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510(k) Data Aggregation

    K Number
    K162392
    Device Name
    Avazzia
    Manufacturer
    Date Cleared
    2017-05-12

    (259 days)

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

    K062641, K123099, K060222

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

    Transcutaneous Electrical Nerve Stimulation (TENS) for the temporary relief of pain associated with sore and aching muscles in the shoulder, waist, back of the neck, upper extremities (arm), and lower extremities (leg) due to strain from exercise or normal household work activities.

    Device Description

    Avazzia OTC TENS electronic pulse massage devices are electrically powered device intended for overthe-counter use and used to apply a microcurrent electrical pulses to electrodes on a user's skin to relieve pain. They are easy-to-use, handheld, AA battery-operated portable devices for use in the home or clinic. The candidate devices have pre-set modes. The devices are portable, battery operated microcurrent electrical stimulation device that applies charge and power to the tissue through electrodes where maximum power delivered to the load is controlled and limited, and an automatic shut off is implemented. The user can apply the built-in onboard electrodes or place self-adhesive conductive electrodes where indicated and apply stimulation for a period of time. The user controls the output by selecting the mode and power setting.

    AI/ML Overview

    This document is a 510(k) premarket notification for the Avazzia OTC TENS Model Best-AV1™ family of devices. This type of submission focuses on demonstrating substantial equivalence to a legally marketed predicate device rather than conducting a full clinical trial with acceptance criteria for device performance. Therefore, directly answering all your questions about acceptance criteria and a study proving the device meets them, in the typical sense of a diagnostic or therapeutic study, is not applicable to this document.

    However, I can extract the information related to safety and performance from the perspective of substantial equivalence.

    Here's an analysis based on the provided document:

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

    Since this is a 510(k) submission for a TENS device, the "acceptance criteria" are primarily established by demonstrating that the new device (candidate) has similar technological characteristics and performance specifications to a predicate device that has already been cleared by the FDA, and that it does not raise new questions of safety or effectiveness. The reported device performance is presented as a comparison to the predicate.

    CharacteristicAcceptance Criteria (Predicate Device K122744)Reported Device Performance (Avazzia OTC TENS)
    Power SourceFour 1.5 V AAA batteriesTwo 1.5 V AA batteries
    Patient Leakage Current (Normal Condition)1.8 µA13.7 µA
    Patient Leakage Current (Single Fault Condition)3.3 µA27 µA
    Avg DC current through electrodes (no pulses)0 µA0 µA
    Number of output modes32, 4
    Number of output channelsSynchronous1 (Synchronous/Alternating = n/a)
    Regulated Current or VoltageVoltage controlVoltage control
    Software controlYesYes
    Automatic Overload Trip?NoNo
    Automatic No-Load Trip?NoYes
    Automatic Shut Off?YesYes
    User Override Control?YesYes
    Indicator Display: On/Off Status?YesYes
    Indicator Display: Low Battery?NoYes
    Indicator Display: Voltage/Current intensity?NoYes
    Timer Range5, 10, or 15 minutes60 minutes
    Compliance with Voluntary Standards?YesYes
    Compliance with 21 CFR 898YesYes
    Weight8 OZ7 OZ
    Dimensions2.2 x 7.8 x 0.9 In4.6 x 2.5 x 1.3 In
    Housing materials and constructionEnclosure: ABSEnclosure: ABS
    WaveformMonophasicBiphasic (positive square wave followed by a damped sinusoidal waveform)
    ShapeRegularPositive square wave followed by a damped sinusoidal waveform of variable duration depending on damping and body loading
    Max output voltage at 500 Ω12.8 V-42 V
    Max output voltage at 2,000 Ω51 V-122 V
    Max output voltage at 10,000 Ω368 V-348 V
    Max output current at 500 Ω15,000 µA3080 µA
    Max output current at 2,000 Ω3,200 µA451 µA
    Max output current at 10,000 Ω600 µA535 µA
    Duration of primary (depolarizing phase)0.040 µSec506 µSec
    Pulse Duration120 to 6800 µSec1100 µSec
    Frequency1 to 100 Hz20 to 185 Hz
    Net Charge per pulse at 500 Ω18,000 µC4.0 µC
    Max Charge per pulse at 500 Ω23 µC10.12 µC
    Max current density at 500 Ω1.4 mA/cm²1.6 mA/cm²
    Max average power density at 500 Ω230 mW/cm²2.445 mW/cm²
    Burst mode: pulses per burst1Up to 8
    Burst mode: burst per second0-25Up to 77
    Burst mode: burst duration1 secUp to 6 mSec
    Burst mode: Duty Cycle546%
    On TimePotentiometer switch0.46 Sec
    Off timePotentiometer switch0.54 Sec

    Study Proving Acceptance Criteria:

    The document states: "Verification and validation tests as well as certificates and test reports contained in this submission demonstrate that the submitted models are substantially equivalent to the safety and effectiveness as that of the cleared devices."

    Specifically, it mentions:

    • "The software verification is conducted according to the Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices – Guidance for Industry and FDA Staff – May 11, 2005."
    • "The candidates devices and accessories meet general safety requirements IEC 60601-1 and requirements EMC: IEC 60601-1-2."

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

    This document does not describe a clinical trial or performance study with a "test set" of human subjects or patient data in the typical sense of evaluating a diagnostic or therapeutic performance. The "test set" here refers to the device itself undergoing engineering and safety testing. The provenance of this engineering test data is not explicitly stated beyond being part of the submission by Avazzia, Inc. in Dallas, Texas, USA. These tests are typically conducted in a laboratory setting.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    Not applicable. This is not a study that involved human experts establishing ground truth for a diagnostic or clinical outcome. The "ground truth" for the engineering performance and safety tests would be the established international standards (IEC 60601-1, IEC 60601-1-2) and the technical specifications of the predicate device.

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

    Not applicable. This is not a study involving expert adjudication of clinical findings.

    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 Transcutaneous Electrical Nerve Stimulator (TENS) for pain relief, not an AI-assisted diagnostic or imaging device used by human "readers."

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

    Not applicable. This is a medical device, not a standalone algorithm in the AI sense. The device's performance is inherently "standalone" in that its electrical output is measured without human intervention in the primary performance tests, but it is used by a human.

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

    The "ground truth" for this 510(k) submission is based on:

    • Engineering Standards: Compliance with international safety and electromagnetic compatibility standards (IEC 60601-1, IEC 60601-1-2).
    • Predicate Device Specifications: The technical and performance characteristics of the previously cleared predicate device (Prospera OTC TENS Electronic Pulse Massager, Models PL009, PL009A, and PL029, K122744). The new device is deemed substantially equivalent if its performance is similar or better, and it doesn't introduce new safety concerns.
    • Software Verification: Adherence to FDA guidance for software in medical devices.

    8. The sample size for the training set

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

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

    Not applicable. As there is no training set for a machine learning algorithm, there is no ground truth established for it.

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    K Number
    K071878
    Date Cleared
    2007-12-07

    (154 days)

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

    K042912, K053626, K062641

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

    For symptomatic relief and management of chronic, intractable pain, and adjunctive treatment in the management of post-surgical and posttraumatic acute pain.

    Device Description

    Delta Scanner devices are micro-current transcutaneous electro-stimulation devices for symptomatic relief and management of chronic, intractable pain, and as adjunctive treatment in the management of post-traumatic and post surgical pain. They are handheld, easy-to-use battery operated portable devices, for use in the home or clinic. The technological characteristics of these devices, including waveforms, outputs, and impedance sensing functions are the same as the InterX 5000™ and the Avazzia Best ProTM

    AI/ML Overview

    The provided text is a 510(k) summary for the Med-Lectric Corporation's Delta Scanner devices. This type of submission focuses on demonstrating substantial equivalence to predicate devices rather than conducting new clinical trials with acceptance criteria and performance metrics described in the way a de novo or PMA submission would.

    Therefore, the document does not contain the information requested regarding acceptance criteria and a specific study proving the device meets them, as it relates to performance benchmarks (e.g., sensitivity, specificity, accuracy).

    Here's why the information is not present and what the document does state:

    • Acceptance Criteria & Reported Device Performance: This information is not explicitly stated in the context of a performance study for the Delta Scanner devices. The submission claims substantial equivalence based on technological characteristics and intended use matching predicate devices. The document implies that the "acceptance criteria" are met if the new device's characteristics are similar enough to existing cleared devices.
    • Study That Proves the Device Meets Acceptance Criteria: There is no specific clinical study described that proves the Delta Scanner devices meet quantitative performance acceptance criteria in terms of efficacy or safety beyond demonstrating substantial equivalence to predicate devices. The submission mentions "verification and validation tests" but provides no details on their methodology, results, or how they relate to specific performance metrics.

    Breakdown of what can be extracted or inferred from the provided text, and what is explicitly missing:

    1. Table of Acceptance Criteria and Reported Device Performance:

      • Acceptance Criteria (Inferred): Substantial equivalence to predicate devices (InterX5000™, K042912, K053626; Body-Stim™, Biomodulator™, Best-RSI™, Best Pro™, K062641). Specifically, "technological characteristics... including waveforms, outputs, and impedance sensing functions are the same as the InterX 5000™ and the Avazzia Best ProTM." Also, the "intended uses" are the same.
      • Reported Device Performance: Not mentioned in terms of quantitative clinical outcomes or performance metrics (e.g., pain reduction percentage, adverse events rate, etc.) for the Delta Scanner itself, beyond the claim of substantial equivalence to predicate devices which are presumed to be safe and effective.
    2. Sample size used for the test set and the data provenance: Not applicable. No clinical test set or data provenance is detailed for this 510(k) submission.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. No ground truth establishment for a test set is detailed.

    4. Adjudication method for the test set: Not applicable.

    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 TENS device, not an AI-based imaging or diagnostic tool that involves human readers.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable. This device is a TENS device, not an algorithm.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.): Not applicable to this type of submission. The "ground truth" for a 510(k) is the established safety and effectiveness of the predicate devices.

    8. The sample size for the training set: Not applicable. No training set is detailed.

    9. How the ground truth for the training set was established: Not applicable.

    Conclusion from the document:

    The 510(k) summary for the Delta Scanner devices relies on demonstrating "substantial equivalence" to already cleared devices. The "verification and validation tests" mentioned are general statements regarding software compliance and overall device equivalence, rather than detailed clinical performance studies with specific acceptance criteria and results for the new device itself.

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