K Number
K153311
Device Name
Flexitouch System
Date Cleared
2016-09-14

(302 days)

Product Code
Regulation Number
870.5800
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Flexitouch® system and garments for legs, arms, trunk, and chest are intended for use by medical professionals and patients who are under medical supervision, for the treatment of many conditions such as: - Lymphedema - Primary lymphedema - · Post mastectomy edema - · Edema following trauma and sports injuries - · Post immobilization edema - · Venous insufficiencies - · Reducing wound healing time · Treatment and assistance in healing stasis dermatitis, venous stasis ulcers, or arterial and diabetic leg ulcers The Flexitouch® system and garments for the head and neck are intended for use by medical professionals and patients who are under medical supervision for the treatment of head and neck lymphedema.
Device Description
The Flexitouch® system consists of two main components: a garment set and a pneumatic sequential controller. The garments are wrapped around an affected region so that the garment fits snugly. The garments have multiple chambers that are filled with air to provide for low-level compression therapy. Up to four (4) tubing harness assemblies containing eight (8) discrete individual air passage tubes connect individual garment chambers with the controller.
More Information

Not Found

No
The description focuses on pneumatic compression and does not mention any AI/ML components or capabilities.

Yes
The device is intended for the treatment of various medical conditions such as lymphedema and edema, and it delivers compression therapy to affected regions of the body.

No

The Flexitouch® system is described as a treatment device for various conditions, including lymphedema and edema, using compression therapy. Its intended use focuses on treatment and assistance in healing, rather than diagnosing conditions.

No

The device description explicitly states it consists of a garment set and a pneumatic sequential controller, which are hardware components.

Based on the provided information, the Flexitouch® system is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • IVD Definition: In Vitro Diagnostics are medical devices used to examine specimens taken from the human body (like blood, urine, tissue) to provide information for diagnosis, monitoring, or screening.
  • Flexitouch® System Function: The description clearly states that the Flexitouch® system is a pneumatic sequential compression device that applies pressure to affected body regions. It is a physical therapy device used for treatment, not for analyzing biological samples.
  • Intended Use: The intended use is for the treatment of various conditions like lymphedema and edema, and for assisting in wound healing. This is a therapeutic application, not a diagnostic one.
  • Device Description: The device consists of garments and a controller that inflates chambers with air. This mechanism is entirely external and does not involve the analysis of internal biological samples.
  • Lack of IVD Indicators: There is no mention of analyzing specimens, using reagents, or providing diagnostic information based on biological markers.

Therefore, the Flexitouch® system falls under the category of a therapeutic medical device, not an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

The Flexitouch® system and garments for legs, arms, trunk, and chest are intended for use by medical professionals and patients who are under medical supervision, for the treatment of many conditions such as:

  • Lymphedema
  • Primary lymphedema
  • Post mastectomy edema
  • Edema following trauma and sports injuries
  • Post immobilization edema
  • Venous insufficiencies
  • Reducing wound healing time
  • Treatment and assistance in healing stasis dermatitis, venous stasis ulcers, or arterial and diabetic leg ulcers

The Flexitouch® system and garments for the head and neck are intended for use by medical professionals and patients who are under medical supervision for the treatment of head and neck lymphedema.

Product codes (comma separated list FDA assigned to the subject device)

PPS, JOW

Device Description

The Flexitouch® system consists of two main components: a garment set and a pneumatic sequential controller. The garments are wrapped around an affected region so that the garment fits snugly. The garments have multiple chambers that are filled with air to provide for low-level compression therapy. Up to four (4) tubing harness assemblies containing eight (8) discrete individual air passage tubes connect individual garment chambers with the controller.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

legs, arms, trunk, chest, head and neck

Indicated Patient Age Range

patients ≥ 18 years of age

Intended User / Care Setting

medical professionals and patients who are under medical supervision

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Comparative performance testing was completed to verify the equivalence between the Flexitouch® system with head and neck garments, which is the subject of this submission, and the predicate device. Testing included software verification and validation, garment inflation/deflation, and garment pressure withstand testing. The test results verify that the safety and performance for the device met all pre-specified performance criteria and is substantially equivalent to the predicate device for its intended use.

A prospective, single-arm, single-center study was conducted to evaluate ease of application, garment fit, garment comfort, and reduction in head/neck lymphedema in patients ≥ 18 years of age diagnosed with head and/or neck lymphedema without active cancer and at least 4 weeks post cancer treatment and/or radiation. Adverse events related to the device safety profile and facial and neck composite scores were monitored. The study confirmed that use of the device in the head and neck location does not cause harm and has the potential to perform as designed. A majority of subjects were able to don and doff the device by the second attempt, reported that the garment was very/somewhat comfortable, and experienced a decrease in facial composite score. The results indicate that the benefit-risk profile of the indication for use in the head and neck is favorable.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K120972, K062818, K013061

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 870.5800 Compressible limb sleeve.

(a)
Identification. A compressible limb sleeve is a device that is used to prevent pooling of blood in a limb by inflating periodically a sleeve around the limb.(b)
Classification. Class II (performance standards).

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Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized caduceus symbol, which is a staff with two snakes coiled around it, and the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged in a circular fashion around the symbol. The caduceus is a common symbol associated with healthcare and medicine.

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

Tactile Systems Technology Inc (dba Tactile Medical) Thomas Dold Vice President, Quality and Regulatory Affairs 1331 Tyler St NE, Ste 200 Minneapolis, Minnesota 55413

Re: K153311

Trade/Device Name: Flexitouch System Regulation Number: 21 CFR 870.5800 Regulation Name: Sleeve, Head and Neck, Compressible Regulatory Class: Class II Product Code: PPS, JOW Dated: August 12, 2016 Received: August 15, 2016

Dear Mr. Dold:

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 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.

1

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 yours,

M.A. Hillebrenner

for

Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K153311

Device Name Flexitouch System

Indications for Use (Describe)

The Flexitouch® system and garments for legs, arms, trunk, and chest are intended for use by medical professionals and patients who are under medical supervision, for the treatment of many conditions such as:

  • Lymphedema
  • Primary lymphedema
  • · Post mastectomy edema
  • · Edema following trauma and sports injuries
  • · Post immobilization edema
  • · Venous insufficiencies
  • · Reducing wound healing time

· Treatment and assistance in healing stasis dermatitis, venous stasis ulcers, or arterial and diabetic leg ulcers

The Flexitouch® system and garments for the head and neck are intended for use by medical professionals and patients who are under medical supervision for the treatment of head and neck lymphedema.

Type of Use (Select one or both, as applicable)
☑ Prescription Use (Part 21 CFR 801 Subpart D)☐ Over-The-Counter Use (21 CFR 801 Subpart C)

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K153311: 510(k) Summary

Submission Date:16 November 2015
Submitter:Thomas A. Dold
Vice President, Quality and Regulatory Affairs
Tactile Systems Technology, Inc. (DBA Tactile Medical)
1331 Tyler Street NE, Suite 200
Minneapolis, MN 55413
Phone: (612) 355-5100
Contact person:Thomas A. Dold
Name of Device:Flexitouch® system
FDA Regulation:Sleeve, Head and Neck, Compressible (21 CFR 870.5800)
Device Classification:Class II
Predicate Device:Tactile Systems Technology, Inc. Flexitouch® system (K120972 K062818 & K013061)

Description of Device

The Flexitouch® system consists of two main components: a garment set and a pneumatic sequential controller. The garments are wrapped around an affected region so that the garment fits snugly. The garments have multiple chambers that are filled with air to provide for low-level compression therapy. Up to four (4) tubing harness assemblies containing eight (8) discrete individual air passage tubes connect individual garment chambers with the controller.

Indications for Use:

The Flexitouch® system and garments for legs, arms, trunk, and chest are intended for use by medical professionals and patients who are under medical supervision, for the treatment of many conditions such as:

  • Lymphedema ●
  • Primary lymphedema ●
  • Post mastectomy edema
  • Edema following trauma and sports injuries
  • Post immobilization edema
  • Venous insufficiencies
  • . Reducing wound healing time
  • . Treatment and assistance in healing stasis dermatitis, venous stasis ulcers, or arterial and diabetic leg ulcers

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The Flexitouch® system and garments for the head and neck are intended for use by medical professionals and patients who are under medical supervision for the treatment of head and neck lymphedema.

Comparison of Technological Characteristics:

The Flexitouch® system has the same technological characteristics to the predicate device with respect to, design, materials used, and construction. The head and neck garments referenced in this submission are indicated for use in head and neck lymphedema, a new anatomical location. The new garments use the same controller as the predicate device, with a separate program in the software specific for head and neck treatment. The table below summarizes the comparison of technological characteristics. Non-clinical and clinical testing results support use of the Flexitouch device in the new anatomical location, and demonstrate that no new questions of safety and effectiveness are raised.

| | Flexitouch System including Head
and Neck Garments
(Current Submission K153311) | Flexitouch System Predicate
Device
(K120972, K062818, K013061) |
|--------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Indications for Use | The Flexitouch® system and
garments for legs, arms, trunk, and
chest are indicated for use by medical
professionals and patients who are
under medical supervision for the
treatment of many conditions such as:
lymphedema, primary lymphedema,
post mastectomy edema, edema
following trauma and sports injuries,
post immobilization edema, venous
insufficiencies, reducing wound
healing time, treatment and assistance
in healing stasis dermatitis; venous
stasis ulcers, or arterial and diabetic
leg ulcers.

The Flexitouch® System and
garments for the head and neck are
intended for use by medical
professionals and patients who are
under medical supervision for the
treatment of head and neck
lymphedema. | The Flexitouch® system is
indicated for use by medical
professionals and patients who are
under medical supervision for the
treatment of many conditions such
as: lymphedema, primary
lymphedema, post mastectomy
edema, edema following trauma
and sports injuries, post
immobilization edema, venous
insufficiencies, reducing wound
healing time, treatment and
assistance in healing stasis
dermatitis; venous stasis ulcers, or
arterial and diabetic leg ulcers |
| FDA Classification | Class II | Class II |
| FDA Product Code | PPS (primary), JOW (secondary) | JOW |
| FDA Regulation | 21 CFR 870.5800 | 21 CFR 870.5800 |
| Prescription
Required | Yes | Yes |

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Controller Design
Size5.5" x 12.25" x 10.5"5.5" x 12.25" x 10.5"
Weight8 lbs8 lbs
Electrical
Requirements100-240 VAC, 1.0 A, 50/60 Hz
UL/CUL100-240 VAC, 1.0 A, 50/60 Hz
UL/CUL
Enclosure MaterialPlastic constructionPlastic construction
Manifold
AssemblyPlastic construction with integrated
air channelsPlastic construction with integrated
air channels
User InterfaceTactile push buttonsTactile push buttons
Software-concern
LevelModerateModerate
Software/HardwareAnalog and digital electronics with
microprocessorAnalog and digital electronics with
microprocessor
ChambersUp to 32 depending on garment size
and typeUp to 32 depending on garment
size and type
Pressure Range25-75 mmHg25-75 mmHg
Inflation time per
chamber1-6 seconds1-6 seconds
OutputSequential/IntermittentSequential/Intermittent
Inflatable Garments
MaterialNylon outer layer, polyurethane inner
layerNylon outer layer, polyurethane
inner layer
Port MaterialPolyurethanePolyurethane
Garment
ConnectorsPlastic constructionPlastic construction
SterilityNon-sterileNon-sterile
Garment Type and
SizesArm - left or right, short or long
Chest – left or right, 4 sizes
Trunk-thigh - left or right
Universal Trunk
Calf-foot - left or right, regular or
EXT
Trunk/thigh - left or right, short, long
or EXT
Full leg/trunk
Full leg – left or right, short medium,
long
Head and Neck GarmentArm - left or right, short or long
Chest – left or right, 4 sizes
Trunk-thigh - left or right
Universal Trunk
Calf-foot - left or right, regular or
EXT
Trunk/thigh – left or right, short,
long or EXT
Full leg/trunk
Full leg – left or right, short
medium, long

Summary of Performance Testing:

Comparative performance testing was completed to verify the equivalence between the Flexitouch® system with head and neck garments, which is the subject of this submission, and the predicate device. Testing included software verification and validation, garment inflation/deflation, and garment pressure withstand testing. The test results verify that the safety

6

and performance for the device met all pre-specified performance criteria and is substantially equivalent to the predicate device for its intended use.

Summary of Clinical Evaluation:

A prospective, single-arm, single-center study was conducted to evaluate ease of application, garment fit, garment comfort, and reduction in head/neck lymphedema in patients ≥ 18 years of age diagnosed with head and/or neck lymphedema without active cancer and at least 4 weeks post cancer treatment and/or radiation. Adverse events related to the device safety profile and facial and neck composite scores were monitored. The study confirmed that use of the device in the head and neck location does not cause harm and has the potential to perform as designed. A majority of subjects were able to don and doff the device by the second attempt, reported that the garment was very/somewhat comfortable, and experienced a decrease in facial composite score. The results indicate that the benefit-risk profile of the indication for use in the head and neck is favorable.

Conclusion:

The results from the nonclinical and clinical device evaluations, which are referenced herein, demonstrate that the Flexitouch® system is substantially equivalent to the predicate device.