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510(k) Data Aggregation
(379 days)
EMS is used for:
- Relaxation of muscle spasms
- Prevention or retardation of disuse atrophy
- Increasing local blood circulation
- Muscle re-education
- Maintaining or increasing range of motion
- Immediate postsurgical stimulation of calf muscles to prevent venous thrombosis
TENS is used for:
- Symptomatic relief and management of chronic, intractable pain
- Post-surgical acute pain
- Post-trauma acute pain
EVE Synergy has Synergy handpiece (1EA), Pro handpiece (2EA), Micro cable, Tip (Ball type, T type, COMB type) and Power adaptor & cable.
EVE Synergy has Synergy mode and Pro mode.
Synergy mode has radio frequency and low frequency functions using a synergy handpiece. The Synergy handpiece has a temperature sensor, so the output is automatically turned off when the skin surface temperature exceeds 43℃.
Pro mode has low frequency function that uses the Pro handpiece with tip.
It should be noted that the device has radio frequency (RF Mode) indicated for relief of minor muscle aches and pain, relief of muscle spasm, temporary improvement of local blood circulation. This RF mode was previously reviewed by the FDA under K212253 and was cleared under regulation 21 CFR 878.4400 (Product code PBX). In the subject submission, there are no changes being proposed related to the RF Mode, and, hence, the review of the RF Mode is not within the scope of the subject 510(k) submission.
The provided text is a 510(k) clearance letter and an accompanying 510(k) summary for the EVE Synergy (EVE-20M) device. This document focuses on demonstrating substantial equivalence to previously cleared predicate devices, rather than proving the device meets specific acceptance criteria through a comparative effectiveness study involving AI assistance or human-in-the-loop performance.
Therefore, many of the requested details regarding acceptance criteria for AI performance, specific study designs (MRMC, standalone), ground truth establishment for AI training/test sets, and sample sizes for these, are not present in this type of regulatory submission. This document primarily describes the physical and electrical characteristics of the device and compares them to predicate devices, along with standard electrical safety, EMC, and software validation testing.
Here's a breakdown of the requested information based on the provided text, highlighting what is present and what is not:
1. A table of acceptance criteria and the reported device performance
The document does not present "acceptance criteria" in the traditional sense of a specific performance metric (like accuracy, sensitivity, specificity) for a clinical outcome or an AI model's performance. Instead, it demonstrates compliance with safety and performance standards and similarity to predicate devices.
The "acceptance criteria" are implicitly met by showing:
- Compliance with various IEC standards (IEC 60601-1, IEC 60601-1-2, IEC 60601-2-10, IEC 62304) for electrical safety, EMC, and software.
- The device's technical specifications (e.g., output voltage, current, pulse width, frequency, power density) are comparable to or within the safe limits established by the predicate devices.
Table of Performance (extracted from comparison tables):
| Characteristic | Acceptance Criteria (Implied by Predicate & Standards) | EVE Synergy (EVE-20M) Reported Performance |
|---|---|---|
| General Compliance | Compliance with IEC 60601-1, IEC 60601-1-2, IEC 60601-2-10, ISO 14971, IEC 60601-1-6, IEC 62304 | Passed all testing in accordance with internal requirements, national standards, and international standards. |
| Device Configuration | Similar design, components, and method of current isolation to predicates. | Consists of AC/DC power supply, controller, LCD touch screen; Supports Synergy and Pro handpieces; Independent transformer isolation; Type BF Electrical Type. |
| Electrical Safety | Patient Leakage Current – Normal Condition: <100uA; Single Fault Condition: <300uA; Automatic Overload/No Load Trip; Automatic Shut Off. | Patient Leakage – Normal: <100uA; Single Fault: <300uA; Automatic Overload Trip: Yes; Automatic No Load Trip: Yes; Automatic Shut Off: Yes. |
| Biocompatibility | User-contacting materials (Stainless Steel 304, Polycarbonate) comparable to previously cleared devices. | Electrodes (SUS 304), LED Display part (PC) are the same as previously cleared K212253; Contact duration: Limited (< 24 hours). |
| EMS Mode Output | ||
| Waveform | Symmetrical Biphasic Waveform | Symmetrical Biphasic Waveform |
| Pulse Shape | Rectangular | Rectangular |
| Max Output Voltage | Comparable to predicates (e.g., Primary Predicate: 30V@500Ω, 54V@2kΩ, 54V@10kΩ; Secondary Predicate: 56V at all). Minor differences acceptable if safety demonstrated. | 34V@500Ω, 48V@2kΩ, 48V@10kΩ. "Similar to predicate devices". |
| Max Output Current | Comparable to predicates (e.g., Primary Predicate: 60mA@500Ω, 27mA@2kΩ, 5.4mA@10kΩ; Secondary Predicate: 92.86mA@500Ω, 26.7mA@2kΩ, 5.4mA@10kΩ). | 68mA@500Ω, 24mA@2kΩ, 4.8mA@10kΩ. "Similar to predicate devices". |
| Pulse Width | Within predicate range (20 to 400 μs). | 100 to 155 μs. "Within the range of the predicate devices". |
| Frequency | 3 to 200 Hz | 3 to 200 Hz |
| Net Charge @ 500 Ohms | 0 μC/pulse | 0 μC/pulse |
| Max Phase Charge | Within predicate range (e.g., Primary Predicate: 1.2 μC to 24 μC). | 10.54 μC@500Ω. "Within the range of the predicate device". |
| Max Current Density | ≤ 2 mA/cm² (IEC 60601-2-10). | 1.31 mA/cm² (Surface = 6 cm²). "Does not exceed the safety level 2 mA/cm²". |
| Max Power Density | Comparable to predicates (e.g., Primary Predicate: 22.2 mW/cm²; Secondary Predicate: 55 mW/cm²). | 47 mW/cm² @ 500Ω. "Similar to the predicate devices". |
| Burst Mode Parameters | Pulses/burst: 3-200; Bursts/sec: 1; Burst duration: 1-60 sec; Duty Cycle: Time on/off. | Pulses/burst: 3-200; Bursts/sec: 1; Burst duration: 1-60 sec; Duty Cycle: Time on/off. |
| On/Off Time | 1-60 seconds | 1-60 seconds |
| Treatment Time | Up to 60 minutes | Up to 60 minutes |
| TENS Mode Output | ||
| Waveform | Symmetrical Biphasic Waveform, Pulsed Monophasic (present in cleared predicate devices). | Symmetrical Biphasic Waveform, Pulsed Monophasic. "Does not raise new questions about safety and effectiveness." |
| Pulse Shape | Rectangular | Rectangular |
| Max Output Voltage | Comparable to predicates (e.g., Primary Predicate: 19V; Secondary Predicate: 36V). Minor differences acceptable if safety demonstrated. | 10V @500Ω, 10V @2kΩ, 10V @10kΩ. "Similar to those of the primary predicate device... does not raise new questions about safety and effectiveness." |
| Max Output Current | Comparable to predicates (e.g., Primary Predicate: 38mA@500Ω; Secondary Predicate: 67.8mA@500Ω). | 20mA@500Ω, 5.0mA@2kΩ, 1.0mA@10kΩ. (Note: Comparison comments for Voltage apply here as well). |
| Pulse Width | Within predicate range (20 to 400 μs). | 100 to 150 μs. "Within the range of the predicate devices". |
| Frequency | 3 to 200 Hz | 3 to 200 Hz |
| Net Charge @ 500 Ohms | 0 μC/pulse | 0 μC/pulse |
| Max Phase Charge | Within predicate range (e.g., Primary Predicate: 0.76 μC to 15.2 μC). | 3.0 μC@500Ω. "Within the range of the predicate device". |
| Max Current Density | ≤ 2 mA/cm² (IEC 60601-2-10). | 0.83 mA/cm² (Surface = 6 cm²). "Does not exceed the safety level 2 mA/cm²". |
| Max Power Density | Comparable to predicates (e.g., Primary Predicate: 8.9 mW/cm²; Secondary Predicate: 17.3 mW/cm²). | 8.3 mW/cm² @ 500Ω. "Similar to the primary predicate device". |
2. Sample sizes 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 test set or data derived from human subjects. The testing described is non-clinical bench testing:
- Electrical safety tests
- Electromagnetic compatibility tests
- Performance tests (measuring output parameters against specifications)
- Software verification and validation
- Usability testing (presumably, for the device's user interface, not clinical user performance)
There is no mention of "country of origin for data" or "retrospective/prospective" as these are not relevant to bench testing for device parameters.
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 is not applicable. "Ground truth" in the context of AI or clinical diagnostic studies (e.g., for radiologists interpreting images) is not established or referenced here because this is a physical medical device (muscle stimulator) undergoing bench testing for safety and performance specifications, not an AI diagnostic tool.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set
Not applicable. There are no clinical or image-based test sets requiring adjudication by experts.
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 muscle stimulator, not an AI-assisted diagnostic tool. No MRMC study was performed or required for this type of submission.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done
Not applicable. There is no AI algorithm being cleared as a standalone device. The "software validation testing" mentioned (IEC 62304) relates to the safe and effective operation of the device's inherent control software, not an AI-driven clinical function.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
Not applicable in the context of AI or clinical ground truth. For this submission, "ground truth" implicitly refers to the engineering specifications and established safety limits as defined by relevant IEC standards and comparison with predicate devices. The device's output parameters were measured against these defined standards and specifications.
8. The sample size for the training set
Not applicable. This is a medical device, not an AI model. There is no training set for an AI algorithm mentioned or required.
9. How the ground truth for the training set was established
Not applicable. As above, there is no AI training set.
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