The BRC 2200 is intended for temporary symptomatic relief and management of chronic intractable pain and as an adjunctive treatment in the management of post-surgical and post-traumatic pain.
Device Story
BRC 2200 is a non-invasive, hand-held TENS device delivering bipolar electrical current for pain management. Device features a touch screen interface; licensed healthcare professionals use pass codes to access 24 pre-programmed treatment options and patient data. Patients may pause treatment or reduce power during use if discomfort occurs. System includes single-use electrodes (polyurethane foam/synthetic neoprene) wrapped circumferentially around limbs or trunk, secured with hook and loop fasteners; requires water or saline as a conductive medium. Powered by a 3.7V Li-polymer rechargeable battery. Optional USB connectivity allows data transfer to computers for professional review. Used in clinical or home settings to provide symptomatic pain relief, potentially reducing reliance on other interventions.
Clinical Evidence
No clinical data. Bench testing only, including functional performance and electrical safety testing per IEC 60601-1, IEC 60601-1-2, IEC 60601-1-4, and IEC 60601-2-10. Biocompatibility testing for skin-contacting materials performed per ISO 10993-1, ISO 10993-5, and ISO 10993-10.
Technological Characteristics
Hand-held TENS device; injection-molded plastic housing. Biphasic rectangular waveform; 10 Hz frequency; 100 ms pulse duration. Powered by 3.7V Li-polymer battery. Electrodes: polyurethane foam/synthetic neoprene, ISO 10993 compliant. Connectivity: USB for data logging. Microprocessor-controlled with automatic overload trip and automatic shut-off. Regulated current output.
Indications for Use
Indicated for temporary symptomatic relief and management of chronic intractable pain and as an adjunctive treatment for post-surgical and post-traumatic pain in patients requiring TENS therapy.
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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K121578
JUL 3 1 2012
# 510(K) Summary
(Per 21 CFR 807.92)
#### Applicant
Applicant: Bioelectric Research Corporation 112 N. Curry St. Carson City, NV 89703 Phone: 775-884-1200
Contact: ·
Shepard G. Bentley, RAC President & Principal Consultant Bentley Biomedical Consulting, LLC 28241 Crown Valley Parkway Suite 510(k) Laguna Niguel, CA 92677 Phone: 949-374-9187 Fax: 949-606-8191 sbentley@bentleybiomed.com
Date summary was prepared: July 28, 2012
### Predicate Device
The BRC 2200 device is substantially equivalent to the transcutaneous electrical nerve stimulator (TENS) device BodiHealth System (K052836).
### Device Description
The BRC 2200 is a non-invasive, therapeutic device that delivers bipolar electrical current. In order to maintain a neutral charge for each cycle, the device delivers a current of one polarity for the first half of the cycle and then the opposite polarity for the second half of the cycle.
The BRC 2200 is a hand-held device with a touch screen designed for ease of the user. The licensed healthcare professional uses a pass code to access screens regarding the treatment options and patient information. The main treatment screen shows the progression of the treatment, date, time, battery level, and gives options to pause the treatment or reduce the power if the patient feels discomfort.
The BRC 2200 contains 24 pre-programmed treatments accessible only to the licensed healthcare professional. Using the designated pass code, the licensed healthcare professional selects the treatment and updates the correct patient information to the
Section 4 - 1
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K12/578
device before starting the treatment. Once the treatment has started, the patient will be able to pause the treatment or reduce power if he/she feels mild discomfort.
Components included with the BRC 2200 contain a pair of single-use electrodes, a pair of electrode cables, a battery charger, and an optional USB cable.
The electrodes come in a variety of sizes ranging from extra-small to large and either two inch or three inch widths. The electrodes attach by being circumferentially wrapped around a limb or the trunk of the body and the overlapping ends secured with hook and loop fasteners to maintain circumferential tension during treatment. The electrodes consist of a conductive layer sandwiched between a layer of polyurethane foam and a layer of synthetic neoprene. The foam is in contact with normal, intact skin for up to 3 hours and complies with ISO 10993.
The electrode cables attach to the electrodes via a silver metal hook and loop fastener which then attaches to the BRC 2200 using push-pull connectors. The electrode cables used with the electrodes can be multi-use and are available in 40, 50, and 60 inches in length. These three different sizes in electrode cables allow for differences in the placement of electrodes and the different sizes of patients.
In order to conduct the current through the body, the electrodes require water as the conducting medium. This is achieved by soaking the electrodes in water or normal saline solution and applying to the location in which current flow should be directed.
The BRC 2200 is powered by a Tenergy 3.7V Li-polymer rechargeable battery. The battery is charged by the Tenergy 3.7V Li-ion battery charger model OH-1048A0451500U. The optional USB cable allows the licensed healthcare professional to obtain treatment information and transfer it to a computer.
The BRC 2200 is a prescription device and can be used in a healthcare facility or at home.
#### Indications for Use
The BRC 2200 is intended for temporary symptomatic relief and management of chronic intractable pain and as an adjunctive treatment in the management of post-surgical and post-traumatic pain.
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K121578.
# Summary of the Technical Characteristics of the BRC2200 as Related to the Predicate Device
| Table 1 | | |
|------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | Atom 1 (Model: BRC 2200) | BodiHealth |
| 510(k) Number | Pending | K052836 |
| Intended Use | The BRC 2200 is intended for temporary symptomatic relief and management of chronic intractable pain and as an adjunctive treatment in the management of post-surgical and post-traumatic pain. | The Bodihealth System is intended for temporary symptomatic relief and management of chronic intractable pain and as an adjunctive treatment in the management of post-surgical and post-traumatic pain. |
| Power Source | Tenergy Li-ion battery 3.7V - 3Ah | Sealed lead acid rechargeable battery 6V - 4Ah |
| - Method of Line Current Isolation | N/A | N/A |
| - Patient Leakage Current | N/A | N/A |
| - Normal Condition (μΑ) | N/A | N/A |
| - Single Fault Condition (μA) | N/A | N/A |
| Average DC current through electrodes when device is on but no pulses are being applied (µΑ) | 0.002 μΑ | 0.002 μΑ |
| Number of Output Modes | 24 | 26 |
| Number of Output Channels | 1 | 1 |
| Regulated Current or Regulated Voltage? | Regulated current | Regulated current |
| Software/Firmware/Microprocessor Control? | Yes | Yes |
| Automatic Overload Trip? | Yes | Yes |
| Automatic No-Load Trip? | No | No |
| Automatic Shut Off? | Yes | No |
| Indicator Display: On/Off Status? | Yes | Yes |
| Indicator Display: Low Battery? | Yes | Yes |
| Indicator Display: Voltage/Current Level? | Yes | No |
| Indicator Display: Open Circuit? | Yes | Yes |
| Timer Range (minutes) | 92-161 minutes | User-controlled with |
| | | 23 minute cycles. |
| Compliance with Voluntary<br>Standards? | No | No |
| Compliance with 21 CFR 898? | Yes | Yes |
| Weight (lbs., oz.) | 10.5 oz. | 7 lbs., 3 oz. |
| Dimensions (in.) [W x H x D] | 5.9 in. x 3.75 in. x 1.5 in. | 9 in. x 4.5 in. x 11 in. |
| Housing Materials and Construction | Injection-molded plastic<br>case | Injection-molded<br>plastic case |
| Mode or Program Name | Treatment G, H, or I,<br>Cycle 3 | Treatment C |
| Waveform (e.g., pulsed monophasic,<br>biphasic) | Biphasic | Biphasic |
| Shape (e.g., rectangular, spike,<br>rectified sinusoidal) | Rectangular | Rectangular |
| Maximum Output Voltage (volts)<br>(+/- 5%) | 1.5V@500 Ω<br>6V@2 kΩ<br>30V@10kΩ | 1.5V@500 Ω<br>6V@2 KΩ<br>25V@10kΩ |
| Maximum Output Current (specify<br>units) (+/- 5%) | 3mA@500 Ω<br>3mA@2 kΩ<br>3mA@10kΩ | 3mA@500 Ω<br>3mA@2 kΩ<br>2.5mA@ 10 kΩ |
| Duration of primary (depolarizing)<br>phase (µsec) | N/A | N/A |
| Pulse duration (usec) | 100 ms | 128 ms |
| Frequency (Hz) [or Rate pps] | 10 Hz | 7.8 Hz |
| Net Charge (microcoulombs (µC) per<br>pulse) (If zero, state method of<br>achieving zero net charge) | 0 µC @500Ω<br>Symmetrical waveform | 0 µC @500Ω<br>Symmetrical waveform |
| Maximum Phase Charge (μC) | 3 µC @500Ω | 4.3 µC @500Ω |
| Maximum Current Density (mA/cm2,<br>r.m.s.) | 0.0205 mA/cm²@500Ω<br>(3mA/146.577 cm²) | 0.0089<br>mA/ cm²@500Ω<br>(3mA/338.7 cm²) |
| Maximum Average Current (average<br>absolute value) mA | 3mA@500Ω | 3mA@500Ω |
| Maximum Average Power Density<br>(W/cm²) (using smallest electrode<br>conductive surface area) | 30.7μW/ cm² @500Ω<br>(0.0045/146.577) | 13.297μW/ cm²<br>@500Ω<br>(0.0045/338.7) |
| ON Time (seconds) | 9660 seconds<br>(maximum treatment<br>time) | User-controlled |
| Additional Features (specify, if<br>applicable) | Data-logging | |
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K121518
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# Non-Clinical Testing
Testing of the BRC 2200 includes functional performance testing and electrical safety testing in accordance with IEC 60601-1, IEC 60601-1-2, IEC 60601-1-4, and IEC 60601-2-10. Testing of any skin-contacting materials includes biocompatibility testing in accordance with ISO 10993-1, ISO 10993-5, and ISO 10993-10.
# Conclusions
In comparison to the BodiHealth System, the BRC 2200 is substantially equivalent and has similar technical, functional, and performance characteristics. The BRC 2200 is designed to comply with the generally accepted performance specifications for TENS devices. The BRC 2200 performs as intended and does not raise any new safety or efficacy issues.
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Image /page/5/Picture/1 description: The image is a black and white logo for the U.S. Department of Health & Human Services. The logo features a stylized eagle with its wings spread, enclosed within a circular border. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged around the upper portion of the circle.
#### · Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
JUL 3 1 2012
Bioelectric Research Corporation c/o Ms. Paula Wilkerson Sr. Staff Engineer, Sr. Reviewer, Program Manager Intertek Testing Services 2307 E. Aurora Rd. Unit B7 Twinsburg, OH 44087
Re: K121578
Trade/Device Name: Atom 1, Model BRC 2200 Regulation Number: 21 CFR 882.5890 Regulation Name: Transcutaneous electrical nerve stimulator for pain relief Regulatory Class: II Product Code: GZJ Dated: July 13, 2012 Received: July 16, 2012
Dear Ms. Wilkerson:
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.
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
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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 (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.
n
Sincerely yours,
Kesia Alexander
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
Enclosure
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# Indications for Use
510(k) Number (if known): K12/ 578
Device Name: Atom 1
Model: BRC 2200
Indications for Use:
The BRC 2200 is intended for temporary symptomatic relief and management of chronic intractable pain and as an adjunctive treatment in the management of post-surgical and post-traumatic pain.
AND/OR Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use _ (Part 21 CFR 801 Subpart C)
PLEASE DO NOT WRITE BELOW THIS LINE – CONTINUE ONTO ANOTHER PAGE IF NEEDED
Concurrence of CDRH, Office of Device Evaluation (ODE)
CLLCY
(Division Sign-Off)
(Division Sign-Off) Division of Ophthalmic, Neurological and Ear, Nose and Throat Devices
510(k) Number 15121578
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.