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510(k) Data Aggregation

    K Number
    K160138
    Date Cleared
    2016-08-11

    (203 days)

    Product Code
    Regulation Number
    882.1320
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K092546, K132998

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

    The Adhesive Electrodes are intended for use as a reusable, conductive adhesive interface between the patient's skin and the marketed electrical stimulators (i.e. TENS (Transcutaneous Electrical Nerve Stimulation), EMS (Electrical Muscular Stimulation), IF (Interferential) or PGF (Pulsed Galvanic Stimulation) for transmitting electrical current. The electrode is for OTC (Over-The-Counter) or Prescription use.

    Device Description

    Adhesive Electrodes manufactured by GMDASZ are multi-layer reusable, flexible structures composed of laminated materials commonly used in this application:

    First layer: Insulating backing material: Fabric/foam/tan fabric
    Second layer: Conductive film/Carbon film coated with silver/Aluminum foil film
    Third layer: Biocompatible self-adhesive conductive hydrogel
    Protective liner: PET

    The electrodes are designed for single-patient/multiple application use. Because of the adhesive nature of the biocompatible conductive hydrogel, no securing materials are required to secure the device to the patient's skin. The electrode is connected to the electrical stimulator by lead wire, with a standard .080" recessed female terminal with insulating outer jacket. By design, the insulated outer jacket prevents the conductive connection to earth or hazardous voltages. Wire assembly is incompliance with FDA performance standard 21 CFR Part 898.

    AI/ML Overview

    This document is a 510(k) premarket notification for "Adhesive Electrodes" manufactured by GMDASZ Manufacturing Co., Ltd. The submission seeks to expand the sales of their existing electrodes (previously cleared under K092546) to include Over-The-Counter (OTC) use, and also introduces new electrodes with an Aluminum foil film conductive layer, comparing them to the predicate device K132998 (Wandy self-adhesive electrodes).

    Here's an analysis of the acceptance criteria and study information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly present a "table of acceptance criteria." Instead, it compares the subject device's performance against two predicate devices (K092546 and K132998) across various technical specifications, which implicitly serve as acceptance criteria. The key performance metrics and their comparison are:

    Acceptance Criteria (Implied from Predicate Devices)Reported Device Performance (K160138)Comparison/Remark
    Material/Design Features:
    Insulation backing material: Fabric/Foam/Tan fabricSame: Fabric/Foam/Tan fabricSame
    Conductive film (K092546 D-pred): Carbon film/Carbon film coated with silverCarbon film/Carbon film coated with silver/Aluminum foil filmSimilar; new option of Aluminum foil film, justified by K132998 predicate.
    Conductive hydrogel (A, T or U gel)Same: (A, T or U gel)Same
    Electrical Connection: LeadwireLeadwireSame or Similar. Some K132998 models had snap, but subject device uses leadwire.
    Protective Liner: PETPETSame
    Lead Wire Connector: .080" female socket connector.080" female socket connectorSame
    ReusableReusableSame
    Packaging: Re-sealable bag packedRe-sealable bag packedSame
    Self-adhesiveSelf-adhesiveSame
    Performance Characteristics:
    Biocompatibility: Complies with ISO10993Complies with ISO10993Same. For new aluminum foil models, no new tests were conducted as materials for other layers were identical to K092546.
    A.C. Impedance: 6 pounds of forceMore than 6 pounds of forceSame
    Regulatory/Indications:
    OTC or Prescription use (K092546 Pred: Prescription, K132998 Pred: OTC & Rx)OTC and PrescriptionExpanded from K092546, aligned with K132998.
    Single Patient UseSingle Patient UseSame

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

    The document does not specify the sample size for any conducted tests.
    The data provenance is from GMDASZ Manufacturing Co., Ltd., which is based in Guangdong Province, P.R. China. The studies appear to be prospective testing conducted by the manufacturer to demonstrate substantial equivalence.

    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 applicable/not provided. The device is an adhesive electrode, and the evaluation relies on technical and performance testing against established standards and predicate devices, not on expert interpretation of medical images or conditions where "ground truth" is typically established by medical professionals.

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

    This information is not applicable/not provided. Adjudication methods like "2+1" or "3+1" are typically used in clinical studies or image interpretation studies where multiple readers assess cases and discrepancies are resolved. The studies described here are laboratory/performance tests.

    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/not provided. An MRMC study is for evaluating diagnostic performance, often with AI. The device is a medical accessory (adhesive electrode) and is not an AI diagnostic tool.

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

    This information is not applicable/not provided. This device is an electrode, not an algorithm. Therefore, "standalone" algorithm performance is not relevant. The device's performance is inherently tied to its physical and electrical properties.

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

    The "ground truth" for the performance tests appears to be established industry standards (e.g., EC12/EC53, ISO10993) and the documented performance characteristics of legally marketed predicate devices. The tests conducted (safety, adhesion, current dispersion, reusability, stability) evaluate whether the device meets these pre-defined technical specifications.

    8. The sample size for the training set

    This information is not applicable/not provided. This medical device is a physical product (electrode) and does not involve machine learning or AI models that require a "training set."

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

    This information is not applicable/not provided, as there is no training set for this type of device.

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