K Number
K201645
Device Name
Massage Compression Boots
Manufacturer
Date Cleared
2020-09-15

(90 days)

Product Code
Regulation Number
890.5650
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Massage Compression Boots are intended for the temporary relief of minor muscle aches and for the temporary increase in circulation to the treated areas. The device can simulate kneading and stroking of tissues by using an inflatable garment.
Device Description
The subject device is a portable and rechargeable device. It is intended to be an over-the-counter portable inflatable tube massage system which simulates kneading and stroking of tissue by use of an inflatable garment. It can be used to temporarily increase blood circulation and temporarily relieve minor muscle aches and pains. The device, supplied clean and non-sterile, utilizes the pneumatically controlled chambers actuated by an electronically controlled air pump unit. All pump, battery and control components are protectively housed in a plastic case of the control unit that is permanently attached to an inflatable sleeve of multiple air chambers. An ON/OFF button, a SET button, and a display of LEDs provide for user interface. There is also a port for connecting the battery charger/AC adapter plug. The sleeve component consists of multiple air chambers/bladders encased inside a soft medical fabric or equivalent medical for increased patient comfort and biocompatibility compliance.
More Information

No
The description focuses on pneumatic control and user interface via buttons and LEDs, with no mention of AI/ML terms or capabilities.

Yes
This device is intended for temporary relief of minor muscle aches and temporary increase in circulation, which are therapeutic claims. Furthermore, the predicate devices are identified as "Massage System" and "Compression Therapy Device," indicating a therapeutic purpose.

No

The device is intended for temporary relief of muscle aches and temporary increase in circulation, not for diagnosing medical conditions.

No

The device description explicitly details hardware components including an air pump unit, battery, control components housed in a plastic case, an inflatable sleeve with air chambers, and user interface buttons and LEDs. The performance studies also mention testing for electrical safety and electromagnetic compatibility, which are hardware-related.

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

Here's why:

  • IVD Definition: In Vitro Diagnostic devices are used to examine specimens taken from the human body (like blood, urine, or tissue) to provide information about a person's health. This is typically done in a laboratory setting.
  • Device Function: The description clearly states the device is a "Massage Compression Boot" system that uses inflatable garments to simulate kneading and stroking of tissues. Its intended uses are for temporary relief of minor muscle aches and temporary increase in circulation.
  • Mechanism of Action: The device works externally on the body through pneumatic compression, not by analyzing biological samples.
  • Lack of IVD Indicators: The document does not mention any analysis of biological specimens, laboratory procedures, or diagnostic purposes.

The device described is a physical therapy or massage device that applies external pressure to the body.

N/A

Intended Use / Indications for Use

The Massage Compression Boots are intended for the temporary relief of minor muscle aches and for the temporary increase in circulation to the treated areas. The device can simulate kneading and stroking of tissues by using an inflatable garment.

Product codes

IRP

Device Description

The subject device is a portable and rechargeable device. It is intended to be an over-the-counter portable inflatable tube massage system which simulates kneading and stroking of tissue by use of an inflatable garment. It can be used to temporarily increase blood circulation and temporarily relieve minor muscle aches and pains.

The device, supplied clean and non-sterile, utilizes the pneumatically controlled chambers actuated by an electronically controlled air pump unit. All pump, battery and control components are protectively housed in a plastic case of the control unit that is permanently attached to an inflatable sleeve of multiple air chambers. An ON/OFF button, a SET button, and a display of LEDs provide for user interface. There is also a port for connecting the battery charger/AC adapter plug. The sleeve component consists of multiple air chambers/bladders encased inside a soft medical fabric or equivalent medical for increased patient comfort and biocompatibility compliance.

In operation, the user simply turns the power on via the ON/OFF button. A sleeve containing the air chambers is connected to the control unit. And the control unit then inflates the sleeve to the predetermined or adjusted pressure. The sleeve pressure is monitored by an internal pressure switch and system software. Once the sleeve pressure of the air chambers reaches the proper level, the pump is turned off for a rest period, and the sleeve deflates to the ambient pressure through a valve inside the plastic case. After the rest period, the cycle of inflation repeats until the unit is turned off.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Leg, arm/shoulder, and hip/waist

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Users who need temporary increase of blood circulation in the treated area and temporary relief of minor muscular aches and pains.
Clinics, hospital, athlete training, and home environments

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)

Non-clinical tests were performed on the subject device in order to validate the design and to assure conformance with the following voluntary design standards in connection with medical device electrical safety, and electromagnetic compatibility.
(a) ANSI AAMI ES60601-1 "Medical Electrical Equipment Part 1: General requirements for basic safety and essential performance (IEC 60601-1)".
(b) IEC 60601-1-2 "Medical Electrical Equipment Part 1-2: General Requirements for Basic Safety and Essential Performance - Collateral standard: Electromagnetic Compatibility - Requirements and Tests".
In addition to the compliance of voluntary standards, bench tests have been performed on the physical requirements, electrical requirement, and performance requirement; the verification of software used in the subject device has been carried out according to the FDA Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices.

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

Not Found

Predicate Device(s)

K122112, K191862

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 890.5650 Powered inflatable tube massager.

(a)
Identification. A powered inflatable tube massager is a powered device intended for medical purposes, such as to relieve minor muscle aches and pains and to increase circulation. It simulates kneading and stroking of tissues with the hands by use of an inflatable pressure cuff.(b)
Classification. Class II (performance standards).

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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

September 15, 2020

JKH USA, LLC Bill Dai Manager 14271 Jeffrey Rd. #246 Irvine, California 92620

Re: K201645

Trade/Device Name: Massage Compression Boots Regulation Number: 21 CFR 890.5650 Regulation Name: Powered Inflatable Tube Massager Regulatory Class: Class II Product Code: IRP Dated: June 14, 2020 Received: June 17, 2020

Dear Dr. Bill Dai:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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

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requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Amber Ballard, PhD Assistant Director DHT5B: Division of Neuromodulation and Physical Medicine Devices OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

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Indications for Use

510(k) Number (if known) K201645

Device Name Massage Compression Boots

Indications for Use (Describe)

The Massage Compression Boots are intended for the temporary relief of minor muscle aches and for the temporary increase in circulation to the treated areas. The device can simulate kneading and stroking of tissues by using an inflatable garment.

Type of Use (Select one or both, as applicable)
---------------------------------------------------

Prescription Use (Part 21 CFR 801 Subpart D)

X Over-The-Counter Use (21 CFR 801 Subpart C)

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510(k) Summary

1. Submitter's Information

Submitter: JKH USA, LLC Mailing Address: 14271 Jeffrey Rd. #246, Irvine, CA 92620 Contact Person: Dr. Bill Quanqin Dai Tel: 909-929-9896 Email: Bill(@jkhUSA.com Date of Preparation: 06/14/2020

2. Subject Device

Trade/Device Name: Massage Compression Boots Common Name: Massager, Powered Inflatable Tube Regulation Medical Specialty: Physical Medicine Review Panel: Physical Medicine Product Code: IRP Regulation Number: 21 CFR 890.5650 Device Class: II Use: Over-The-Counter (OTC)

3. Predicate device

Primary Predicate Device: 2004-OC Massage System 510(k) Number: K122112 Clearance Date: April 9, 2013 Submitter: Bio Compression Systems, Inc.

Predicate Device: Compression Therapy Device Model LGT-2200SP 510(k) Number: K191862 Clearance Date: October 29, 2019 Submitter: Guangzhou Longest Science & Technology Co., Ltd.

4. Description of Subject Device

The subject device is a portable and rechargeable device. It is intended to be an over-the-counter portable inflatable tube massage system which simulates kneading and stroking of tissue by use of an inflatable garment. It can be used to temporarily increase blood circulation and temporarily relieve minor muscle aches and pains.

The device, supplied clean and non-sterile, utilizes the pneumatically controlled chambers actuated by an electronically controlled air pump unit. All pump, battery and control components are protectively housed in a plastic case of the control unit that is permanently attached to an inflatable sleeve of multiple air chambers. An ON/OFF button, a SET button, and a display of LEDs provide for user interface. There is also a port for connecting the battery charger/AC adapter plug. The sleeve component consists of multiple air chambers/bladders encased inside a soft medical fabric or equivalent medical for increased patient comfort and biocompatibility compliance.

In operation, the user simply turns the power on via the ON/OFF button. A sleeve containing the air chambers is connected to the control unit. And the control unit then inflates the sleeve to the predetermined or adjusted pressure. The sleeve pressure is monitored by an internal pressure switch and system software. Once the sleeve pressure of the air chambers reaches the proper level, the pump is

4

turned off for a rest period, and the sleeve deflates to the ambient pressure through a valve inside the plastic case. After the rest period, the cycle of inflation repeats until the unit is turned off.

5. Indications for Use

The Massage Compression Boots are intended for the temporary relief of minor muscle aches and/or pains, and for the temporary increase in circulation to the treated areas. The device can simulate kneading and stroking of tissues by using an inflatable garment.

6. Summary of Substantial Equivalence

The following comparison Table 1 summarizes the comparison between the subject device and the predicate device, indicating the intended use and technical characteristics of the subject device are substantially equivalent to those of the predicate device.

Subject DevicePrimary Predicate DevicePredicate/Reference DeviceEquivalence
510(k) NumberN/AK122112K191862N/A
SubmitterJKH USA, LLCBio Compression Systems,
Inc.Guangzhou Longest Science
& Technology Co., Ltd.N/A
Device Name/ModelMassage Compression Boots2004-OC Massage SystemCompression Therapy
Device Model LGT-2200SPN/A
Classification NamePowered Inflatable Tube
MassagerPowered Inflatable Tube
MassagerPowered Inflatable Tube
MassagerIdentical
Regulation Class222Identical
Regulation Number21 CFR 890.565021 CFR 890.565021 CFR 890.5650Identical
Principal of OperationPneumatic compressionPneumatic compressionPneumatic compressionIdentical
Intended UseThe Massage Compression
Boots are intended for the
temporary relief of minor muscle
aches and/or pains, and for the
temporary increase in circulation
to the treated areas. The device
can simulate kneading and
stroking of tissues by using an
inflatable garment.The 2004-OC Massage
Systems are powered
inflatable tube massagers
intended to temporarily
relieve minor muscle aches
and/or pains, and to
temporarily increase
circulation to the treated areas.
The devices are intended for
home use by people who are
in good health.Compression Therapy
Device LGT-2200SP is
intended for the temporary
relief of minor muscle aches
and pains and for the
temporary increase in
circulation to the treated
areas, it can simulate
kneading and stroking of
tissues by using an inflatable
garment.Identical
Prescription or OTCOTCOTCOTCIdentical
Power Source(s)5-12V DC power supply (100-
240 VAC input) and 3.7V
rechargeable battery115 VAC, 50-60 HzAC 100-240V, 50/60Hz
Battery 11.1V, 6500mAhIdentical or similar.
The voltage
difference of power
supply used does not
change the product
performance or
parameters, which
does not raise any
new issue of the
safety or
effectiveness.
Internal rechargeable
batteriesYesNoYesIdentical to the
Predicate/Reference
Device. The battery
used or not does not
raise any new issue
of the safety or
Compliance with
Voluntary Standards?YesYesYeseffectiveness.
Electrical Safety
Mechanical Safety
Chemical Safety Thermal
Safety Radiation Safety?YesYesYesIdentical
Functions and designSimulate kneading and stroking
of tissue by use of inflatable
pressure cuffsSimulate kneading and
stroking of tissue by use of
inflatable pressure cuffsSimulate kneading and
stroking of tissue by use of
inflatable pressure cuffsIdentical
Target Population /
Intended UsersUsers who need temporary
increase of blood circulation in
the treated area and temporary
relief of minor muscular aches
and painsUsers who need temporary
increase of blood circulation
in the treated area and
temporary relief of minor
muscular aches and painsUsers who need temporary
increase of blood circulation
in the treated area and
temporary relief of minor
muscular aches and painsIdentical
Intended use EnvironmentClinics, hospital, athlete training,
and home environmentsClinics, hospital, athlete
training, and home
environmentsClinics, hospital, athlete
training, and home
environmentsIdentical
ApplicationNon-invasive / externalNon-invasive / externalNon-invasive / externalIdentical
Basis of operationUsing cyclic, intermittent,
pneumatic pressure application
(inflation followed by deflation)Using cyclic, intermittent,
pneumatic pressure
application (inflation followed
by deflation)Using cyclic, intermittent,
pneumatic pressure
application (inflation
followed by deflation)Identical
Anatomical Site /
Location of treatment
applicationLeg, arm/shoulder, and hip/waistLeg and arm/shoulderLeg, arm, waist, hip, and
thighIdentical
Software
Micro-processor
ControlMicroprocessorMicroprocessorMicroprocessorIdentical
Pressure SourceMicro pump controlled by
microprocessorMicro pump controlled by
microprocessorMicro pump controlled by
microprocessorIdentical
Pressure Range0-120 mmHg30-80 mmHg30-150 mmHgIdentical or similar.
The subject device
has the compression
pressure within the
range of the primary
predicate device,
which does not raise
any new issue of the
safety or
effectiveness.
Cycle Time60-150 seconds90 secondsN/AIdentical or similar.
The subject device
has the cycle time
cover that of the
primary predicate
device, which does
not raise any new
issue of the safety or
effectiveness.
System diagnosticsAudible and visual alarms
prompt recognition of system
faultsVisual alarms prompt
recognition of system faultsAudible and visual alarms
prompt recognition of
system faultsIdentical
Air delivery from pump to
cuff bladderVia flexible plastic tube(s)
connected directly to the air
bladderVia flexible plastic tube(s)
connected directly to the air
bladderVia flexible plastic tube(s)
connected directly to the air
bladderIdentical
SterilityClean / non-sterileClean / non-sterileClean / non-sterileIdentical
Cuff usageSingle Patient UseSingle Patient UseSingle Patient UseIdentical
Material UsedABS housing and Nylon fabric
fabric sleeveABS housing and Nylon
fabric sleeveABS housing and Nylon
fabric sleeveIdentical
BiocompatibilityBiocompatibleBiocompatibleBiocompatibleIdentical
Patient ContactNon-conductive appliancesNon-conductive appliancesNon-conductive appliancesIdentical
Dimensions165x83x55mm305x203x140mm270x148x129mmIdentical of similar.
The difference of
dimensions does not
raise any new issue
of safety or
effectiveness
Weight Approx.0.80kg3.6kg2kgIdentical or similar.
The difference of
weight does not raise
any new issue of
safety or
effectiveness

Table 1. Comparison between the subject device and the predicate device

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7. Substantial Equivalence

As shown in the above table of comparison, the subject device in this submission has the identical performance and parameter to the predicate device. And the differences discussed between the subject device and the predicate device do not raise any new issues of safety or effectiveness.

The subject device is substantially equivalent to the predicate devices listed in function and operating principals to achieve identical results. The predicate device utilizes microprocessor controlled pumps to deliver pressurized air to chambers that are attached to the user's body area. Each cycle consists of air inflation of chambers, followed by a rest period during which the chambers deflate and the relax without any compression.

Identical to the predicate device the subject device has multiple and visual safety alarms built into the system. including the low pressure alarm and low battery alarm. In addition, the sleeve is comprised of multiple bladder PVC chambers encased in a covering of soft and non-latex medical fabric or equivalent medical material for increased patient comfort and biocompatibility compliance. The microprocessor and pump units are powered by internal rechargeable batteries, and can be connected to the main AC power line (through the battery charger / AC adaptor) while in use, allowing uninterrupted prolonged service.

The skin contact components and materials of the subject device are identical to those of the predicate device in formulation, suppliers, processing, and geometry and no other chemicals have been added (e.g., plasticizers, fillers, color additives, cleaning agents, mold release agents, etc.). Therefore, there is no issue or concern of biocompatibility.

As demonstrated, the differences between the subject and predicate devices do not affect the intended use or alter the fundamental technology of the device. There are no new safety or effectiveness issues concerning the subject device, which offers substantially equivalent technical specifications, features, intended use, safety, and effectiveness to the predicate device.

8. Non-Clinical Tests Performed

Non-clinical tests were performed on the subject device in order to validate the design and to assure conformance with the following voluntary design standards in connection with medical device electrical safety, and electromagnetic compatibility.

  • (a) ANSI AAMI ES60601-1 "Medical Electrical Equipment Part 1: General requirements for basic safety and essential performance (IEC 60601-1)".

7

  • (b) IEC 60601-1-2 "Medical Electrical Equipment Part 1-2: General Requirements for Basic Safety and Essential Performance - Collateral standard: Electromagnetic Compatibility - Requirements and Tests".
    In addition to the compliance of voluntary standards, bench tests have been performed on the physical requirements, electrical requirement, and performance requirement; the verification of software used in the subject device has been carried out according to the FDA Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices.

9. Conclusion

The tests and comparison performed demonstrate the subject device is substantially equivalent to the predicate device. Therefore, the subject device is as safe and effective as the predicate device that has been legally marketed in the United States.