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510(k) Data Aggregation

    K Number
    K190115
    Device Name
    MHD TENS
    Date Cleared
    2019-06-19

    (146 days)

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

    K152815, K121719

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

    Transcutaneous Electrical Nerve Stimulation (Program 2, 3, 4, 6, 8, 9): To be used for temporary relief of pain associated with sore and aching muscles in the shoulder, waist, back, upper extremities (arm), and lower extremities (leg) due to strain from exercise or normal household work activities. Powered Muscle Stimulation (Program 1, 5, 7, 10, 11, 12): It is intended to be used to stimulate healthy muscles in order to improve and facilitate muscle performance.

    Device Description

    MHD TENS is portable and DC 3.7V battery powered device, offering both transcutaneous electrical nerve stimulator (TENS) and powered muscle stimulator (PMS) qualities in one device. MHD TENS has 12 operation programs, which can give certain electrical pulses through electrode adhesive pads to the suggested area of the body where the electrodes are placed. The electronic stimulatory module has the operating elements of Switch, LCD Display screen, Screen lock key, Intensity Modification keys, Timing key, Output sockets, and USB port for battery charging. The LCD screen can display treatment remaining time, battery power, selected program, output port, current intensity, selected intensity and lock state. The device is equipped with accessories of electrode pads, electrode cables, a screen stylus, a battery charger and a USB cable. The electrode cables are used to connect the pads to the device; the USB cable is used to connect the AC charger and the built-in lithium battery. The screen stylus is used to touch and operate the display screen. All accessories, including the USB cable, electrode pads, electrode cables, and the charger can only be replaced by the electrodes are interchangeable. The application area of electrode pads must be larger than 12cm². The electrode pads are provided by Shenzhen Mailuokang Technology Co., Ltd. with 510(k) cleared Number K152815.

    AI/ML Overview

    This FDA 510(k) summary describes the MHD TENS device and establishes its substantial equivalence to a predicate device (K143268). The provided document does not contain information about a study proving the device meets acceptance criteria in the manner typically expected for AI/ML device performance (e.g., clinical study with human readers, ground truth establishment, etc.). This is because the MHD TENS is a physical electrical stimulation device, not an AI/ML diagnostic or therapeutic system.

    Instead, the "acceptance criteria" for a device like the MHD TENS are compliance with recognized electrical safety and performance standards, and comparison with a legally marketed predicate device to demonstrate substantial equivalence. The "study" proving it meets these "acceptance criteria" consists of engineering tests and comparisons to the predicate.

    Here's the information extracted and formatted, noting where AI/ML-specific criteria are not applicable:


    Acceptance Criteria and Device Performance for MHD TENS

    Device Name: MHD TENS
    510(k) Number: K190115
    Predicate Device: K143268

    1. Table of Acceptance Criteria (as indicated by comparison to predicate and safety standards) and Reported Device Performance

    Acceptance Criteria (Implied by Predicate Comparison & Standards)Reported Device Performance (MHD TENS)Note from document regarding comparison to predicate
    Intended Use:
    - Temporary pain relief for sore/aching musclesTo be used for temporary relief of pain associated with sore and aching muscles in the shoulder, waist, back, upper extremities (arm), and lower extremities (leg) due to strain from exercise or normal household work activities.Same
    - Stimulate healthy muscles to improve performanceIt is intended to be used to stimulate healthy muscles in order to improve and facilitate muscle performance.Same
    Electrical Safety & Performance (via Standards):
    Patient Leakage Current (Normal Condition)
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    K Number
    K170205
    Date Cleared
    2017-05-11

    (108 days)

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

    K152815

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

    To be used for temporary relief of pain associated with sore and aching muscles in the shoulder, waist, back, arm, leg and foot, due to strain from exercise or normal household and work activities

    Device Description

    The Low-Frequency Therapy Instrument is a product that adopts modern electronic science and technology to produce low-frequency electrical pulse and transmit that through the skin to the underlying peripheral nerves by electrodes, in order to reach the therapeutic aim.

    There are three models of Low-Frequency Therapy Instrument which are KTR-201, KTR-202, KTR-203. Their technical parameters are slightly different, but they share the basically same characteristics: 1) They are small, and exquisite; 2) they have different treatment modes which can satisfy various demands, thus can be used by a wider range of people; 3) LCD display with a big screen makes the operation easy and clear, and the contents displayed on LCD can guide the treatment.

    The Low-Frequency Therapy Instrument is mainly composed of the host and electrode patches and it uses AAA batteries for power supply. To start therapy, first insert batteries, then paste the electrode patches onto treatment areas and press power button to turn the power on. The modes and intensity can be selected according to needs. The current status is displayed on LCD.

    AI/ML Overview

    This FDA 510(k) submission describes the "Low-Frequency Therapy Instrument" (Models: KTR-201, KTR-202, KTR-203), a Transcutaneous Electrical Nerve Stimulator (TENS) for pain relief.

    Here's an analysis of the acceptance criteria and supporting studies based on the provided document:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly present a table of acceptance criteria with corresponding performance metrics. Instead, the acceptance is implied by demonstrating substantial equivalence to a predicate device (Shenzhen OSTO Technology Company Limited's Health Expert Electronic Stimulator, Model AST-300C and AST-300D, K133929) and compliance with relevant voluntary standards.

    The "Technological characteristics and substantial equivalence" table (pages 5-6) serves as the core comparison for "performance." Key metrics and their comparison to the predicate are:

    ParameterSubject Device (K170205)Primary Predicate (K133929)Remark / Implied Acceptance
    Indications for UseTemporary pain relief for sore/aching muscles (shoulder, waist, back, arm, leg, foot) due to strain from exercise/normal activities.Temporary pain relief for sore/aching muscles (shoulder, waist, back, back of the neck, arm, leg, foot) due to strain from exercise/normal activities by applying current to stimulate nerve.Similar. The subject device's indications are slightly narrower (omitting "back of the neck"), but fundamentally the same therapeutic area and type of pain relief. Implied acceptance: performs a similar therapeutic function for similar conditions.
    Regulation Number21 CFR 882.589021 CFR 882.5890Identical. Implied acceptance: operates under the same regulatory classification.
    Product CodeNUHNUH, NGXSimilar. NUH is shared, indicating the core function. Implied acceptance: fits the same product category.
    ClassClass IIClass IIIdentical. Implied acceptance: same regulatory class.
    OTC/RxOTCOTCIdentical. Implied acceptance: same intended availability.
    Power SupplyKTR-201: DC 3V, 30 mA; KTR-202: DC 4.5V, 100 mA; KTR-203: DC 3V, 30mA100-240VAC, 50-60Hz, 0.1ADifferent. Predicate is mains-powered. Remark states: "Predicate is powered by mains supply but does not affect safety and effectiveness of subject device." Implied acceptance: different power source does not compromise safety/effectiveness.
    Output ModesKTR-201: 10; KTR-202: 10; KTR-203: 525Identical. (This remark seems incorrect; the numbers are different for all subject models compared to the predicate's 25. It should likely state "Similar" or "Different but does not affect...") Implied acceptance: sufficient modes for therapy.
    Output ChannelsKTR-201: 1; KTR-202: 1; KTR-203: 22Similar. Remark states: "Does not affect safety and effectiveness of subject device." Implied acceptance: sufficient channels for therapy.
    Timer Range15 mins25 minsDifferent. Remark states: "Different but does not affect safety and effectiveness of subject device." Implied acceptance: sufficient timer for therapy sessions.
    WaveformPulsed symmetric, biphasic, square wavePulse symmetric, biphasic, rectangular with interphase intervalSimilar. Implied acceptance: provides therapeutically similar electrical stimulation.
    Max Output Voltage44V@500ohm, 58V@2kohm, 63.5V@10kohm44V±10% @500ohm, 80V±10% @2kohm, 112V±10@10kohmSimilar. Implied acceptance: within acceptable therapeutic range.
    Max Output Current88mA@500ohm, 29mA@2kohm, 6.35mA@10kohm88mA±10% @500ohm, 40mA±10% @2kohm, 11.2mA±10% @ 10kohmSimilar. Implied acceptance: within acceptable therapeutic range.
    Net Charge (per pulse)0µC @500ohm0µC @500ohmIdentical. Important for safety to prevent DC component. Implied acceptance: safe.
    Max Phase Charge11.7µC @500ohm12.78μC@500ohmSimilar. Implied acceptance: therapeutically comparable and safe.
    Max Average Current (500ohm)7.4mA0.968mADifferent. Remark states: "Although the maximum average current is different, it is
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