MEDRELIEF ST SERIES, MODELS RT-50, ST-100, ST 150, ST-200, ST-300
K060669 · Healthonics, Inc. · GZJ · Oct 13, 2006 · Neurology
Device Facts
Record ID
K060669
Device Name
MEDRELIEF ST SERIES, MODELS RT-50, ST-100, ST 150, ST-200, ST-300
Applicant
Healthonics, Inc.
Product Code
GZJ · Neurology
Decision Date
Oct 13, 2006
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 882.5890
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
For Prescription Use Model SE-100: - Relief of chronic intractable pain. - Adjunctive treatment of post-surgical or post-traumatic acute pain. For Prescription Use Models ST-150, ST-200 and ST-300: - Relief of chronic intractable pain. - Adjunctive treatment of post-surgical or post-traumatic acute pain. - Adjunctive therapy in reducing the level of pain associated with osteoarthritis of the knee. - Adjunctive therapy in reducing the level of pain from rheumatoid arthritis of the hand.
Device Story
MedRelief ST Series (ST-100, ST-150, ST-200, ST-300) provides subthreshold electrical stimulation for pain relief. Device inputs: battery power; user-selected settings (frequency, burst timing). Principle: hard-wired solid-state electronics generate biphasic, subthreshold electrical pulse trains (20 Hz–20 kHz) applied via skin-contact electrodes. No microprocessor or software used. Output: electrical pulses to skin. Used in home (ST-100, ST-150, ST-200) or clinical (ST-300) settings. Healthcare providers prescribe; patients apply electrodes and operate controls. Subthreshold stimulation acts at cellular level without causing sensation or muscle contraction, potentially relieving pain.
Clinical Evidence
Bench testing only. No clinical data provided. Substantial equivalence is based on comparative analysis of electrical output characteristics (current, pulse shape, frequency, charge) and intended use against legally marketed predicate devices.
Technological Characteristics
Battery-powered (9V lithium) TENS device; flame-retardant ABS plastic housing. Solid-state, hard-wired circuitry (no software/microprocessor). Biphasic pulse output; frequencies 20 Hz–20 kHz. Applied via self-adhesive/gelled electrodes. Complies with AAMI NS4 safety standards. Dimensions vary by model (1.7 oz to 8 oz).
Indications for Use
Indicated for patients requiring relief of chronic intractable pain, adjunctive treatment of post-surgical or post-traumatic acute pain, and adjunctive therapy for pain associated with osteoarthritis of the knee or rheumatoid arthritis of the hand. Prescription use only.
Regulatory Classification
Identification
A transcutaneous electrical nerve stimulator for pain relief is a device used to apply an electrical current to electrodes on a patient's skin to treat pain.
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K060669
Applicant: Healthonics, Inc. MedRelief®® ST Series Microcurrent TENS Traditional 510(k) Premarket Notification
Page 1:4
# OCT 1 3 2006 Biophysics Health Co
510(k) Summary:
| 510(k) Owner: | Healthonics, Inc.<br>903 Main Street South<br>New Ellenton, SC 29803 |
|-----------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | James W. Kronberg<br>Chief Engineer<br>Phone 803-652-2354<br>Fax 775-251-0023 |
| Date Prepared: | March 10, 2006 - Revised September 13, 2006 |
| Device Name: | MedRelief ST ("Sub-Threshold") Series, consisting<br>of models ST-100, ST-150, ST-200 and ST-300. |
| Common or Usual Name: | TENS device. |
| Classification Name: | Transcutaneous Electrical Nerve Stimulator for Pain<br>Relief. 21 CFR 882.5890, Class II, Product Code<br>84GZJ (prescription) or Stimulator, Electrical,<br>Transcutaneous, for Arthritis. 21 CFR 882.5890,<br>Class II, Product Code NYN (prescription). |
| Predicate Devices: | Healthonics MedRelief® SE-50 for acute and chronic<br>pain indications (K030998).<br>Bionicare Model BIO-1000 for osteoarthritis<br>(K030332) and rheumatoid arthritis (K983228)<br>indications. |
#### Description of the Device:
The MedRelief" ST Series™, consisting of models ST-100, ST-150, ST-200 and ST-300, is designed to provide subthreshold electrical stimulation for acute and chronic pain, including pain, including pain from osteoarthritis and rheumatoid arthritis, in a single compact, lightweight and user-friendly package. "Subthreshold" stimulation does not normally cause sensation or muscle contraction, but acts at a cellular level to relieve pain.
Each device in the ST Series is comprised of the following main components.
- A power section consisting of battery, switch, test and conditioning components; .
- A dosing timer, initialized at power-on and providing a choice of treatment times; .
- A control oscillator, providing pulse-burst timing; .
- A pulse oscillator, providing timing for individual pulses; and .
- An output section, providing filtering, DC blocking and intensity control.
While some components are digital, all functions are hard-wired and there is no microprocessor or software used. Output is by means of lead wires and skin-contact electrodes already commercially available and legally sold by others.
The member devices in the ST Series™ differ only in the complexity of their controls and number of physician or user options which each model offers.
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page 2:4
Indications and Intended Use:
- . Relief of chronic intractable pain. (All modelse) ;
- . Adjunctive treatment of post-surgical or post-traumatic acute pain. {{{#=====================================================================================================
- Adjunctive therapy in reducing the level of pain and symptoms associated with . osteoarthritis of the knee. (ST-150, ST-200 and ST-300 and ST-300 and ST-300 coment
- . Adjunctive therapy in reducing the level of pain, and stiffness associated with pain, from rheumatoid arthritis of the hand. (ST-150, ST-200 and ST-300 and ST-300 ember
The indications are the same as for the predicate devices listed. All units are for prescription use only. The ST-100 is a simplified unit meant for home use, with one output channel and a minimal set of signal options, closely similar to the SE-50 predicate device. Other devices in the ST Series™ are meant for a wider range of indications by including a signal modeled on that of the Bionicare BIO-1000 predicate device. The ST-150 is otherwise identical with the ST-100. The ST-200 offers two output channels and more user options. The ST-300 offers four channels, even more options, and is meant for use in a clinical setting only.
#### Technological Characteristics:
The technological characteristics of the MedRelief® ST Series™ are the same as those of the predicate devices. Each device is battery-powered with no provisions for line power or AC adapters. Each uses solid-state electronics to produce trains of subthreshold electrical pulses, at frequencies within the human audible range (~20 Hz to ~20 KHz), which are applied to the body through self-adhesive or gelled electrodes placed on the skin. Pulses have zero net charge and may be applied either continuously, or divided into pulse bursts alternating with quiet periods. All signal characteristics comply with the safety requirements of AAMI NS4.
#### Comparison of Features of MedRelief® ST Series™ Models
(s) - user switch selected. (c) - user adjustable through continuous range.
| Characteristic or Feature | ST-100 | ST-150 | ST-200 | ST-300 |
|---------------------------------|-------------------------------------------------------------------------------------|-----------------------------|----------------------------------------------|-------------------------|
| Intended use | Intractable chronic, postsurgical / posttraumatic acute and arthritis-related pain. | | | |
| Intended sale | Prescription only | | | |
| Number of output<br>channels | 1 | 1 | 2 | 4 |
| Pulse frequency | 700, 1800 or<br>4150 Hz (s) | 100, 700 or<br>4150 Hz (s) | 100, 230, 700,1800, 4150<br>Hz or 12 KHz (s) | 100 Hz to 20<br>KHz (c) |
| Pulse (short phase) length | 1/7 of long phase or 20 microseconds, whichever is greater | | | |
| Burst frequency | 15 Hz in pulse burst mode; N/A in continuous mode. | | | |
| Burst duty cycle | 15% or 100%* (s) | 5% up to 100%* (c) | | |
| Timer | None (runs whenever turned on) | 30 min., 8 hrs or cont. (s) | | |
| Dimensions, in. | 2.5 x 2.1 x 0.63 | 3.5 x 2.5 x 1 | 7 x 5 x 2.5 | |
| Weight including battery | 1.7 oz. | 2.5 oz. | 8 oz. | |
| Charger, AC cord or<br>adapter? | None | | | |
* Burst duty cycle of 100% = continuous operation.
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y 3. 4
#### Comparison of General and Technical Characteristics to Predicates.
Electrical output measurements assume a 500-ohm load. Timing values cited below are accurate to ±20% or 10 microseconds, whichever is larger. Other cited values are accurate to ±20% unless otherwise stated.
For conciseness, (10), (15), (20) and (30) refer to the ST-100, ST-150, ST-200 and ST-300 respectively. "Same" plus one or more of these labels in a Predicate column means "same as in the indicated ST Series™ device(s)," while without a label it means "same for all." See also notes 1-3 at the bottom of the table.
| Unit Characteristic | Proposed Device | Predicate #1 | Predicate #2 |
|---------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|
| Device name and model | MedRelief® ST Series<br>(ST-100, ST-150, ST-200 and ST-300) | MedRelief® SE-50<br>(in SE Series). | BioniCare®<br>Stimulator, Model<br>BIO-1000™ |
| Manufacturer | Healthonics, Inc.<br>903 Main Street South<br>New Ellenton, SC 29803 | Same. | BioniCare Medical<br>Technologies, Inc.<br>47 R. Loveton Circle<br>Sparks, MD 21152 |
| 510(k) number | To be assigned | K030998 | K030332, K983228 |
| Procode | GZJ, NYN | GZJ | NYN |
| Intended Use<br>(indications; abbreviated,<br>see full list above.) | 1. Chronic intractable pain.<br>2. Post-surgical/post-traumatic acute<br>pain.<br>3. Pain/symptoms from osteoarthritis<br>of the knee.<br>4. Pain/stiffness from rheumatoid<br>arthritis of the hand. | Same as #1 and #2<br>for proposed device. | Same as #3 and #4<br>for proposed device |
| Number of output<br>modes | One: subthreshold<br>TENS. | Same. | Same. |
| Number of output<br>channels. | One (10, 15), two (20), or four (30). | One. | Version A: one.<br>Version B: two. |
| Pulse shape | Rectangular to exponential,<br>depending on pulse length and<br>charge balancing time chosen. | Same. | One phase<br>exponential, other<br>phase rectangular. |
| Mono- or biphasic | Biphasic | Biphasic | Biphasic (note 1) |
| Maximum instantaneous<br>current | 8.62 mA | Same | 24 mA |
| Maximum time averaged<br>current | 2.27 mA (2.71 mA, note 2) | Same | 2 mA |
| Maximum phase charge | 12.4 µC at 100 Hz;<br>1.87 µC at 700 Hz (note 2) | 1.87 µC at 700 Hz<br>(note 2) | 20 µC at 100 Hz |
| Maximum current density<br>at electrode | 0.41 mA/sq.cm. (note 2) | Same | 0.14 mA/sq.cm.<br>(note 3) |
| Maximum power density<br>at electrode | 0.133 mW/sq.cm. (note 2) | Same | 0.83 mW/sq.cm.<br>(note 3) |
| Regulated current or<br>regulated voltage? | Regulated current. | Same. | Regulated voltage. |
| Software/ firmware/<br>/microprocessor control? | No | No | No in Version A; yes<br>in Version B. |
| Housing materials and<br>construction. | Flame-retardant ABS plastic. | Same. | Flame-retardant<br>Cycolac plastic |
| Accessories:<br>1. Electrodes. | Pregelled reusable electrode,<br>25 cm² gel area, with "pigtail" wire<br>connection. For 100 Hz use (15, 20,<br>30), same but with 175 cm² gel area. | Pregelled reusable<br>electrode, 25 cm² gel<br>area, with "pigtail"<br>wire connection. | BioniCare special<br>design, metal mesh,<br>170-176 cm² gel-<br>coated area. |
| 2. Conductive<br>medium (gel) | None | None | Spectra 360 |
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### Applicant: Healthonics, Inc.
x 4:4
| 3. Electrode lead<br>wires. | 2 mm pin joined to 2mm socket by<br>flexible wire | Same. | Semicustom wires,<br>snap connectors |
|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------|-------------------|-----------------------------------------|
| 4. Batteries. | 9V lithium batteries: miniature<br>semicustom (10, 15, 20) ; standard<br>rectangular (30). | Same (10, 15, 20) | Self-contained<br>rechargeable battery. |
| 5. Battery charger,<br>if used. | None. | None. | Plug-in wall<br>transformer type |
| Note 1. BioniCare claims monophasic pulses, but Healthonics scope measurements show the second phase is not<br>completely suppressed so the BioniCare pulses are actually biphasic.<br>Note 2: Taken under conservative worst-case conditions including any single-component failure. | | | |
:
:
:
Note 3. Healthonics measured from predicate device or calculated from information in predicate's 510(k).
.
.
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Image /page/4/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo is a circular seal with the words "DEPARTMENT OF HEALTH AND HUMAN SERVICES, USA" around the perimeter. Inside the circle is an abstract symbol that resembles a stylized caduceus, a symbol often associated with medicine and healthcare. The symbol consists of three human profiles facing right, with flowing lines connecting them.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
# OCT 1 3 2006
Healthonics, Inc. % Mr. James W. Kronberg Chief Engineer 903 Main Street South New Ellenton, South Carolina 29809
Re: K060669
Trade Name: MedRelief ST ("Sub-Threshold") Series consisting of model numbers ST-100. ST-150, ST-200, and ST-300 Regulation Number: 21 CFR 882.5890 Regulation Name: Transcutaneous electrical nerve stimulator for pain relief Regulatory Class: Class II Product Codes: GZJ, NYN Dated: September 13, 2006 Received: September 14, 2006
Dear Mr. Kronberg:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such additional controls. Existing major regulations affecting your device, can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition. FDA may publish further announcements concerning your device in the Federal Pegister.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements not mour or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 100-1050.
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Page 2 - Mr. James W. Kronberg
This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Office of Compliance at (240) 276-0120. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely vours.
Mark N. Melkonian
Mark N. Melkerson Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health
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## Indications for Use
510(k) number (if known): ___K060669
Device Name: MedRelief ST ("Sub-Threshold") Series, consisting of model numbers ST-100, ST-150, ST-200 and ST-300.
Indications for Use.
For Prescription Use Model SE-100:
- Relief of chronic intractable pain. .
- Adjunctive treatment of post-surgical or post-traumatic acute pain. .
For Prescription Use Models ST-150, ST-200 and ST-300:
- Relief of chronic intractable pain. .
- Adjunctive treatment of post-surgical or post-traumatic acute pain. .
- Adjunctive therapy in reducing the level of pain associated with osteoarthritis of the ● knee.
- Adjunctive therapy in reducing the level of pain from rheumatoid arthritis of the hand. .
| Prescription Use<br>(21 CFR 801 Subpart D) | AND/OR | Over-The-Counter Use<br>(21 CFR 801 Subpart D) |
|--------------------------------------------|--------|------------------------------------------------|
|--------------------------------------------|--------|------------------------------------------------|
Concurrence of CDRH, Office of Device Evaluation (ODE)
(Division Sign-Off)
Division of General, Restorative, and Neurological Devices
| 510(k) Number | L060669 |
|---------------|---------|
|---------------|---------|
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.