V. Noted as in range or below predicate, not raising new safety/effectiveness questions.)
    Maximum Output Voltage (Volts +/- 20%) at 10KΩN/A (Device stops delivering current at this impedance for safety). (Compared to predicate's 124V-134V. Noted as a safety feature that prevents measurements at this impedance).
    Maximum Output Current (mA +/- 20%) at 500ΩRanges from 58.2mA (P10) to 60.4mA (multiple programs). (Compared to predicate's 60.4mA to 115.2mA. Noted as in range or below predicate, not raising new safety/effectiveness questions.)
    Maximum Output Current (mA +/- 20%) at 2KΩ28.95mA (all programs). (Compared to predicate's 28.95mA to 48.0mA. Noted as in range or below predicate, not raising new safety/effectiveness questions.)
    Maximum Output Current (mA +/- 20%) at 10KΩN/A (Device stops delivering current at this impedance for safety). (Compared to predicate's 12.4mA-13.4mA. Noted as a safety feature that prevents measurements at this impedance).
    Pulse Width (µSec)Ranges from 57.5µSec (P12) to 247.5µSec (P3, P9). (Compared to predicate's 92µSec-100µSec. Noted as not raising new safety/effectiveness questions.)
    Frequency (Hz)Ranges from 2Hz (P3, P6, P8 modulated) to 100Hz (P1, P4, P5, P7, P6). (Compared to predicate's 156.2Hz-178.5Hz. Noted as in range or below predicate, not raising new safety/effectiveness questions.)
    Maximum Phase Charge (µC) at 500ΩRanges from 3.5µC (P12) to 14.9µC (P3). (Compared to predicate's 16.9µC-23.0µC. Noted as in the same range or lower than predicate, not raising new safety/effectiveness questions.)
    Maximum Current Density (mA/cm²) at 500ΩRanges from 1.7mA/cm² (P8) to 3.0mA/cm² (multiple programs). (Compared to predicate's 3.26mA/cm²-3.29mA/cm². Noted as in the same range or higher but within limits, not raising new safety/effectiveness questions, specifically <250mW/cm² for power density.)
    Maximum Average Power Density (mW/cm²) at 500ΩNot explicitly listed, but inferred to be within limits from current density discussion (<250mW/cm² as required by guidance for Powered Muscle Stimulator).
    Compliance with Voluntary StandardsYes (Same as predicate)
    Compliance with 21 CFR 898Yes (Same as predicate)
    Electrical Safety and EMCMet IEC 60601-1, IEC 60601-1-2, IEC 60601-1-6, IEC 60601-1-11, IEC 60601-2-10.
    Software Verification and ValidationMet IEC 62304 and FDA guidance documents.
    BiocompatibilityElectrodes previously cleared under K070807.
    Shelf-lifeElectrodes cleared under K070807, battery 12 months (information from manufacturer).

    2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    The document explicitly states: "Human Clinical Performance Testing: Clinical testing was not required to demonstrate the safety and effectiveness of the device." Therefore, there is no test set of clinical data from human subjects in the traditional sense for evaluating device performance. The performance data presented are primarily from benchtop testing and comparisons to a predicate device.

    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, as no clinical human performance testing was conducted that would require expert-established ground truth.

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

    Not applicable, as no clinical human performance testing was conducted that would require adjudication.

    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. The device is a Transcutaneous Electrical Nerve Stimulator (TENS) and Electrical Muscle Stimulator (EMS), not an AI-assisted diagnostic or imaging device that would involve human readers or MRMC studies.

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

    This concept is not directly applicable to a TENS/EMS device. The "standalone" performance is assessed through the electrical safety, EMC, software, and benchtop performance testing, which evaluate the device's technical specifications.

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

    For the safety and performance evaluation, the "ground truth" is established through:

    • Engineering specifications and standards: IEC 60601-1 series, IEC 62304, ASTM D4169-16, UL 1642, IEC 62366-1, IEC 62133-2.
    • Comparison to a legally marketed predicate device: The characteristics and demonstrated safety/effectiveness of the JKH Stimulator Plus (K182203) serve as a benchmark.
    • Manufacturer's data: For components like battery shelf-life.

    8. The sample size for the training set

    Not applicable, as this device does not utilize a "training set" for an algorithm in the way AI/Machine Learning models do.

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

    Not applicable.

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