K162240 · Promedtek, Inc. · IMJ · Nov 17, 2016 · Physical Medicine
Device Facts
Record ID
K162240
Device Name
ProMedTek Model C1400 Shortwave Diathermy Device
Applicant
Promedtek, Inc.
Product Code
IMJ · Physical Medicine
Decision Date
Nov 17, 2016
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 890.5290
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The ProMedTek Model C1400 Shortwave Diathermy device delivers energy in the radio band of 27.12 MHz to provide deep heating therapeutic effects to body tissues. When shortwave diathermy is delivered to the body at intensities capable of generating a deep tissue temperature increase, it can be used to treat selected medical conditions such as: 1. Relieving pain 2. Reducing muscle spasm 3. Increasing range of motion of contracted joints using heat and stretch techniques. 4. Increasing blood flow to tissues in the treatment area.
Device Story
Device delivers 27.12 MHz radio frequency energy for deep tissue heating; utilizes inductive drum or soft-rubber electrodes. Operated by clinicians in clinical settings; mounted on a mobile cart with locking wheels. User interface features LCD touch screen for setup and parameter selection (continuous/pulsed modes, pulse rates 10-400 Hz, pulse widths 65-400 μs). Includes patient safety pull-cord to terminate output. Output provides therapeutic heat to treat pain, muscle spasms, joint contractures, and blood flow deficits. Benefits include non-invasive deep tissue thermal therapy.
Clinical Evidence
Bench testing only. No clinical data provided. Evidence includes software verification and validation (moderate level of concern) and compliance with electrical safety and electromagnetic compatibility standards (IEC 60601-1, IEC 60601-1-2, IEC 60601-2-3).
Technological Characteristics
Shortwave diathermy device operating at 27.12 MHz. Components: mobile cart, arm, inductive drum applicator, soft-rubber electrodes. Power: 100-240 VAC, 50-60 Hz. Output: 100 W average (continuous), 200 W peak (pulsed). Modes: Inductive and capacitive. Software-controlled via LCD touch screen. Standards: IEC 60601-1, IEC 60601-1-2, IEC 60601-2-3.
Indications for Use
Indicated for patients requiring deep tissue heating to relieve pain, reduce muscle spasm, increase range of motion of contracted joints, or increase blood flow to tissues.
Regulatory Classification
Identification
A nonthermal shortwave therapy is a prescription device that applies to the body pulsed electromagnetic energy in the RF bands of 13.56 MHz or 27.12 MHz and that is intended for adjunctive use in the palliative treatment of postoperative pain and edema of soft tissue by means other than the generation of deep heat within body tissues as described in paragraph (a) of this section.
Special Controls
*Classification: Class II (special controls).* The device is classified as class II. The special controls for this device are:(i) Components of the device that come into human contact must be demonstrated to be biocompatible.
(ii) Appropriate analysis/testing must demonstrate that the device is electrically safe and electromagnetically compatible in its intended use environment.
(iii) Non-clinical performance testing must demonstrate that the device performs as intended under anticipated conditions of use. Non-clinical performance testing must characterize the output waveform of the device and demonstrate that the device meets appropriate output performance specifications. The output characteristics and the methods used to determine these characteristics, including the following, must be determined:
(A) Peak output power;
(B) Pulse width;
(C) Pulse frequency;
(D) Duty cycle;
(E) Characteristics of other types of modulation that may be used;
(F) Average measured output powered into the RF antenna/applicator;
(G) Specific absorption rates in saline gel test load or other appropriate model;
(H) Characterization of the electrical and magnetic fields in saline gel test load or other appropriate model for each RF antenna and prescribed RF antenna orientation/position; and
(I) Characterization of the deposited energy density in saline gel test load or other appropriate model.
(iv) A detailed summary of the clinical testing pertinent to use of the device to demonstrate the effectiveness of the device in its intended use.
(v) Labeling must include the following:
(A) Output characteristics of the device;
(B) Recommended treatment regimes, including duration of use; and
(C) A detailed summary of the clinical testing pertinent to the use of the device and a summary of the adverse events and complications.
(vi) Nonthermal shortwave therapy devices marketed prior to the effective date of this reclassification must submit an amendment to their previously cleared premarket notification (510(k)) demonstrating compliance with these special controls.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
November 17, 2016
ProMedTek Inc. % Diane Horwitz President Mandell Horwitz Consultants LLC 2995 Steven Martin Dr. Fairfax, Virginia 22031
Re: K162240
Trade/Device Name: ProMedTek Model C1400 Shortwave Diathermy Device Regulation Number: 21 CFR 890.5290 Regulation Name: Shortwave Diathermy Regulatory Class: Class II Product Code: IMJ Dated: October 14, 2016 Received: October 15, 2016
Dear Ms. Horwitz:
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 device
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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 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,
# Michael J. Hoffmann -A
for Carlos L. Peña, PhD, MS Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K162440
Device Name
ProMedTek Model C1400 Shortwave Diathermy Device
Indications for Use (Describe)
The ProMedTek Model C1400 Shortwave Diathermy device delivers energy in the radio band of 27.12 MHz to provide deep heating therapeutic effects to body tissues. When shortwave diathermy is delivered to the body at intensities capable of generating a deep tissue temperature increase, it can be used to treat selected medical conditions such as:
- 1. Relieving pain
- 2. Reducing muscle spasm
- 3. Increasing range of motion of contracted joints using heat and stretch techniques
- 4. Increasing blood flow to tissues in the treatment area
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 PROMEDTEK. The logo features the company name in gray, with a stylized figure above the "M" and a globe in orange replacing the "O". The font is sans-serif and appears to be a modern design.
# 510(k) SUMMARY
#### GENERAL INFORMATION 1.
#### 1.1 Submitter and 510(k) Owner
Dan Puchek, President and CEO ProMedTek Inc. 4110 N Scottsdale Road, Suite 270 Scottsdale AZ 85251
#### 1.2 Official Correspondent
Diane Horwitz, Ph.D., RAC, Regulatory Consultant 2995 Steven Martin Dr. Fairfax, VA 22031
Telephone: 703.307.2921 Fax: 703.242.1117 Email: dmh@mandellhorwitzconsulting.com
#### 1.3 Date of Preparation
November 15, 2016
#### 2. NAME OF THE DEVICE
#### 2.1.1 Trade/Proprietary Name
ProMedTek Model C1400 Shortwave Diathermy
#### 2.1.2 Common/Usual Name
Diathermy, Shortwave, for use in Applying Therapeutic Deep Heat
#### 2.1.3 Classification Information
| Classification Name: | Shortwave diathermy |
|----------------------------|---------------------|
| Classification Regulation: | 21 CFR 890.5290 |
| Class: | II |
| Product Code: | IMJ |
| Panel: | Physical Medicine |
#### 3. PREDICATE DEVICE
The predicate device is Auto Therm 390, Model ME 390 (Mettler Electronics Corp., K042554).
1
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Image /page/4/Picture/0 description: The image shows the logo for PROMEDTEK. The logo is in gray and orange. The letters are in gray, and there is an orange globe in the middle of the logo.
#### 4. DESCRIPTION OF THE DEVICE
The ProMedTek C1400 shortwave diathermy device operates at 27.12 MHz. It provides traditional shortwave diathermy using an inductive drum or soft-rubber electrodes. The unit offers both continuous or pulsed modes of operation with a variety of frequencies and pulse widths to choose from. An easy-to-use LCD Touch Screen guides the user through setup. A Patient Safety Pull-Cord allows the patient to stop all output. The base of the ProMedTek C1400 is a sturdy cart with large locking wheels that allows the ProMedTek C1400 to be moved easily around the clinic and supports the arm and drum applicator during treatment.
#### 5. INTENDED USE
The intended use / indications for use for the Model C1400 Shortwave Diathermy is as follows:
"The ProMedTek Model C1400 Shortwave Diathermy device delivers energy in the radio band of 27.12 MHz to provide deep heating therapeutic effects to body tissues. When shortwave diathermy is delivered to the body at intensities capable of generating a deep tissue temperature increase, it can be used to treat selected medical conditions such as:
- 1. Relieving pain
- 2. Reducing muscle spasm
- 3. Increasing range of motion of contracted joints using heat and stretch techniques.
- 4. Increasing blood flow to tissues in the treatment area."
#### SUBSTANTIAL EQUIVALENCE COMPARISON 6.
The Model C1400 Shortwave Diathermy and the predicate device share intended use and technological features. The intended use and indications for use statements are almost identical. There are no differences in technology between the two devices. A comparison of the characteristics to the predicate device follows.
| Characteristic | ProMedTek Model C1400<br>Shortwave Diathermy<br>New device | Predicate (K042554)<br>AutoTherm 390<br>Mettler Electronics Corp. |
|----------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| INTENDED USE / INDICATIONS FOR USE STATEMENT | | |
| Statement | The ProMedTek Model C1400<br>Shortwave Diathermy device delivers<br>energy in the radio band of 27.12<br>MHz to provide deep heating<br>therapeutic effects to body tissues.<br>When shortwave diathermy is<br>delivered to the body at intensities<br>capable of generating a deep tissue<br>temperature increase, it can be used to<br>treat selected medical conditions such<br>as:<br>1. Relieving pain<br>2. Reducing muscle spasm | Shortwave diathermy delivers<br>energy in the radio band of 27.12<br>MHz to provide deep heating<br>therapeutic effects to body<br>tissues. When shortwave<br>diathermy is delivered to the<br>body at intensities capable of<br>generating a deep tissue<br>temperature increase, it can be<br>used to treat selected medical<br>conditions such as:<br>1. Relieving pain<br>2. Reducing muscle spasm |
| Characteristic | ProMedTek Model C1400<br>Shortwave Diathermy | Predicate (K042554)<br>AutoTherm 390 |
| | New device | Mettler Electronics Corp. |
| | 3. Increasing range of motion of<br>contracted joints using heat and<br>stretch techniques.<br>4. Increasing blood flow to tissues in<br>the treatment area. | 3. Increasing range of motion of<br>contracted joints using heat and<br>stretch techniques.<br>4. Increasing blood flow to<br>tissues in the treatment area. |
| TECHNOLOGY | | |
| System Components | Unit with Cart and Arm for Inductive<br>Drum Applicator | Same |
| Applicator Components | Inductive Drum Applicator<br>Soft-Rubber Applicators (2) | Same |
| Accessories | Felt spacers for Soft-Rubber<br>Applicators (6)<br>Cloth cover for Soft-Rubber<br>Applicators (2)<br>Velcro Receptive Elastic Straps (2) | Same |
| Input | 100-240 VAC, 50-60 Hz | Same |
| Frequency | 27.12 MHz | Same |
| Output Types | Continuous<br>Pulsed | Same |
| HF Output Continuous | 100 W Average Power | Same |
| HF Output Pulsed | 200 W Peak Power | Same |
| Pulse Rate Settings | 10Hz, 20 Hz, 50 Hz, 100 Hz, 400 Hz | Same |
| Pulse Width Settings | 65 μs, 100 μs, 200 μs, 300 μs, 400 μs | Same |
| Modes | Inductive<br>Capacitive | Same |
| Treatment Time | 1-30 minutes | Same |
| Software controlled | Yes | Same |
| User Display and<br>Interface | LCD Touch Screen displays<br>interactive instructions and indicators | Similar<br>User interface has tactile<br>selection buttons and LED<br>indicators |
## TECHNOLOGY OF THE MODEL C1400 SHORTWAVE DIATHERMY AND THE PREDICATE DEVICE
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Image /page/5/Picture/0 description: The image shows the logo for PROMEDTEK. The logo features the company name in a bold, sans-serif font, with the letters in gray. Above the letters 'OM' is a stylized graphic of a person with their arms raised above their head, and the letter 'O' is replaced with an orange globe.
#### PERFORMANCE TESTING 7.
The 510(k) submission provided performance data to establish the substantial equivalence of the ProMedTek Model C1400 to the predicate device. A summary of these performance tests is provided below.
Software verification and validation testing: Software verification and validation testing was conducted and documentation was provided as recommended by FDA's Guidance for Industry and
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Image /page/6/Picture/0 description: The image shows the logo for PROMEDTEK. The logo is in gray, except for the globe in the middle of the logo, which is orange. The logo also includes a figure above the globe.
FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices." The software for this device was considered as a "moderate" level of concern.
Electrical safety and electromagnetic compatibility: The Model C1400 complies with IEC 60601-1, IEC 60601-1-2 and IEC 60601-2-3 and was found to meet all applicable requirements.
#### 8. CONCLUSIONS
This 510(k) submission demonstrates that the ProMedTek Model C1400 is substantially equivalent to the 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.