K113017 · Mettler Electronics Corp. · IPF · Jun 26, 2012 · Physical Medicine
Device Facts
Record ID
K113017
Device Name
SYS*STIM 240
Applicant
Mettler Electronics Corp.
Product Code
IPF · Physical Medicine
Decision Date
Jun 26, 2012
Decision
SESE
Submission Type
Abbreviated
Regulation
21 CFR 890.5850
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
Indications for Medium Frequency (Russian), Biphasic, High Volt Pulsed Current (HVPC), Interferential (4P) and Premodulated (2P) waveforms · Relaxation of muscle spasms · Prevention or retardation of disuse atrophy · Increase local blood circulation · Muscle re-education · Maintaining or increasing range of motion · Immediate post-surgical stimulation of calf muscles to prevent venous thrombosis Additional indications for Microcurrent, Interferential (4P), Premodulated (2P), Biphasic and TENS waveforms · Symptomatic relief and management of chronic, intractable pain · Post-traumatic acute pain · Post-surgical acute pain Indications for DC (Direct Current) Mode · Relaxation of muscle spasm The laser and cluster applicators of the Sys*Stim 240 emit infrared energy for: · Temporary increase in local blood circulation · Temporary relief of minor muscle and joint aches, pains and stiffness · Relaxation of muscles · Temporary relief of muscle spasms · Temporary relief of minor pain and stiffness associated with arthritis
Device Story
Sys*Stim 240 is a combination neuromuscular stimulator and low-level light therapy device. It delivers nine discrete electrical waveforms (Russian, Biphasic, HVPC, Interferential, Premodulated, Microcurrent, TENS, DC) and infrared light therapy via optional laser or cluster applicators. Clinicians operate the device in clinical settings, using a touch-sensitive interface and M Wheel navigation to select treatment protocols and monitor parameters. The device provides electrical stimulation to muscles and nerves or infrared energy to tissues. Outputs include electrical pulses for muscle/pain management and infrared light for circulation/pain relief. Safety features include automatic overload, over-current, and no-load trips, plus patient interrupt switches. Optional battery pack enables portable use. Output affects clinical decision-making by providing standardized protocols for pain management and muscle rehabilitation, potentially benefiting patients through reduced pain, improved muscle function, and increased range of motion.
Clinical Evidence
Bench testing only. No clinical data provided. Device compliance verified against electrical safety and performance standards including IEC 60601-1, IEC 60601-1-2 (EMC), IEC 60601-2-10, IEC 60601-2-22 (laser), IEC 60825-1 (laser safety), and IEC 62471 (photobiological safety). Biocompatibility of electrodes confirmed via reference to previously cleared Mettler devices.
Indicated for patients requiring muscle spasm relaxation, disuse atrophy prevention, local blood circulation increase, muscle re-education, range of motion maintenance, or post-surgical calf stimulation to prevent venous thrombosis. Also indicated for symptomatic relief of chronic intractable, post-traumatic, or post-surgical acute pain. Laser/cluster applicators indicated for temporary relief of minor muscle/joint aches, pain, stiffness, and arthritis-related pain.
Regulatory Classification
Identification
A powered muscle stimulator is an electrically powered device intended for medical purposes that repeatedly contracts muscles by passing electrical currents through electrodes contacting the affected body area.
Predicate Devices
Chattanooga Group's Vectra Genisys 2channel electrotherapy system (K031077)
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K113017
PAGE 1 OF 5
JUN 2 6 2012
### 510(k) SUMMARY
### Mettler Sys*Stim 240, ME 240
Submitter's Name: Mettler Electronics Corp. Address: 1333 South Claudina Street Anaheim, CA 92805
> Telephone: 714-533-2221 x331 Fax: 714-635-7539
Christina Cavuela Contact: QS/RA Manager
September 29, 2011 Date Prepared: Revised copy : March 27, 2012 Revised copy: May 23, 2012 Revised copy: June 25, 2012
#### Proposed Device Name:
a. TRADE NAME: Sys*Stim 240
b. CLASSIFICATION NAME: Powered Muscle Stimulator (890.5850), Transcutaneous Electrical Nerve Stimulator for pain relief (882.5890) and Infrared Lamp (890.5500) c. COMMON NAME: Combination Neuromuscular Stimulator
and Low Level Light Therapy device
#### Predicate Devices:
- a. TRADE NAME: Chattanooga Group's Vectra Genisys 2channel electrotherapy system
- b. 510(k) Number: (K031077)
- c. TRADE NAME: Mettler Electronic Corp.'s Laser Sys*Stim 540, infrared lamp, therapeutic heating device
- d. 510(k) Number: (K043586)
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#### Description of Proposed Device:
The new Sys*Stim® 240 neuromuscular stimulator features nine discrete waveforms designed to facilitate clinical versatility. Waveforms may be combined with on-off programs for neuromuscular education as well as frequency and amplitude modulation programs for optimal pain management.
New touch-sensitive technology has been used to make starting a treatment easy. The high-resolution color display allows clinicians to monitor all treatment parameters continuously. The patented M Wheel™ provides easy navigation through all of the menus.
Clinicians can add full-featured light therapy capabilities to the Sys*Stim 240 by purchasing either the cluster or laser applicator package. The laser applicator has an 80 mW, 785 nm, laser diode and the cluster emits 500 mW at 600 and 950 nm. Applicator holders are provided with each applicator and can be attached to the sides of the Sys*Stim 240.
Treatment protocols complete with electrode placement quidance allow clinicians to quickly program treatment parameters for their patients. There is even space to save special treatment protocols for each waveform and for light therapy.
The Sys*Stim 240 has an optional battery pack so that clinicians can take either electrical stimulation or light therapy to their patients. A carrying case is also available which holds the units and all the accessories necessary for therapy on the road.
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#### Proposed Device Intended Use Statement:
#### Indications for Medium Frequency (Russian), Biphasic, High Volt Pulsed Current (HVPC), Interferential (4P) and Premodulated (2P) waveforms
- · Relaxation of muscle spasms
- · Prevention or retardation of disuse atrophy
- · Increase local blood circulation
- · Muscle re-education
- · Maintaining or increasing range of motion
- · Immediate post surgical stimulation of calf muscles to prevent venous
- thrombosis
#### Additional Indications for Microcurrent, Interferential (4P), Premodulated (2P), Biphasic, and TENS waveforms
- · Symptomatic relief and management of chronic, intractable pain
- · Post-traumatic acute pain
- · Post-surgical acute pain
#### Indications for DC (Direct Current) Mode
- · Relaxation of muscle spasm
#### The laser and cluster applicators of the Sys Stim 240 emit infrared energy for:
- Temporary increase in local blood circulation .
- Temporary relief of minor muscle and joint aches, pains and stiffness .
- Relaxation of muscles .
- Temporary relief of Muscle spasms .
- Temporary relief of minor pain and stiffness associated with arthritis
Biocompatibility Certification: Electrodes to be provided with this device are the same as those previously submitted since 1997 with Mettler Electronics Corp. devices: Sonicator Plus 992/994 (K984142); Sys*Stim 226 (K964028); Sys*Stim 294 (K984114); and Sonicator Plus 930 (K013192).
Performance Testing: The Sys*Stim 240 has been certified for:
- ITS certification for ETL and C-ETL Listing .
- Compliance with EMC, EN 60601-1-2: 2001 and FCC's 47 CFR, . FCC Sub Part 18
- Compliance to IEC 60601-2-22: 2007 ●
- Compliance to IEC 60825-1: 2007 .
- Compliance to IEC 62471: 2006 ●
- Compliance to EN60601-2-10, (IEC 601-2-10) 2001
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# Comparison Table for Sys Sti 510K Submission
## Section 2
| 1. | 510 K # | K | K031077 |
|----|-------------------------------------------------|--------------------------------------------------------------------------|---------------------------------------|
| 2. | Device Name | Sys*Stim 240 | Vectra Genisys |
| 3. | Manufacturer | Mettler Electronics | Encore Medical<br>(Chattanooga Group) |
| 4. | Power Source | AC line or optional battery pack 10.8 V<br>Lithium Ion | AC line or optional battery pack |
| | Line Current Isolation | Yes | Yes |
| | Patient Leakage Current (μΑ) | | |
| | Normal condition (ac) | 78 (Less than 100 μΑ) | Less than 100 μΑ |
| | Single fault condition (ac) | 78 (Less than 500 μΑ) | Less than 500 μΑ |
| 5. | Number Of Output Modes | 9 (one less output ) | 10 |
| 6. | Channel(s) | 2 Channel | 2 Channel |
| | Synchronous | 1 & 2 | 1 & 2 |
| | Reciprocal | 1 & 2 | 1 & 2 |
| | Other | Yes | Yes |
| 7. | Constant Current | Optional | Optional |
| | Constant Voltage | Optional | Optional |
| 8. | Software / Firmware /<br>Microprocessor Control | Yes | Yes |
| 9. | Automatic Overload Trip | Yes | Yes |
| | Automatic Over Current Trip | Yes | Warning only, Overcurrent |
| | 10. Automatic No Load Trip | Yes | Warning only, Bad electrode contact |
| | 11. Automatic Shut Off | Yes | Yes |
| | 12. Patient Override | Yes | Yes |
| | Control Method | Patient interrupt switch | Patient interrupt switch |
| | 13. Indicator Display | | |
| | On / Off Status | Yes | Yes |
| | Low Battery Indicator | Yes | Yes |
| | Voltage / Current Level | Yes | Yes |
| | 14. Timer Display: (Stimulator) | 0 - 60 minutes for stimulation<br>Auto based on dosage for light therapy | 0 - 60 minutes |
| | 15. Standards | | |
| | ISO 14971 : 2000 | Yes | Yes |
| | UL 60601-1 | Yes | Yes |
| | CSA C22.2 NO 601.1-M90 | Yes | Yes |
| | IEC/EN 60601-1 | Yes | Yes |
| | IEC/EN 60601-1-2 | Yes | Yes |
| | IEC/EN 60601-2-10 | Yes | Yes |
| | MDD 93/42/EEC, Annex II | Yes | Yes |
| | 16. Compliance with<br>21 CFR 898 | Yes | Yes |
| | 17. Weight (lbs.) | 4.5 lb / 5.50 lb with Battery (Lighter wt) | 7 |
| | 18. Dimensions (in.) H x W x L | 8 in (H) x 8 in (W) x 13 in (L) | 8.8 x 11.375 x 12.75 |
| | 19. Housing Materials &<br>Construction | ABS Plastic | ABS Plastic |
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## Explanation of Differences on the Comparison Table for the Sys*Stim® 240
:
| Item | Mettler | Chattanooga | Explanation |
|--------------------------------|------------|-------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 5. Number of output modes | 9 | 10 | Mettler does not have<br>Chattanooga's proprietary<br>VMS burst |
| 9. Automatic Over Current Trip | Yes | Warning only,<br>Overcurrent | On an error such as this one,<br>Mettler chooses to stop all<br>output in the interest of<br>patient safety. |
| 10. Automatic No Load Trip | Yes | Warning only,<br>Bad electrode<br>contact | Mettler chooses patient<br>safety, by requiring the<br>clinician to fix the contact<br>issue and then restart the<br>system, to assure there are<br>no excess outputs. |
| 17. Weight | 4.5 lbs. | 7 lbs. | Different design criteria, no<br>effect on function |
| 18. Dimensions | 8 x 8 x 13 | 8.8 x 11.375 x<br>12.75 | Different design criteria, no<br>effect on function |
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#### DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/5/Picture/1 description: The image shows the seal of the Department of Health & Human Services USA. The seal features a stylized eagle with its wings spread, symbolizing protection and service. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" are arranged in a circular pattern around the eagle.
#### Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room-WO66-G609 Silver Spring, MD 20993-0002
JUN 2 6 2012
Mettler Electronics Corporation % Ms. Christina Cayuela OS/RA Manager 1333 South Claudina Street Anaheim, California 92805
Re: K113017
Trade/Device Name: SYS*stim 240 Regulation Number: 21 CFR 890.5850 Regulation Name: Powered muscle stimulator Regulatory Class: II Product Code: IPF, ILY, GZJ, LIH Dated: May 26, 2012 Received: June 04, 2012
#### Dear Ms. Cayuela:
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. Please note: CDRH does not evaluate information related to contract liability . warranties. We remind you; however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to 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 Register.
{6}------------------------------------------------
Page 2 - Ms. Christina Cayuela
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 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); medical device reporting of medical device-related adverse events) (21 CFR 803); 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 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled. "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
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) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours,
Eunice Keith
Mark N. Melkerson Director Division of Surgical, Orthopedic and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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### Indications for Use
510(k) Number (if known): K113017
Sys*Stim® 240, Model ME240 Device Name:
- 1. Indications for Medium Frequency (Russian), Biphasic, High Volt Pulsed Current (HVPC), Interferential (4P) and Premodulated (2P) waveforms
- · Relaxation of muscle spasms
- · Prevention or retardation of disuse atrophy
- · Increase local blood circulation
- · Muscle re-education
- · Maintaining or increasing range of motion
- · Immediate post-surgical stimulation of calf muscles to prevent venous thrombosis
- 2. Additional indications for Microcurrent, Interferential (4P), Premodulated (2P), Biphasic and TENS waveforms
- · Symptomatic relief and management of chronic, intractable pain
- · Post-traumatic acute pain
- · Post-surgical acute pain
#### 3. Indications for DC (Direct Current) Mode
- Relaxation of muscle spasm
- 4. The laser and cluster applicators of the Sys*Stim 240 emit infrared energy for:
- · Temporary increase in local blood circulation
- · Temporary relief of minor muscle and joint aches, pains and stiffness
- · Relaxation of muscles
- · Temporary relief of muscle spasms
- Temporary relief of minor pain and stiffness associated with arthritis
× Prescription Use
AND/OR
Over-The-Counter Use (Per 21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE — CONTINUE ON ANOTHER PAGE IF NEEDED)
Evaluation (ODE) Concurrent of CDRH Office of Device
KAYLA L. LYNCH
(Division Sign-Off)
Division of Surgical, Orthopedic, and Restorative Devices
5 . 0(k) Number
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.