K162010 · BTL Industries, Inc. · KPI · Dec 13, 2016 · Gastroenterology, Urology
Device Facts
Record ID
K162010
Device Name
HPM-6000U
Applicant
BTL Industries, Inc.
Product Code
KPI · Gastroenterology, Urology
Decision Date
Dec 13, 2016
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 876.5320
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
HPM-6000U is intended to provide entirely non-invasive electromagnetic stimulation of pelvic floor musculature for the purpose of rehabilitation of weak pelvic muscles and restoration of neuromuscular control for the treatment of urinary incontinence in women.
Device Story
HPM-6000U is a non-invasive therapeutic device for pelvic floor muscle rehabilitation. It utilizes an electromagnetic field generated by a single coil within a chair-based applicator to induce action potentials in nerves, resulting in muscle contraction. The device is operated by a clinician in a clinical setting. The user interacts with a color touch screen to set therapeutic parameters, including pulse repetition rate (1-150 Hz) and amplitude (0-100%). The device provides continuous stimulation for a 30-minute session. By stimulating the pelvic floor musculature, the device aims to strengthen muscles and restore neuromuscular control, potentially benefiting patients suffering from urinary incontinence. The clinician monitors the therapy via the on-screen display, which shows the applied therapy type, remaining time, and main parameters.
Clinical Evidence
No clinical data. Substantial equivalence is demonstrated through comparison of technical characteristics and bench testing, including electrical safety (IEC 60601-1), electromagnetic compatibility (IEC 60601-1-2), usability (IEC 60601-1-6), and biological evaluation (ISO 10993-1, 5, 10).
Technological Characteristics
Non-invasive electromagnetic stimulator; chair-based applicator with single magnetic coil; magnetic field intensity 0.7-2.5 T; pulse repetition rate 1-150 Hz; pulse duration 280 μs; sine, biphasic pulse shape. Powered by 100-240 V AC. Complies with ISO 14971, IEC 62304, IEC 60601-1, IEC 60601-1-2, IEC 60601-1-6, ISO 10993-1, ISO 10993-5, ISO 10993-10.
Indications for Use
Indicated for women with urinary incontinence requiring rehabilitation of weak pelvic floor muscles and restoration of neuromuscular control.
Regulatory Classification
Identification
A nonimplanted electrical continence device is a device that consists of a pair of electrodes on a plug or a pessary that are connected by an electrical cable to a battery-powered pulse source. The plug or pessary is inserted into the rectum or into the vagina and used to stimulate the muscles of the pelvic floor to maintain urinary or fecal continence. When necessary, the plug or pessary may be removed by the user. This device excludes an AC-powered nonimplanted electrical continence device and the powered vaginal muscle stimulator for therapeutic use (§ 884.5940).
Predicate Devices
Neotonus Model 1000 Muscle Stimulator System (K973096)
Submission Summary (Full Text)
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
December 13, 2016
BTL Industries, Inc. % Jan Zarsky Director 47 Loring Drive Framingham, MA 01702
Re: K162010 Trade/Device Name: HPM-6000U Regulation Number: 21 CFR 876.5320 Regulation Name: Nonimplanted Electrical Continence Device Regulatory Class: Class II Product Code: KPI Dated: September 15, 2016 Received: September 16, 2016
Dear Jan Zarsky,
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 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 devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in
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the quality systems (OS) 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 contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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 Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely,
# Joyce M. Whang -S
for
Benjamin R. Fisher, Ph.D. Director Division of Reproductive, Gastro-Renal, and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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#### Indications for Use
510(k) Number (if known) Not known K162010 Device Name HPM-6000U
Indications for Use (Describe)
HPM-6000U is intended to provide entirely non-invasive electromagnetic stimulation of pelvic floor musculature for the purpose of rehabilitation of weak pelvic muscles and restoration of neuromuscular control for the treatment of urinary incontinence in women.
Type of Use (Select one or both, as applicable)
X Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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Image /page/3/Picture/0 description: The image shows the logo for BTL Industries. The logo consists of three blue squares, each rotated 45 degrees, with the letters "BTL" inside. To the right of the squares is the text "BTL Industries" in a dark gray sans-serif font.
## 510(k) Summary
### General Information
| Sponsor: | BTL Industries, Inc.<br>47 Loring Drive<br>Framingham, MA 01702<br>Tel: +1-866-285-1656<br>Fax: +1-888-499-2502 |
|------------------------------|-----------------------------------------------------------------------------------------------------------------|
| Applicant: | BTL Industries, Inc.<br>47 Loring Drive<br>Framingham, MA 01702<br>Tel: +1-866-285-1656<br>Fax: +1-888-499-2502 |
| Contact Person: | Jan Žársky<br>Director<br>BTL Industries, Inc.<br>zarsky@btlnet.com |
| Summary Preparation<br>Date: | July 19, 2016 |
#### Device Name
| Trade/Proprietary Name: | HPM-6000U |
|------------------------------|--------------------------------------------------------------|
| Primary Classification Name: | Stimulator, Electrical, Non-Implantable, For<br>Incontinence |
| Classification Regulation: | 21 CFR 876.5320, Class II |
| Classification Product Code: | KPI |
#### Legally Marketed Predicate Devices
The HPM-6000U is a non-invasive therapeutic device, and is substantially equivalent to the current product that is already cleared for distribution in the USA under the following 510(k) Premarket Notification number:
Neotonus Model 1000 Muscle Stimulator System (K973096)
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## Product Description
The HPM-6000U is a non-invasive therapeutic device. The device produces electromagnetic field that interacts with the tissues of the human body. The electromagnetic field delivered in the muscular or neuronal tissue area is triggering the stimulation and tonisation.
The HPM-6000U is equipped with a color touch screen with wide view angle that significantly facilitates the use of the device. The on-screen information guides the user step-by-step through the entire therapy procedure. The therapeutic parameters are easily set using the touch screen, buttons and knob on the device. During the therapy the device keeps information about the applied therapy type, remaining therapy time and main therapy parameters on the screen.
### Intended Use
HPM-6000U is intended to provide entirely non-invasive electromagnetic stimulation of pelvic floor musculature for the purpose of rehabilitation of weak pelvic muscles and restoration of neuromuscular control for the treatment of urinary incontinence in women.
## Non-clinical Testing
The HPM-6000U device has been thoroughly evaluated for electrical safety. The HPM-6000U has been found to comply with the following applicable medical device safety standards:
| ISO 14971 | Medical devices - Application of risk management to medical<br>devices |
|---------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| IEC 62304 | Medical device software - Software life cycle processes |
| IEC 60601-1 | Medical electrical equipment - Part 1: General requirements<br>for basic safety and essential performance |
| IEC 60601-1-2 | Medical electrical equipment – Part 1-2: General requirements<br>for basic safety and essential performance - Collateral<br>standard: Electromagnetic compatibility – Requirements and<br>tests |
| IEC 60601-1-6 | Medical electrical equipment – Part 1-6: General requirements<br>for basic safety and essential performance - Collateral<br>standard: Usability |
| ISO 10993-1 | Biological evaluation of medical devices – Part 1: Evaluation<br>and testing within a risk management process |
| ISO 10993-5 | Biological evaluation of medical devices - Part 5: Tests for in<br>vitro cytotoxicity |
| ISO 10993-10 | Biological evaluation of medical devices - Part 10: Tests for<br>irritation and skin sensitization |
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Image /page/5/Picture/0 description: The image shows the logo for BTL Industries. The logo consists of three blue squares nested inside each other, with the letters "BTL" in white inside the innermost square. To the right of the logo is the text "BTL Industries" in a gray, sans-serif font.
### Clinical testing
The substantial equivalence determination for the HPM-6000U is not based on clinical testing. The device safety and efficacy was demonstrated by comparison of technical characteristics between the HPM-6000U and the predicate device.
### Comparison with the Predicate Device
| 510(k) number | Not Assigned | K973096 |
|-------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Device name | HPM-6000U | Neotonus Model 1000<br>Muscle Stimulator System |
| Company name | BTL Industries, Inc. | Neotonus, Inc. |
| Product Code<br>and Regulation | Gastroenterology-Urology<br>Devices<br>21 CFR 876.5320<br>KPI - Stimulator, Electrical,<br>Non-Implantable, For<br>Incontinence | Gastroenterology-Urology<br>Devices<br>21 CFR 876.5320<br>KPI - Stimulator, Electrical,<br>Non-Implantable, For<br>Incontinence |
| Intended Use | HPM-6000U is intended to<br>provide entirely non-<br>invasive electromagnetic<br>stimulation of pelvic floor<br>musculature for the<br>purpose of rehabilitation of<br>weak pelvic muscles and<br>restoration of<br>neuromuscular control for<br>the treatment of urinary<br>incontinence in women. | Neotonus Model 1000 Muscle<br>Stimulator System is intended<br>to provide entirely non-<br>invasive electromagnetic<br>stimulation of pelvic floor<br>musculature for the purpose<br>of rehabilitation of weak pelvic<br>muscles and restoration of<br>neuromuscular control for the<br>treatment of urinary<br>incontinence in women. |
| Primary Function | Stimulation of pelvic floor<br>musculature | Stimulation of pelvic floor<br>musculature |
| Principle of<br>Action | Initiating action potential of<br>nerves results in muscle<br>contraction | Initiating action potential of<br>nerves results in muscle<br>contraction |
| Type of Energy | Magnetic field | Magnetic field |
| Energy Source | 100 - 240 V AC, 50 - 60<br>Hz, max 14 A | 110 V AC, 50 - 60 Hz,<br>max 12 A |
| Type of Coil | Single magnetic coil | Single magnetic coil |
| Number of | 1 | 1 |
| 510(k) number | Not Assigned | K973096 |
| Device name | HPM-6000U | Neotonus Model 1000<br>Muscle Stimulator System |
| Company name | BTL Industries, Inc. | Neotonus, Inc. |
| Magnetic Coils<br>in the Applicator | | |
| Type of<br>Applicator | Chair | Chair |
| Number of<br>Applicators | 1 | 1 |
| Patient Position<br>during Therapy | Sitting position | Sitting position |
| Position of Coil | Center of applicator seat | Center of applicator seat |
| Type of<br>Operation | Continuous | Continuous |
| Magnetic Field<br>Intensity | 0.7 - 2.5 T | Up to 2.2 T |
| Pulse Repetition<br>Rate | 1 - 150 Hz | 1 – 55 Hz |
| Step of<br>Frequency<br>Setting | 1 Hz | 1 Hz |
| Pulse Duration | 280 μs (± 20%) | 275 μs |
| Pulse Amplitude | 0 – 100 % | 0 - 100 % |
| Shape of<br>Stimulation<br>Pulse | Sine, biphasic | Sine, biphasic |
| Therapy Time | 30 min | 30 min |
| Operating<br>Temperature | +10 to +30 °C (50 - 86 °F) | +10 to +30 °C (50 - 86 °F) |
| Interface | Touch-screen | Graphical Display |
| Firmware<br>controlled | Yes | Yes |
| Environmental<br>Specifications | For indoor use only | For indoor use only |
| Clinical Use | Prescription Use | Prescription Use |
| 510(k) number | Not Assigned | K973096 |
| Device name | HPM-6000U | Neotonus Model 1000<br>Muscle Stimulator System |
| Company name | BTL Industries, Inc. | Neotonus, Inc. |
| External<br>Exchangeable<br>Fuse | Yes | Yes |
| Main Unit<br>Dimensions<br>(W×H×D) | 500×970×580 mm<br>(20×38×23 in) | 580×170×320 mm<br>(23×7×12.5 in) |
| Applicator<br>Dimensions<br>(W×H×D) | 730x730x730 mm<br>(29x29x29 in) | 700x1250x785 mm<br>(27.5x49x31 in) |
| System Weight | 46 kg (101 lb) | 42.5 kg |
| Position | Vertical - On castors | Horizontal |
| Electrical<br>Protection | Class II, BF | Class II |
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Image /page/6/Picture/0 description: The image shows the logo for BTL Industries. The logo consists of three nested squares with the letters BTL inside them. To the right of the logo is the text "BTL Industries" in a simple, sans-serif font.
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### Substantial Equivalence
Based upon the intended use and known technical information provided in this pre-market notification, the HPM-6000U device has been shown to be substantially equivalent to currently marketed predicate device. Thorough Substantial Equivalence Discussion is provided in Section 12.
### Conclusion
Based on the aforementioned information, the HPM-6000U is safe and effective and substantially equivalent to the identified predicate device.
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.