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510(k) Data Aggregation

    K Number
    K060669
    Manufacturer
    Date Cleared
    2006-10-13

    (213 days)

    Product Code
    Regulation Number
    882.5890
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K030998, K030332, K983228

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    For Prescription Use Model SE-100:

    • Relief of chronic intractable pain. .
    • Adjunctive treatment of post-surgical or post-traumatic acute pain. .

    For Prescription Use Models ST-150, ST-200 and ST-300:

    • Relief of chronic intractable pain. .
    • Adjunctive treatment of post-surgical or post-traumatic acute pain. .
    • Adjunctive therapy in reducing the level of pain associated with osteoarthritis of the ● knee.
    • Adjunctive therapy in reducing the level of pain from rheumatoid arthritis of the hand. .
    Device Description

    The MedRelief" ST Series™, consisting of models ST-100, ST-150, ST-200 and ST-300, is designed to provide subthreshold electrical stimulation for acute and chronic pain, including pain, including pain from osteoarthritis and rheumatoid arthritis, in a single compact, lightweight and user-friendly package. "Subthreshold" stimulation does not normally cause sensation or muscle contraction, but acts at a cellular level to relieve pain.

    Each device in the ST Series is comprised of the following main components.

    • A power section consisting of battery, switch, test and conditioning components; .
    • A dosing timer, initialized at power-on and providing a choice of treatment times; .
    • A control oscillator, providing pulse-burst timing; .
    • A pulse oscillator, providing timing for individual pulses; and .
    • An output section, providing filtering, DC blocking and intensity control.

    While some components are digital, all functions are hard-wired and there is no microprocessor or software used. Output is by means of lead wires and skin-contact electrodes already commercially available and legally sold by others.

    The member devices in the ST Series™ differ only in the complexity of their controls and number of physician or user options which each model offers.

    AI/ML Overview

    The provided document (K060669) is a 510(k) summary for a Transcutaneous Electrical Nerve Stimulator (TENS) device called the MedRelief ST Series. This type of submission generally focuses on demonstrating substantial equivalence to a legally marketed predicate device, rather than on detailed clinical study results and acceptance criteria derived from them.

    Therefore, the document does not contain the information required to fully answer the request, particularly regarding specific acceptance criteria for device performance, outcomes of a study proving those criteria were met, sample sizes, expert qualifications, or ground truth establishment.

    However, based on the comparative tables, we can infer that the general acceptance criteria for the MedRelief ST Series are substantial equivalence in technological characteristics and intended use to the predicate devices. The study proving this, in the context of a 510(k), is the comparison of the proposed device's characteristics to those of the predicate devices.

    Here's an attempt to answer the questions based on the available information, noting where information is not present:


    1. Table of acceptance criteria and the reported device performance

    Since this is a 510(k) submission based on substantial equivalence, the "acceptance criteria" are implied to be that the proposed device's characteristics fall within acceptable limits or are the "same as" the predicate devices. The "reported device performance" is essentially the detailed description of the proposed device's characteristics.

    Acceptance Criteria (Implied by Predicate Comparison)Reported Device Performance (MedRelief ST Series)
    Intended Use (Indications)ST-100: Relief of chronic intractable pain; Adjunctive treatment of post-surgical or post-traumatic acute pain.
    ST-150, ST-200, ST-300: Relief of chronic intractable pain; Adjunctive treatment of post-surgical or post-traumatic acute pain; Adjunctive therapy in reducing the level of pain associated with osteoarthritis of the knee; Adjunctive therapy in reducing the level of pain and stiffness associated with pain from rheumatoid arthritis of the hand. (Stated to be the same as predicate devices for respective indications)
    Number of Output Modes (Subthreshold TENS)One: Subthreshold TENS (Same as predicates)
    Number of Output ChannelsOne (ST-100, ST-150); Two (ST-200); Four (ST-300). (Predicate 1 has one; Predicate 2 has one or two versions)
    Pulse ShapeRectangular to exponential, depending on pulse length and charge balancing time chosen (Same as Predicate 1, different but biphasic for Predicate 2)
    Mono- or Biphasic OutputBiphasic (Same as Predicate 1; Predicate 2's claimed monophasic was measured by Healthonics as biphasic - Note 1)
    Maximum Instantaneous Current8.62 mA (Same as Predicate 1; Lower than Predicate 2's 24 mA)
    Maximum Time Averaged Current2.27 mA (2.71 mA, Note 2) (Same as Predicate 1's 2.27 mA; Higher than Predicate 2's 2 mA)
    Maximum Phase Charge12.4 µC at 100 Hz; 1.87 µC at 700 Hz (Note 2) (Predicate 1: 1.87 µC at 700 Hz; Predicate 2: 20 µC at 100 Hz). Values show variability across models and frequencies but are presented in comparison to predicates.
    Maximum Current Density at Electrode0.41 mA/sq.cm. (Note 2) (Same as Predicate 1's 0.41 mA/sq.cm.; Much higher than Predicate 2's 0.14 mA/sq.cm.)
    Maximum Power Density at Electrode0.133 mW/sq.cm. (Note 2) (Same as Predicate 1's 0.133 mW/sq.cm.; Much lower than Predicate 2's 0.83 mW/sq.cm.)
    Regulated Current or Voltage?Regulated current (Same as Predicate 1; Different from Predicate 2's regulated voltage)
    Software/Firmware/Microprocessor Control?No (Same as Predicate 1 and Predicate 2 Version A; Different from Predicate 2 Version B which has it)
    Housing MaterialsFlame-retardant ABS plastic (Same as Predicate 1; Different from Predicate 2's Cycolac plastic)

    The "study" proving these "criteria" are met is essentially the technical comparison presented in the 510(k) submission, where the characteristics of the MedRelief ST series are directly compared against those of the predicate devices (Healthonics MedRelief SE-50 and Bionicare Model BIO-1000). The FDA's issuance of the 510(k) clearance signifies their agreement that the device is substantially equivalent based on this comparison.

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

    This information is not provided in the 510(k) summary. 510(k) submissions for TENS devices demonstrating substantial equivalence rarely require clinical studies with human test sets, especially if the new device is technologically similar to previously cleared devices. The "test set" here would implicitly be the technical specifications and performance measurements detailed in the tables, which were likely derived from in-house engineering tests and comparisons.

    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)

    This information is not provided. As no clinical study is detailed, the concept of establishing ground truth by medical experts in this context is not applicable. The "ground truth" for this submission would be the verifiable specifications and performance of the device and its predicates.

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

    This information is not provided. Not applicable in the context of a technical comparison for substantial equivalence.

    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, a multi-reader multi-case comparative effectiveness study was not done. This is a TENS device, and the submission is a 510(k) for substantial equivalence, not an AI or imaging device requiring MRMC studies.

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

    No, a standalone algorithm performance study was not done. The device does not contain a microprocessor or software (except for Version B of one predicate), therefore, it does not rely on algorithms in the way modern AI devices do. Its performance is based on its hardware characteristics.

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

    The "ground truth" for this 510(k) submission consists of technical specifications and performance measurements of both the proposed device and its predicate devices (some measured by Healthonics from predicate devices, some from predicate's 510(k) information). For example, electrical output measurements, timing values, pulse characteristics, current/power densities, and material compositions.

    8. The sample size for the training set

    This information is not applicable/not provided. There is no "training set" in the context of this device and submission type.

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

    This information is not applicable/not provided. There is no "training set" for this device.

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