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510(k) Data Aggregation

    K Number
    K213879
    Date Cleared
    2022-01-05

    (23 days)

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

    The Self-adhesive Electrode is intended to be used to transmit electrical stimulation current to the patient's skin. Example electrical stimulations for current applications of the electrodes are: TENS and EMS.

    Device Description

    The Self-adhesive electrode, lead wire type and snap button type, are non-sterile flexible structures, composed of materials commonly used in this application:
    First layer: Non-woven fabric tape
    Second layer: Polyurethane (PU) electrically conductive carbon cloth (Hebei Kangshengda Electronic Technology Co., Ltd)
    Third layer: Biocompatible conductive hydrogel coupling media (ValueTrode Carbon, K970426), which has passed the required skin sensitivity testing criteria as specified in ISO 10993-10 and cytotoxicity testing criteria as specified in ISO 10993-5.
    The electrodes are designed for single patient / multiple application use. It can be used for low-frequency or medium-frequency nerve or muscle stimulators, as the conduction film adhered to body skin.

    AI/ML Overview

    Here's an analysis of the provided text regarding the acceptance criteria and supporting study for the "Self-adhesive Electrode" (K213879), structured according to your requested information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The FDA 510(k) summary does not explicitly list "acceptance criteria" for each parameter in the way a formal study report might. Instead, it demonstrates substantial equivalence to a predicate device (K090198) by comparing various characteristics and reporting that the new device met specific test standards or manufacturer requirements.

    The table below presents the comparative data and implies the "acceptance criteria" are generally that the new device's performance is similar to or meets the standards met by the predicate device, or adheres to established industry standards for such devices.

    ParameterAcceptance Criteria (Implied / Indirect)Reported Device Performance (New Device)Remark (from document)
    Formulation/Design Characteristics
    Trade Name(Not applicable for acceptance criteria)Self-adhesive Electrode--
    Common NameSame as predicateCutaneous electrodeSame
    Classification NameSame as predicateElectrode, cutaneousSame
    Product CodeSame as predicateGXYSame
    Device ClassSame as predicateIISame
    Regulation NumberSame as predicate882.1320Same
    Medical SpecialtySame as predicateNeurologySame
    Indications for useSame as predicateThe Self-adhesive Electrode is intended to be used to transmit electrical stimulation current to the patient's skin. Example electrical stimulations for current applications of the electrodes are: TENS and EMS.Same
    Target populationSame as predicate (Single patient use and multiple application)Single patient use and multiple applicationSame
    Type of useSame as predicate (OTC and Prescription use)OTC and Prescription useSame
    Design (shape & connection)Similar to predicate, customized specification allowedRound, Rectangle, Elliptical, Calabash, Butterfly, Palm shape according to customized specification. Lead wire with female socket, or snap button with male snap connector.Similar
    MaterialsSimilar to predicate and biocompatible standards met- Non-woven fabric tape- Polyurethane (PU) electrically conductive carbon cloth- Biocompatible conductive hydrogel coupling media (ValueTrode Carbon, K970426)Similar
    Electrode Pad SizeWithin ranges comparable to predicateRound Min.Ø20mm; Max.Ø85mmRectangle Min.26×26mm; Max.190×110mmElliptical Min.85×45mm;Calabash Min.90×47mm; Max.200×88mmButterfly Min.73×53mm; Max.195×95mmPalm shape 74×47mmSimilar
    Performance Characteristics
    Electrode Impedance of Electrode PadWithin ranges comparable to predicateRound: 302577ΩRectangle: 303646ΩElliptical: 407676ΩCalabash: 401602ΩButterfly: 402626ΩPalm shape: 402638ΩSimilar
    Patient contact area of electrodeWithin ranges comparable to predicateRound Min.3.14cm²; Max.56.716cm²Rectangle Min.6.76cm²; Max.209cm²Elliptical Min.38.25cm²; Max.240cm²Calabash Min.42.3cm²; Max.176cm²Butterfly Min.38.69cm²; Max.185.25cm²Palm shape 34.78cm²Similar
    Max. current Density (IRMS=10mA calculation)Within ranges comparable to predicateRound: 3.18mA/cm²Rectangle: 1.48mA/cm²Elliptical: 0.52mA/cm²Calabash: 0.24mA/cm²Butterfly: 0.52mA/cm²Palm shape: 0.29mA/cm²Similar
    Hydrogel thickness35mils ± 5mils (0.89mm ± 0.13mm)35mils ± 5mils (0.89mm ± 0.13mm)Same
    Hydrogel pH4.2 ± 1.04.2 ± 1.0Same
    Hydrogel volume resistivity1500 ohm-cm max1500 ohm-cm maxSame
    Compliance/Safety Standards
    Standards meetCompliance with AAMI/ANSI ES 60601-1, ANSI AAMI IEC 60601-2-2, FDA's Impedance Test, ASTM F1980, and manufacturer's requirements (peeling force, simulation use)• Lead wires test per 8.5.2.3 of AAMI/ANSI ES 60601-1;• Impedance test, Conformability test and Fluid tolerance test per 201.15.101.6 and 201.15.101.7 of ANSI AAMI IEC 60601-2-2 Edition 6.0 2017-03;• Impedance Test (Dispersion Test) according to FDA's requirement;• Peeling force test and Simulation use test according to manufacturer's requirement;• Shelf life test per ASTM F1980:2016Similar
    BiocompatibilityISO10993-5; ISO10993-10ISO10993-5; ISO10993-10Same
    Sterility StatusNon-sterile (as per predicate)Non-sterileSame
    Electrical safetyLead wire meets Clause 8.5.2.3 of AAMI/ANSI ES60601-1Lead wire meets Clause 8.5.2.3 of AAMI/ANSI ES60601-1Same
    Other PerformanceGood electrical conductivity, good adhesive property (as per predicate)Good electrical conductivity, good adhesive propertySame

    2. Sample Size Used for the Test Set and Data Provenance

    The document does not specify a separate "test set" in terms of patient data. The evaluation relies on non-clinical bench tests performed on the "Self-adhesive Electrode" device itself.

    • Sample Size: The document does not explicitly state the number of electrodes tested for each bench test. For example, it lists "Impedance test," "Conformability test," "Fluid tolerance test," "Peeling force test," and "Simulation use test" but doesn't provide the quantity of devices subjected to these tests.
    • Data Provenance: The tests were "Bench tests" conducted on the proposed device. The country of origin for the device manufacturer is China (Bozhou Rongjian Medical Appliance Co.,Ltd., Anhui, China). The data is retrospective in the sense that these tests were completed before the 510(k) submission.

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

    This information is not applicable as the study did not involve human interpretation or a "ground truth" derived from expert consensus on clinical data. The tests performed were objective bench tests against established standards and comparative measurements.

    4. Adjudication Method for the Test Set

    This is not applicable as there was no test set involving subjective human assessment or consensus building. The assessments were based on direct measurements and compliance with technical standards.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

    No, a MRMC comparative effectiveness study was not done. The submission explicitly states: "Clinical data was not including in this submission."

    6. If a Standalone (Algorithm Only Without Human-in-the-loop Performance) Was Done

    This is not applicable. The device is a self-adhesive electrode, a physical medical device, not an algorithm or software. Therefore, an "algorithm only" performance study is irrelevant. The compliance for the device involves physical and electrical characteristics.

    7. The Type of Ground Truth Used

    For this device, the "ground truth" or reference for performance and safety is established by:

    • Established industry standards: Such as ISO 10993 series for biocompatibility, AAMI/ANSI ES 60601-1, and IEC 60601-2-2 for electrical safety and performance.
    • Manufacturer's internal requirements: For tests like peeling force and simulation use.
    • Predicate device characteristics: Demonstrating that the new device's properties (materials, dimensions, electrical impedance ranges) are similar to those of a legally marketed predicate device (K090198).

    There is no clinical ground truth (e.g., pathology, outcomes data) as no clinical study was performed.

    8. The Sample Size for the Training Set

    This information is not applicable. This is a physical medical device, not an AI/ML algorithm that requires a "training set."

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

    This information is not applicable for the same reason as point 8.

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