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510(k) Data Aggregation
(150 days)
AMPCARE 50709 Series of cutaneous electrodes are intended to be used to apply electrical stimulation current to the patient's skin. Example electrical stimulation current applications of these electrodes are: a) Transcutaneous Electrical Nerve Stimulation (TENS) for pain relief, b) Electrical muscle stimulation (EMS) for neck muscle stimulation, c) Functional electrical stimulation (FES), d) Galvanic stimulation, e) Microcurrent electrical nerve stimulation (MENS), f) Interferential (IF) stimulation, and g) Neuromuscular electrical stimulation (NMES), including for muscle re-education by application of external stimulation to the muscles necessary for pharyngeal contraction.
The new AMPCARE 50709 Series Electrodes device is a family of cutaneous electrodes with various shapes and sizes, which are similar in design and construction to several predicate cutaneous electrodes. AMPCARE electrodes are non-sterile, self-adhering, and are for multiple use by a single patient, available with either pin/socket or snap connections. The new AMPCARE device is designed in accordance with the general design approach of the predicate devices referenced above. Specifically, each electrode in the AMPCARE 50709 Series is constructed with a non-conductive top layer, conductive center layer and adhesive bottom layer. The plastic liner at the bottom of the electrode is peeled away just prior to placement on the patient, consistent with the four predicate devices. The pin/socket connector version of the new device will be provided with a lead wire that is 21 CFR 898 compatible, containing a female recessed socket for electrical connection.
The provided document is a 510(k) summary for the AMPCARE 50709 Series Electrodes, which are cutaneous electrodes. This device is a Class II medical device, and the submission focuses on demonstrating substantial equivalence to predicate devices rather than proving a new clinical claim or performance. Therefore, the details requested in the prompt, which are typically associated with performance studies for algorithms or diagnostic devices, are not fully applicable to this type of submission.
However, I can extract the information relevant to the non-clinical testing performed to establish substantial equivalence.
Here's a breakdown based on the provided text, addressing the prompt's points where applicable:
1. Table of Acceptance Criteria and Reported Device Performance
For this 510(k) submission, the "acceptance criteria" are implied to be the performance demonstrated by the predicate devices. The "reported device performance" refers to the AMPCARE electrodes' performance in comparison to these predicates during non-clinical testing to demonstrate substantial equivalence.
Performance Characteristic | Acceptance Criteria (Implied by Predicate Devices) | Reported Device Performance (AMPCARE 50709 Series) |
---|---|---|
Current Distribution | Uniform current distribution with no evidence of "hot spots" (as demonstrated by predicates) | Uniform current distribution with no evidence of "hot spots" |
Electrical Impedance | Comparable to predicate device electrodes | Comparison testing performed; demonstrated suitability for use |
Electrical Impedance Uniformity | Comparable to predicate device electrodes | Comparison testing performed; demonstrated suitability for use |
Suitability for Electrical Stimulation Applications | Suitable for applications like TENS, EMS, FES, Galvanic, MENS, IF, NMES (as demonstrated by predicates) | Demonstrated suitability of use for each example of electrical stimulation current applications |
2. Sample size used for the test set and the data provenance:
The document does not specify the sample size for the test set (number of AMPCARE electrodes tested) or the data provenance (country of origin, retrospective/prospective). It only mentions "AMPCARE electrodes" generally.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
This information is not applicable to this type of non-clinical, substantial equivalence testing for a cutaneous electrode. There's no "ground truth" established by experts in the context of diagnostic or algorithmic performance. The testing involved physical and electrical properties of the electrodes.
4. Adjudication method for the test set:
This information is not applicable for the same reasons as point 3.
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:
This information is not applicable. MRMC studies are relevant for diagnostic devices or AI algorithms where human interpretation is involved. This submission is for a physical electrode.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
This information is not applicable. This is not an algorithm or AI device.
7. The type of ground truth used:
For non-clinical testing of electrodes, the "ground truth" is typically defined by objective physical and electrical measurements (e.g., current distribution, impedance values) that meet established engineering standards or comparisons to legally marketed predicate devices. It is not expert consensus, pathology, or outcomes data in this context.
8. The sample size for the training set:
This information is not applicable. There is no "training set" as this is not an algorithmic or AI device requiring machine learning.
9. How the ground truth for the training set was established:
This information is not applicable for the same reasons as point 8.
Summary of Non-Clinical Testing Performed (from the document):
- Dispersion testing: Demonstrated "uniform current distribution with no evidence of 'hot spots'." This testing included predicate devices (Columbia K080386 and Uni-Patch K915333) for comparison.
- Electrical impedance testing: Performed on AMPCARE electrodes and predicate devices to demonstrate substantial equivalence and suitability for various electrical stimulation applications.
- Electrical impedance uniformity testing: Performed on AMPCARE electrodes and predicate devices to demonstrate substantial equivalence.
The conclusion of the submission is that AMPCARE considers its electrodes to be "substantially equivalent" to the predicate devices based on similarities in primary intended use, principles of operation, functional design, nonclinical test results, and established medical use. The FDA's letter concurs with this substantial equivalence determination.
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