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510(k) Data Aggregation

    Why did this record match?
    Reference Devices :

    K181688&180956

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

    Over-The-Counter Use:
    a. Model R-C101C is indicated for OTC TENS and OTC EMS. OTC TENS(NUH) It is used for temporary relief of pain associated with sore and aching muscles in the neck, shoulder, back, upper extremities (arm) and lower extremities (leg) due to strain from exercise or normal household work activities. OTC EMS(NGX) This mode is designed to be used for stimulate healthy muscles in order to improve and facilitate muscle performance.
    b. Model R-C101D is indicated for OTC TENS. It is used for temporary relief of pain associated with sore and aching muscles in the neck, shoulder, back, upper extremities (arm) and lower extremities (leg) due to strain from exercise or normal household work activities.
    c. Model R-C101F is indicated for OTC TENS and OTC EMS. OTC TENS(NUH) It is used for temporary relief of pain associated with sore and aching muscles in the neck, shoulder, back, upper extremities (arm) and lower extremities (leg) due to strain from exercise or normal household work activities. OTC EMS(NGX) This mode is designed to be used for stimulate healthy muscles in order to improve and facilitate muscle performance.
    d. Model R-C101G is indicated for OTC TENS and OTC EMS. OTC TENS(NUH) It is used for temporary relief of pain associated with sore and aching muscles in the neck, shoulder, back, upper extremities (arm) and lower extremities (leg) due to strain from exercise or normal household work activities. OTC EMS(NGX) This mode is designed to be used for stimulate healthy muscles in order to improve and facilitate muscle performance.
    e. Model F100 is indicated for OTC TENS and OTC EMS. OTC TENS(NUH) It is used for temporary relief of pain associated with sore and aching muscles in the neck, shoulder, back, upper extremities (arm) and lower extremities (leg) due to strain from exercise or normal household work activities. OTC EMS(NGX) This mode is designed to be used for stimulate healthy muscles in order to improve and facilitate muscle performance.
    f. Model MINI-TENS-COMB is indicated for OTC TENS. OTC TENS(NUH) It is used for temporary relief of pain associated with sore and aching muscles in the neck, shoulder, back, upper extremities (arm) and lower extremities (leg) due to strain from exercise or normal household work activities.
    g. Model R-C101I is indicated for OTC TENS. OTC TENS(NUH) It is used for temporary relief of pain associated with sore and aching muscles in the neck, shoulder, back, upper extremities (arm) and lower extremities (leg) due to strain from exercise or normal household work activities.
    h. Model TENS3500 is indicated for OTC TENS. OTC TENS(NUH) It is used for temporary relief of pain associated with sore and aching muscles in the neck, shoulder, back, upper extremities (arm) and lower extremities (leg) due to strain from exercise or normal household work activities.

    Prescription Use:
    a. Model R-C101D is indicated for Rx TENS. Rx TENS(GZJ) 1)Symptomatic relief of chronic intractable pain; 2)Post traumatic pain; 3)Post surgical pain;
    b. Model R-C101G is indicated for Rx TENS and Rx EMS. Rx TENS(GZJ) 1)Symptomatic relief of chronic intractable pain; 2)Post traumatic pain; 3)Post surgical pain; Rx EMS(IPF): 1)Relaxation of muscle spasm; 2)Increase of local blood flow circulation: 3)Prevention or retardation of disuse atrophy: 4)Muscle re-education: 5)Maintaining or increasing range of motion; 6)Immediate post-surgical stimulation of calf muscles to prevent venous thrombosis.
    c. Model R-C101C, is indicated for Rx TENS and Rx EMS. Rx TENS(GZJ) : 1)Symptomatic rlief of chronic intractable pain; 2)Post traumatic pain; 3)Post surgical pain; Rx EMS(IPF): 1)Relaxation of muscle spasm; 2)Increase of local blood flow circulation: 3)Prevention or retardation of disuse atrophy: 4)Muscle re-education: 5)Maintaining or increasing range of motion; 6)Immediate post-surgical stimulation of calf muscles to prevent venous thrombosis.
    d. Model F100 is indicated for Rx TENS and Rx EMS. Rx TENS(GZJ) : 1)Symptomatic relief of chronic intractable pain; 2)Post traumatic pain; 3)Post surgical pain; Rx EMS(IPF): 1)Relaxation of muscle spasm; 2)Increase of local blood flow circulation: 3)Prevention or retardation of disuse atrophy: 4)Muscle re-education: 5)Maintaining or increasing range of motion; 6)Immediate post-surgical stimulation of calf muscles to prevent venous thrombosis.
    e. Model MINI-TENS-COMB is indicated for Rx TENS. 1)Symptomatic relief of chronic intractable pain; 2)Post traumatic pain; 3)Post surgical pain;
    f. Model R-C101F is indicated for Rx TENS and Rx EMS. Rx TENS(GZJ) : 1)Symptomatic relief of chronic intractable pain; 2)Post traumatic pain; 3)Post surgical pain; Rx EMS(IPF): 1)Relaxation of muscle spasm; 2)Increase of local blood flow circulation: 3)Prevention or retardation of disuse atrophy: 4)Muscle re-education: 5)Maintaining or increasing range of motion; 6)Immediate post-surgical stimulation of calf muscles to prevent venous thrombosis.
    g. Model R-C101I is indicated for Rx TENS. Rx TENS(GZJ) : 1)Symptomatic relief of chronic intractable pain; 2)Post traumatic pain; 3)Post surgical pain;
    h. Model TENS3500 is indicated for Rx TENS. Rx TENS(GZJ) : 1)Symptomatic relief of chronic intractable pain; 2)Post traumatic pain; 3)Post surgical pain;

    Device Description

    Combo Electrotherapy Device (Model:R-C101C,R-C101F,R-C101G,F100,MINI-TENS-COMB,R-C1011, TENS3500) are Transcutaneous Electrical Nerve Stimulator and muscle stimulator The Device feature two independent output channels and four self-adhesive electrode gel pads. The stimulator sends gentle electrical current to underlying nerves and muscle group via electrode applied on the skin. They offer a wide range of functions for increasing general well- being, pain relief, maintaining physical fitness, relaxation.For these purpose, the user can either choose from pre-set programs or specify their own to suit the user's individual needs. Software controls all controls and indicators. Software controls waveform characteristics. The 8 models have Similar housing with a viewable LCD display,an accessible keypad.The LCD is located on the upper half of the rectangular face of the device, above the keypad. The LCD is used to display system information to the user. The device is battery powered and can be connected to an external power supply for charging the internal battery. The battery is 3.7V D.C.,Li-ion batteries and is not user serviceable or accessible. The only external connections on the device are the power input and the electrode connector there is no connection to any other device. The Battery Charger is not provided in the package, but users will choose adapters that meet the IEC 60601-1 medical standard.

    AI/ML Overview

    The provided document is a 510(k) Premarket Notification from the FDA, evaluating the substantial equivalence of the "Combo Electrotherapy Device" to existing predicate devices. It focuses on technical specifications and safety standards rather than clinical performance or acceptance criteria in the typical sense of a clinical trial. Therefore, many of the requested items (e.g., sample size for test set, number of experts for ground truth, MRMC study, training set sample size) are not applicable or detailed in this type of regulatory submission.

    However, I can extract information related to acceptance criteria as demonstrated by compliance with recognized standards and a comparison to the predicate devices' performance.

    The primary acceptance criteria for this device are demonstrated through compliance with recognized electrical safety and performance standards, as well as showing substantial equivalence to existing predicate devices in terms of intended use and technological characteristics.

    Here's a breakdown of the information that can be extracted from the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    Since this is a 510(k) submission, "acceptance criteria" are generally met by demonstrating compliance with applicable safety standards and showing that any differences from predicate devices do not raise new safety or effectiveness concerns. The "reported device performance" is primarily presented as a comparison to the predicate devices' specifications, along with statements of compliance to relevant IEC standards.

    Acceptance Criterion (via Standard/Compliance)Reported Device Performance (Subject Device K231423)Comparison to Predicate (K192087 & K181688&180956)Discussion/Outcome
    Patient Leakage CurrentNormal Condition: Patient Leakage Current (P): 5 uA; Patient Leakage Current with mains on the F-type applied parts (PM): 9 uA
    Single Fault Condition: Patient Leakage Current (P): 172 uA; Patient Leakage Current with mains on the F-type applied parts (PM): 132 uANormal Condition: Primary Predicate (K192087): 50uA (R-C3, R-C4A, R-C4C); 53uA (R-C4B, R-C4D)
    Reference Predicate (K181688&180956): 11.4 uA
    Single Fault Condition: Primary Predicate (K192087): 31uA (R-C3, R-C4A, R-C4C); 58uA (R-C4B, R-C4D)
    Reference Predicate (K181688&180956): 9.6uADifferent. However, stated to meet IEC 60601-1 requirements (less than 500 uA for Type BF applied parts under Single Fault Condition), demonstrating no new safety or effectiveness risks.
    Maximum Output Voltage (Vpp)@500Ω: 46.4
    @2KΩ: 94
    @10KΩ: 94Primary Predicate (K192087): @500Ω: 66.4; @2KΩ: 106; @10KΩ: 106
    Reference Predicate (K181688&180956): @500Ω: 30; @2KΩ: 108; @10KΩ: 108Different. However, stated that calculations for maximum current density and average power density meet safety limits and passed IEC 60601-2-10 tests.
    Maximum Output Current (mA)@500Ω: 92.8
    @2KΩ: 47
    @10KΩ: 9.4Primary Predicate (K192087): @500Ω: 132.8; @2KΩ: 53; @10KΩ: 10.6
    Reference Predicate (K181688&180956): @500Ω: 60; @2KΩ: 54; @10KΩ: 10.8Different. See discussion for Max Output Voltage.
    Pulse Width Range (uS)50-450uSPrimary Predicate (K192087): 150~300uS (R-C3, R-C4C, R-C4D); 55-300uS (R-C4A, R-C4B)
    Reference Predicate (K181688&180956): 100-380uSDifferent. Stated that it does not adversely impact safety and effectiveness.
    Frequency (Hz)2-150 HzPrimary Predicate (K192087): 2100Hz (R-C3, R-C4C, R-C4D); 2120Hz (R-C4A, R-C4B)
    Reference Predicate (K181688&180956): 1-125HzDifferent. Minor differences do not raise safety or effectiveness issues as per IEC 60601-2-10.
    Maximum Phase Charge (uC, 500Ω)2.73 (TENS mode); 2.73 (EMS mode)Primary Predicate (K192087) TENS: 0.15 (R-C3, R-C4C, R-C4D, R-C4A); 0.14 (R-C4B)
    Primary Predicate (K192087) EMS: 0.13 (R-C3, R-C4C, R-C4D); 0.15 (R-C4A, R-C4B)
    Reference Predicate (K181688&180956): 22.8 (both TENS/EMS)Different. However, Maximum Current Density for the subject device is lower than 2 mA/cm² (referencing IEC 60601-2-10 Clause 201.14.2) and the Maximum Average Power Density for Powered Muscle Simulator (0.25 Watts/cm²), concluding no new safety/effectiveness risks.
    Max Current Density (mA/cm², 500Ω, r.m.s)0.24Primary Predicate (K192087): 0.15
    Reference Predicate (K181688&180956): 2.4Different. See discussion for Maximum Phase Charge.
    Max. Average Current (mA)6.075 (TENS mode); 6.075 (EMS mode)Primary Predicate (K192087) TENS: 3.74 (R-C3, R-C4C, R-C4D, R-C4A); 3.46 (R-C4B)
    Primary Predicate (K192087) EMS: 3.36 (R-C3, R-C4C, R-C4D); 3.84 (R-C4A, R-C4B)
    Reference Predicate (K181688&180956): 16.8 (both TENS/EMS)Different. See discussion for Maximum Phase Charge.
    Maximum Power Density (W/cm², 500Ω, r.m.s)0.74 mW/cm² (TENS mode); 0.74 mW/cm² (EMS mode)Primary Predicate (K192087) TENS: 0.28 mW/cm² (R-C3, R-C4C, R-C4D, R-C4A); 0.24 mW/cm² (R-C4B)
    Primary Predicate (K192087) EMS: 0.23 mW/cm² (R-C3, R-C4C, R-C4D); 0.29 mW/cm² (R-C4A, R-C4B)
    Reference Predicate (K181688&180956): 0.072Different. The stated calculation indicates that the maximum average power density for the subject device is 0.74 mW/cm^2, which is less than the regulatory limit of 0.25 Watts/cm² (250 mW/cm²).
    Compliance with IEC 60601-1CompliantCompliantSame
    Compliance with IEC 60601-2-10CompliantCompliantSame
    Compliance with IEC 60601-1-2 (EMC)CompliantCompliantSame
    Compliance with IEC 60601-1-11CompliantCompliantSame
    BiocompatibilityCompliant with ISO 10993 (for self-adhesive electrodes)Same accessories as previously submitted (K222252)Same accessories, previously evaluated.
    Software Verification & ValidationDocumentation provided; "Moderate" level of concern.N/A (software details not provided for predicates, but generally accepted similar for Class II devices)Complies with FDA guidance.

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

    • Sample size: Not applicable. For a 510(k) submission based on technical equivalence, bench testing and compliance with standards are typically performed on representative units of the device itself, not a 'test set' of patient data in the clinical sense.
    • Data provenance: The tests performed are "Non-Clinical Data" and "Bench Testing," conducted to verify device specifications and compliance with standards. These are typically laboratory tests of the device. The manufacturing company is Shenzhen Roundwhale Technology Co., Ltd. in Longgang District, Shenzhen, China.

    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)

    • Not applicable. This is a technical and safety review of an electrotherapy device, not an image-based diagnostic or screening AI device requiring expert ground truth for a test set.

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

    • Not applicable. As above, this type of adjudication is for clinical or diagnostic studies, not for the technical bench testing described.

    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 an electrotherapy device, not an AI-assisted diagnostic tool for human readers.

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

    • Not applicable. The device is a physical electrotherapy device; its performance is independently verifiable through electrical measurements and safety standards compliance.

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

    • The "ground truth" for this submission are the recognized international and national standards (e.g., IEC 60601-1, IEC 60601-2-10, IEC 60601-1-2, IEC 60601-1-11, ISO 10993) and the specifications and performance of the legally marketed predicate devices. The testing confirmed that the subject device's performance aligned with these standards and was substantially equivalent to the predicate.

    8. The sample size for the training set

    • Not applicable. This is not an AI/ML device that requires a training set of data.

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

    • Not applicable. (See answer to point 8).
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