LIFECARE CONDUCTIVE GARMENTS

K103719 · Everyway Medical Instruments Co.,Ltd · GXY · Aug 24, 2011 · Neurology

Device Facts

• Record ID: K103719
• Device Name: LIFECARE CONDUCTIVE GARMENTS
• Applicant: Everyway Medical Instruments Co.,Ltd
• Product Code: GXY · Neurology
• Decision Date: Aug 24, 2011
• Decision: SESE
• Submission Type: Abbreviated
• Regulation: 21 CFR 882.1320
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The Lifecare HC-88 Series Conductive Garments are used in conjunction with electrical stimulators both in the home and physical therapy setting, and can stimulate large or multiple. They are knitted in different shapes, as gloves, socks, kneecaps and wristlets/elbow guards, and in different sizes.

Device Story

Lifecare HC-88 Series Conductive Garments are single-patient reusable, non-sterile, flexible fabric electrodes; interface between electrical stimulators (TENS, powered muscle stimulators, galvanic devices) and patient skin. Constructed from metal snap terminals and cloth knitted with Spandex and stainless-steel/nylon fibers. Used in home or physical therapy settings; operated by patients or clinicians. Device transmits electrical signals from stimulator through conductive garment to skin surface. Available in various shapes (gloves, socks, kneecaps, wristlets/elbow guards). Not MRI compatible. Benefits include delivery of electrical stimulation to large or multiple body areas simultaneously.

Clinical Evidence

Bench testing only. Biocompatibility testing performed per ISO 10993-5 (cytotoxicity) and ISO 10993-10 (skin irritation and sensitization). Impedance testing conducted using resistance meters and oscilloscopes; results showed impedance <5 ohms/cm and total impedance <50 ohms, maintained after 20 wash cycles.

Technological Characteristics

Materials: Metal snap terminal, Spandex, stainless-steel yarn, nylon fibers. Sensing/Actuation: Passive conductive interface for electrical stimulators. Form factor: Knitted garments (gloves, socks, kneecaps, wristlets/elbow guards). Connectivity: None (passive). Sterilization: Non-sterile. Impedance: <5 ohms/cm; <50 ohms total.

Indications for Use

Indicated for use as cutaneous electrodes with legally marketed electrical stimulators (e.g., powered muscle stimulators, TENS) to deliver stimulation signals to body surfaces including hands, feet, wrists, elbows, and knees.

Regulatory Classification

Identification

A cutaneous electrode is an electrode that is applied directly to a patient's skin either to record physiological signals (e.g., the electroencephalogram) or to apply electrical stimulation.

Predicate Devices

• TheraKnit Garment Cutaneous Electrodes (K053214)

Submission Summary (Full Text)

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### 510(k) Summary As Required by 21 section 807.92 ( c )

Everyway Medical Instruments Co., Ltd. 1-Submitter Name:

2-Address:

3 FL., No.5, LANE 155, Sec. 3, Peishen Rd Shen Keng Hsiang. 222 Taipei Hsien. Taiwan (ROC)

3-Phone: [phone]

4-Fax: [phone]

5-Contact Person: Mr. Robert Tu (General Manager)

6-Date summary prepared: July 15", 2011

7 - Official Correspondent: Mansour Consulting LLC

8- Address: 845 Aronson Lake Court. Roswell, GA 30075 USA

9- Phone: [phone]

10- Fax: [phone]

11- Contact Person: Jav Mansour, President

12-Device Trade or Proprietary Name: Lifecare HC-88 Series Conductive Garments

13-Device Common or usual name: Lifecare HC-88 Series Conductive Garments

14-Device Classification Name: Cutaneous electrode

15-Substantial Equivalency is claimed against the following device:

TheraKnit Garment Cutaneous Electrodes from Neurotron Medical, Inc. 510k# K053214 16-Description of the Device:

The single-patient reusable and non-sterile Lifecare HC-88 Series Conductive Garments are cutaneous. flexible, conductive garment/fabric electrodes.

They are passive devices acting as interface between electrical stimulators (such as powered muscle stimulators, interferential devices, galvanic device and transcutaneous electrical nerve stimulators) and a patient's skin. The signal is transmitted from the conductive knob through the cloth of conductive garment to the surface of the patient's skin.

The Lifecare HC-88 Series Conductive Garments are used in conjunction with electrical stimulators both in the home and physical therapy setting, and can stimulate large or multiple. They are knitted in different shapes, as gloves, socks, kneecaps and wristlets/elbow guards, and in different sizes.

The Lifecare HC-88 Series Conductive Garments are constructed with four basic components (materials): a metal conductive snap terminal; cloth knitted together with Spandex and Stainless-steel yarns that twisted and composed by Stainless-steel and Nylon fibers. The garments are not packaged with lead wire.

Impedance testing evaluated by the "Resistance meter of electronic multimeter" to measure the impedances of all conductive garments are below 5 ohms between each centimeter and evaluated by the "oscilloscope measuring circuit" to measure the total impedance of all conductive garments are below 50 ohms" . Even after over 20 times washing, the impedance of Lifecare HC-88 Series Conductive Garments are still within specification.

The garments are not compatible with MRI spectrometry.

#### 17-Intended use of the device: (refer to FDA form attached)

The Lifecare HC-88 Series Conductive Garments are used in conjunction with electrical stimulators both in the home and physical therapy setting, and can stimulate large or multiple. They are knitted in different shapes, as gloves, socks, kneecaps and wristlets/elbow guards, and in different sizes.

## 18-Safety and Effectiveness of the device:

This device is safe and effective as the predicate devices cited above as detailed within this submission. This type of device has been marketed and used in US for several years as Prescription use and proven to be safe and effective without side effects or complications generated from the use of the device itself.

#### 19-Biocompatibility of material:

The material of Lifecare HC-88 Series Conductive Garments were evaluated and passed the evaluation of biocompatibility testing by SGS Taiwan Ltd.

- Cytotoxicity test (ISO 10993-5, SGS report No.UB/2010/50533), -
- । Skin irritation test (ISO 10993-10, SGS report No. UB/2010/50533A-01) and
- Skin sensitization test (ISO 10993-10, SGS report No. UB/2010/50533A-02)

AUG 2 4 2011

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# 20-Approximate surface area of each garment model:

| REF.NO | SIZE | SURFACE AREA | Type |
|-----------|--------------|--------------|----------------|
| HC-884A | M(L21cm) | 450cm² | Glove |
| HC-885A | L(L24cm) | 580cm² | Glove |
| HC-886A | S(L18cm) | 330cm² | Glove |
| REF.NO | SIZE | SURFACE AREA | Type |
| HC-883 | (L33xW9cm) | 600cm² | Sock |
| REF.NO | SIZE | SURFACE AREA | Type |
| HC-881A | M(L18xW11cm) | 400cm² | Wristlet/Elbow |
| HC-881-1A | S(L18xW10cm) | 360cm² | Wristlet/Elbow |
| REF.NO | SIZE | SURFACE AREA | Type |
| HC-882A | M(L27xW14cm) | 760cm² | Kneecaps |

719

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Image /page/2/Picture/1 description: The image shows the seal of the Department of Health and Human Services (HHS). The seal features a stylized eagle with three stripes forming its body and wings. The eagle is enclosed in a circle with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002

Everyway Medical Instruments Co., Ltd. c/o Mr. Jay Mansour Mansour Consulting, LLC 845 Aronson Lake Court Roswell, GA 30075

AUG 2 4. 2011

Re: K103719

Trade/Device Name: Lifecare HC 88-Series Conductive Garments Regulation Number: 21 CFR 882.1320 Regulation Name: Cutaneous electrode Regulatory Class: Class II Product Code: GXY Dated: August 1, 2011 Received: August 5, 2011

Dear Mr. Mạnsour:

We have reviewed your Section 510(k) premarket notification of intent to market the device We have reviewed your Section 910(x) promation is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate for use stated in the encrosule) to tegally manoves personal perice Ameridae, or to commerce prof to way 20, 1970, the classified in accordance with the provisions of the Federal Food, Drug, devices that have been recursed in accordance was a premarket approval approval application (PMA). and Cosment Act (Act) that do not roques approvinces in controls provisions of the Act. The
You may, therefore, market the device, subject to the general controls provision You may, merelote, market the device, saljers to the gents for annual registration, listing of the general Controls provisions of the vice is a prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability adulteration. Please note. CDITI docs how verse labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or classica on be II your device is classifica (see above) Existing major regulations affecting your device can be may be subject to additional controlly "Linziting Collections, Title 21, Parts 800 to 898. In addition, FDA may found in the Code of I occar 105g ming your device in the Federal Register,

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 of the Act of the Act one of our must oomn that FDA has made a determination that Jour cered by other Federal agencies. You must comply of any Pederal statutes and regulations administered of the registration and listing (2) CFR Patt With an the Act s requiremons; areasing, a with the reporting of medical device-related

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adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the adverse events) (21 CFR 805); good manufacture production in electronic product
quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product quality systems (QS) regulation (21 CFR 100 SE6), 21 CFR 1000-1050.
radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please
r (1580), please and 15 (1) (15) (1)PRIVOR (CDRUCCDRUCC) If you desire specific advice for your device of our laborary copanese (
go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucml (5809.html for go to http://www.tda.gov/AboutFDACEmers/crices/Office of Compliance. Also, please
the Center for Devices and Radiological Health's (CDRH) s (CDRH) stopperket notification" ( the Center for Devices and Radiological ricallis systemarks notification" (21CFR Patt
note the regulation entitled, "Misbranding by reference sunder the MDR regulation (2 note the regulation entitled, "Misoraliung of relected to promation
807.97). For questions regarding the reporting of adverse events under the MDR regulation (21

CFR Part 803), please go to CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportalProblem/default.html for the CDRH's Office ntlp://www.ida.gov.nice.etrics/Division of Postmarket Surveillance.

You may obtain other general information on your responsibilities under the Act from the You may obtain other general inormational and Consumer Assistance at its toll-free number
Division of Small Manufacturers, International and Consumer Assistance at its toll-f [phone] or [phone] or at its Internet address [phone] of [phone] of at its career)
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours,

Kesia Alexander

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Malvina B. Eydelman, M.D. Director Division of Ophthalmic, Neurological, and Ear, Nose and Throat Devices Office of Device Evaluation Center for Devices and Radiological Health

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# Indications for Use

510(k) Number (if known):

Device Name: Lifecare HC-88 Series Conductive Garments

Indications For Use:

The Lifecare HC-88 Series Conductive Garments are cutaneous electrodes to be used with legally marketed electrical stimulators (such as powered muscle stimulators and transcutaneous electrical nerve stimulators).

The knitted garment electrodes will deliver the stimulation signals generated by the stimulator to the body surface with which they are in contact.

These body parts include hands (gloves), feet (socks), wrists / elbows (wristlets / elbow guards) and knees (kneecaps).

Prescription Use (Part 21 CFR 801 Subpart D)

AND/OR

Over-The-Counter Use (21 CFR 807 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

B

(Division Sign-Off) Division of Ophthalmic, Neurological and Ear, Nose and Throat Devices

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510(k) Number