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510(k) Data Aggregation
(196 days)
The E-Stim II is intended for use in the symptomatic relief of chronic intractable pain, post traumatic acute pain, and post surgical pain.
The device consists of a battery powered portable instrument with dual channel outputs connected to lead wires and electrodes. Setting the output switch and the intensity controls will deliver the desired stimulation. Adjusting the frequency control will change the stimulation as well. Treatment continues as long as the intensity control dial switch is on.
This 510(k) summary describes a premarket notification for the E-Stim II, a portable transcutaneous electrical nerve stimulator (TENS) intended for pain relief.
1. Table of Acceptance Criteria and Reported Device Performance
The provided document does not explicitly define acceptance criteria as typically seen for AI/ML device performance (e.g., sensitivity, specificity, AUC thresholds). Instead, the substantial equivalence determination for the E-Stim II is based on its conformity to established safety and performance standards and its similarity to a legally marketed predicate device (Well-TENS).
The "study" used here is a comparison of the E-Stim II to a predicate device and adherence to relevant standards.
| Acceptance Criterion (Implicit) | Reported Device Performance |
|---|---|
| Safety and Electrical Performance Conformity to Standards | The E-Stim II has been designed and tested to conform to the following standards: ISO 14971:2000, EN ISO 10993.1:1997/EN ISO 10993.5:1999/EN ISO 10993.10.2002, EN 60601-1:1990+A1:1993+A2:1995+A13:1996/IEC 60601-1:1988+A1:1991+A2:1995, EN 60601-1-2:2001/IEC 60601-1-2:2001, EN 980:2003. Applicable testing criteria from the AAMI standards for Transcutaneous Electrical Nerve Stimulators NS4:1985 for Well-TENS. |
| Intended Use Equivalence to Predicate Device | The E-Stim II is intended for use in the symptomatic relief of chronic intractable pain, post traumatic acute pain, and post surgical pain. "The intended use of the Well-Tens is identical." |
| Technological Characteristics (No New Safety Concerns) | Both devices (E-Stim II and Well-TENS) use one 9-volt battery. During stimulation, the electrical output for both devices is square waveform pulses. "Details of electrical output are different but new safety concerns are not raised by the differences." Controls on each device regulate stimulation intensity and frequency. Material composition of the electrodes and the lead wires is identical. |
2. Sample Size for Test Set and Data Provenance
This submission is for a medical device (TENS unit), not an AI/ML product that typically involves a "test set" of data. The "testing" refers to non-clinical bench testing for electrical safety, electromagnetic compatibility, and biocompatibility against recognized standards. Therefore, concepts like "sample size for the test set" and "data provenance" (country of origin, retrospective/prospective) are not directly applicable in the context of this 510(k) submission for a TENS device. The performance is assessed against engineering and medical device standards.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
This information is not applicable to this 510(k) submission. "Ground truth" in the context of electrical device testing relies on adherence to the specifications of the standards (e.g., a waveform must be a square wave; a certain current must be delivered within a defined range). No human experts are used to establish "ground truth" for the device's electrical output or material properties in the same way they would for diagnostic image interpretation.
4. Adjudication Method for the Test Set
Not applicable. Adjudication methods like 2+1 or 3+1 are used for establishing ground truth in clinical studies, particularly for diagnostic imaging or similar scenarios where expert consensus is needed to define a reference standard. This is not relevant for the technical performance testing of a TENS device against established engineering standards.
5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study was done
No, an MRMC comparative effectiveness study was not done. These types of studies are typically performed for diagnostic devices (especially AI-powered ones) to assess the impact of a device on reader performance. This submission is for a therapeutic TENS device, and its evaluation relies on its technical specifications, safety, and equivalence to a predicate device, not on how it changes human reader performance.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This device is a hardware-based TENS unit, not an algorithm or AI product. Its performance is inherently "standalone" in the sense that it delivers electrical stimulation as designed, but this is not an "algorithm-only" performance as understood in AI/ML contexts.
7. The Type of Ground Truth Used
The "ground truth" for this device's performance, in the absence of an AI/ML component, is derived from:
- Compliance with Recognized Standards: The device meets the technical specifications and safety requirements outlined in the listed ISO, EN, IEC, and AAMI standards (e.g., electrical output parameters, biocompatibility, risk management). These standards define the expected and acceptable performance characteristics.
- Equivalence to Predicate Device: The electrical characteristics and intended use are considered "substantially equivalent" to a legally marketed predicate device (Well-TENS), implying that its performance is comparable and acceptable.
8. The Sample Size for the Training Set
Not applicable. This device is not an AI/ML algorithm that requires a "training set."
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no "training set" for this device.
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(232 days)
As an NMES device, the Ttech NMES is indicated for the following conditions:
- Relaxation of muscle spasms .
- . Prevention or retardation of disuse atrophy
- Increasing local blood circulation .
- . Muscle re-education
- Immediate post-surgical stimulation of calf muscles to prevent . venous thrombosis; and
- t Maintaining or increasing range of motion
The Ttech NMES is a dual channel NMES device that produces a mild electrical current that is transmitted via leads to electrodes placed on the skin in areas predetermined by the clinician. The device, a set of electrodes with their lead wires, a battery (9 volt), carrying case, and instructions for use make up the Ttech NMES system.
The provided document is a 510(k) premarket notification for the Ttech NMES device. It details the device's characteristics and compares it to predicate devices to establish substantial equivalence. However, it does not contain specific acceptance criteria or an analytical study that proves the device meets such criteria in the way typically found for AI/ML-based medical devices with performance metrics like sensitivity, specificity, etc.
Instead, the document focuses on bench testing to demonstrate safety and performance equivalence to existing predicate devices. The conclusion explicitly states: "Bench testing raised no additional patient safety or performance issues so clinical testing was not indicated." This implies equivalence was established through non-clinical means.
Therefore, many of the requested details about acceptance criteria, sample sizes for test/training sets, expert ground truth, MRMC studies, or standalone algorithm performance are not applicable or present in this document.
Here's an attempt to answer the questions based on the provided text, while highlighting what is not present:
Acceptance Criteria and Study Details for Ttech NMES
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria are implicitly met by demonstrating that the Ttech NMES device performs "Good" in critical functions like "Current pulse regulation" and that its output parameters are within a range comparable to the predicate devices. The study performed was primarily bench testing to ensure safety and performance equivalence, rather than a clinical trial measuring specific performance metrics against pre-defined acceptance thresholds.
| Feature / Performance Metric | Acceptance Criteria (Implicitly based on Predicate Devices) | Reported Device Performance (Ttech NMES) | Predicate Device 1 (EMPI Focus) Performance | Predicate Device 2 (RESTIM) Performance |
|---|---|---|---|---|
| Current pulse regulation | Good | Good | Good | Good |
| Maximum output current | Comparable to or within acceptable range of predicates | 93mA | 60mA | 90mA |
| Load range | Comparable to or within acceptable range of predicates | 8ohm to open circuit | 8ohm to 10Kohm | 8ohm to open circuit |
| Maximum output voltage | Comparable to or within acceptable range of predicates | +100V | +120V | +55V |
| Maximum phase charge | Comparable to or within acceptable range of predicates | 21uC | 3.12 uC | 2.73 uC |
| Peak current density | Comparable to or within acceptable range of predicates | 0.125MAKm² | 7.92mA/cm² | 12.45 mA/cm² |
| Maximum Power Density | Comparable to or within acceptable range of predicates | .0058W/cm² | 4.09X10-5W/cm² | 4.29X10-6W/cm² |
| Patient Lead Safety | Compliance with 21 CFR 898 (Pass/Fail) | Testing Completed (Implied Pass) | N/A - Not explicitly stated for predicates | N/A - Not explicitly stated for predicates |
| Open/Short Circuit | Functional (Pass/Fail) | Testing Completed (Implied Pass) | N/A | N/A |
| Temperature Endurance | Functional (Pass/Fail) | Testing Completed (Implied Pass) | N/A | N/A |
| Incorrect battery install. | Functional (Pass/Fail) | Testing Completed (Implied Pass) | N/A | N/A |
| Vibration Test | Functional (Pass/Fail) | Testing Completed (Implied Pass) | N/A | N/A |
| Mechanical Shock Test | Functional (Pass/Fail) | Testing Completed (Implied Pass) | N/A | N/A |
| Humidity endurance test | Functional (Pass/Fail) | Testing Completed (Implied Pass) | N/A | N/A |
| Water immersion endurance | Functional (Pass/Fail) | Testing Completed (Implied Pass) | N/A | N/A |
2. Sample size used for the test set and the data provenance
Not applicable. The document describes non-clinical "bench testing" and does not refer to a "test set" in the context of patient data for performance evaluation. The data provenance would be laboratory testing in a controlled environment.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable. No expert ground truth on patient data was established, as no clinical testing was performed or deemed necessary.
4. Adjudication method for the test set
Not applicable. No test set involving human interpretation and adjudication was used.
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 powered muscle stimulator (NMES), not an AI/ML-based diagnostic or assistive technology for human readers. No MRMC study was performed.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done
Not applicable. This device is electro-mechanical, not an algorithm.
7. The type of ground truth used
For the safety and performance features, the "ground truth" was established through engineering standards and specifications (e.g., 21 CFR 898 for patient lead safety) and direct comparison of electrical output parameters against established values for predicate devices. There is no biological or clinical "ground truth" like pathology or outcomes data mentioned in this submission.
8. The sample size for the training set
Not applicable. As this is not an AI/ML device, there is no "training set."
9. How the ground truth for the training set was established
Not applicable. See point 8.
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