K Number
K203353
Device Name
DVT-PRO
Date Cleared
2021-04-22

(160 days)

Product Code
Regulation Number
870.5800
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
DVT-PRO is a system to prevent DVT (Deep Vein Thrombosis) by improving the blood velocity of patients. DVT-PRO is Circulation Enhancement, Deep Vein Thrombosis Prophylaxis Edema - Acute, Edema - Chronic, Extremity Pain Incident to Trauma or Surgery Leg Ulcers, Venous Stasis / Venous Insufficiency.
Device Description
In this device, sleeves continuously inflated/deflated by the air pressure generated by the pump. This pressurization increases blood flow and prevent DVT/PE. Operating principal of this device is that the air output from the air motor is delivered to a sleeve composed of four air chambers are sequentially inflated from the first air chamber to the third chamber through solenoid valve.
More Information

Not Found

No
The device description focuses on mechanical inflation/deflation and air pressure, with no mention of AI or ML algorithms for control, analysis, or prediction. The performance studies are based on non-clinical product performance tests comparing to a predicate device, not on the performance of an AI/ML model.

Yes
The device is described as a system to prevent DVT (Deep Vein Thrombosis) and improve blood velocity, which are therapeutic actions. It also lists indications such as Edema and Leg Ulcers, further supporting its therapeutic nature.

No

This device is designed to prevent DVT by improving blood velocity through continuous inflation/deflation of sleeves, which is a prophylactic and therapeutic action, not a diagnostic one. It does not identify or confirm the presence of a disease.

No

The device description explicitly mentions hardware components like "sleeves," "pump," "air pressure," "air motor," and "solenoid valve," indicating it is a hardware-based device with software control, not a software-only medical device.

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

Here's why:

  • Intended Use: The intended use is to prevent DVT and treat various circulatory issues by physically manipulating blood flow through external compression. This is a therapeutic and prophylactic function, not a diagnostic one.
  • Device Description: The device works by applying external pressure to the limbs using air-filled sleeves. This is a mechanical action, not a process that analyzes biological samples (like blood, urine, or tissue) to diagnose a condition.
  • Lack of IVD Characteristics: There is no mention of analyzing samples, using reagents, or providing diagnostic information based on biological markers.

IVD devices are specifically designed to examine specimens derived from the human body to provide information for the diagnosis, prevention, monitoring, treatment, or alleviation of disease. This device does not fit that description.

N/A

Intended Use / Indications for Use

DVT-PRO is a system to prevent DVT (Deep Vein Thrombosis) by improving the blood velocity of patients. DVT-PRO is Circulation Enhancement, Deep Vein Thrombosis Prophylaxis Edema – Acute, Edema – Chronic, Extremity Pain Incident to Trauma or Surgery Leg Ulcers, Venous Stasis / Venous Insufficiency.

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

JOW

Device Description

In this device, sleeves continuously inflated/deflated by the air pressure generated by the pump. This pressurization increases blood flow and prevent DVT/PE.

Operating principal of this device is that the air output from the air motor is delivered to a sleeve composed of four air chambers are sequentially inflated from the first air chamber to the third chamber through solenoid valve.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Professional healthcare environment

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 Test Summary: The DVT-PRO complies with voluntary standards for electromagnetic compatibility. And a biocompatibility test was conducted for the sleeves, not for device, an accessory used with DVT-PRO. In addition, it was confirmed that the performance of the product was satisfactory by conducting a performance test to prove that it is substantially equivalent to the equivalent device.

  1. Electrical Safety, Electromagnetic Compatibility and Performance: The DVT-PRO complies with the electrical safety and electromagnetic compatibility requirements established by the standards.
  2. Non-clinical test (Product performance test): A test was conducted that reflected the difference from the equivalent device, and after the change, it was confirmed that the product satisfies the existing performance. Therefore, it can be confirmed that the existing predicate device(K150980) and the proposed device(K203353) are substantially equivalent.

Clinical Test Summary: Clinical testing was not required to demonstrate the substantial equivalence of the DVT-PRO to its predicate device.

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.

K150980

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).

0

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April 22, 2021

Daesung Maref Co., LTD Su Hyeon So Assistant Researcher 298-24. Gongdan-Ro Gunpo-Si, Gyeonggido 15809 Korea, South

Re: K203353

Trade/Device Name: DVT-PRO Regulation Number: 21 CFR 870.5800 Regulation Name: Compressible Limb Sleeve Regulatory Class: Class II Product Code: JOW Dated: February 22, 2021 Received: March 23, 2021

Dear Su Hyeon So:

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 requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part

1

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 (QS) 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 medical devices and radiation-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,

Nicole Gillette Assistant Director (Acting) DHT2B: Division of Circulatory Support, Structural and Vascular Devices OHT2: Office of Cardiovascular Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K203353

Device Name DVT-PRO

Indications for Use (Describe)

DVT-PRO is a system to prevent DVT (Deep Vein Thrombosis) by improving the blood velocity of patients. DVT-PRO is Circulation Enhancement, Deep Vein Thrombosis Prophylaxis Edema - Chronic, Extremity Pain Incident to Trauma or Surgery Leg Ulcers, Venous Stasis / Venous Insufficiency

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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1. Data Prepared [21 CFR 807.92(a)(a)]

February 22, 2021

2. Submitter's Information [21 CFR 807.92(a)(1)]

  • Name of Manufacturer : DAESUNG MAREF CO., LTD.
  • Address :

298-24, Gongdan-ro Gunpo-si, Gyeonggido Republic of Korea

  • Contact Name :
    • Su Hyeon, So
  • Telephone No. : 82-31-459-7211
  • Fax No. :
    • 82-31-459-7215
  • Email Adress : rndra@dsmaref.com
  • Registration No. : 3004116008

3. Trade Name, Regulation Name, Classification [21 CFR 807.92(a)(2)]

Trade / Device NameDVT-PRO
Classification NameCompressible Limb Sleeve
Regulation Number21 CFR 870.5800
Regulation ClassII
Product CodeJOW

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4. Identification of Predicate Device(s) [21 CFR 807.92(a)(3)[

Predicate Device

  • 510(k) Number :
  • K150980
  • Applicant : DAESUNG MAREF CO., LTD.
  • Trade / Device Name :

DVT-Pro

  • · Regulation Number : 21 CFR 870.5800
  • · Regulation Name :
    • Compressible Limb Sleeve
  • Regulation Class:

II

  • Product Code:
    • JOW

Predicate device has not been subject to a design-related recall.

5. Description of the Device [21 CFR 807.92(a)(4)]

In this device, sleeves continuously inflated/deflated by the air pressure generated by the pump. This pressurization increases blood flow and prevent DVT/PE.

Operating principal of this device is that the air output from the air motor is delivered to a sleeve composed of four air chambers are sequentially inflated from the first air chamber to the third chamber through solenoid valve.

6. Indications For Use [21 CFR 807(a)(5)]

DVT-PRO is a system to prevent DVT (Deep Vein Thrombosis) by improving the blood velocity of patients. DVT-PRO is Circulation Enhancement, Deep Vein Thrombosis Prophylaxis Edema – Acute, Edema – Chronic, Extremity Pain Incident to Trauma or Surgery Leg Ulcers, Venous Stasis / Venous Insufficiency.

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7. Determination of Substantial Equivalence

Summary of technological characteristics of the device compared to the predicate device. [21CFR 807.92(a)(6)]

The DVT-PRO(Proposed device) is substantially equivalent to legally marketed predicate device (DVT-PRO,K150980) with respect to indications for use and technology characteristics. The table below presents comparisons for device :

Proposed DevicePredicate Device
Model NameDVT-PRODVT-PRO
510(k) NumberK203353K150980
ManufacturerDAESUNG MAREF CO., LTD.DAESUNG MAREF CO., LTD.
Product CodeJOWJOW
Device ClassIIII
Regulation
Number21 CFR 870.580021 CFR 870.5800
Regulation
NameCompressible Limb SleeveCompressible Limb Sleeve
Indications For UseDVT-PRO is a system to prevent
DVT (Deep Vein Thrombosis) by
improving the blood velocity of
patients. DVT-PRO is Circulation
Enhancement, Deep Vein
Thrombosis Prophylaxis Edema -
Acute, Edema - Chronic, Extremity
Pain Incident to Trauma or Surgery
Leg Ulcers, Venous Stasis / Venous
InsufficiencyDVT-PRO is a system to prevent
DVT (Deep Vein Thrombosis) by
improving the blood velocity of
patients. DVT-PRO is Circulation
Enhancement, Deep Vein
Thrombosis Prophylaxis Edema -
Acute, Edema - Chronic, Extremity
Pain Incident to Trauma or Surgery
Leg Ulcers, Venous Stasis / Venous
Insufficiency
Intended Use
environmentProfessional healthcare environmentProfessional healthcare environment

[Table 1. Comparison of Proposed Device to Predicate Device]

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| Accessories | Calf sleeve
Foot sleeve | Calf sleeve
Foot sleeve | | |
|-----------------------|-----------------------------------------------------------|-----------------------------------------------------------|--|--|
| Specifications | | | | |
| Adaptor specification | 9Vdc / 2A, 18W | 9Vdc / 2A, 15W | | |
| Power Source | 100-240VAC, 50/60Hz | 100-240VAC, 50/60Hz | | |
| Pressure | LEG : 20-65mmHg (±15mmHg)
FOOT : 120-140mmHg (±15mmHg) | LEG : 20-65mmHg (±20mmHg)
FOOT : 120-140mmHg (±20mmHg) | | |
| Number of chamber | 3 | 3 | | |
| Battery | 5200mAh | 5200mAh | | |

The table also provides rationale for a little difference in support of substantial equivalence to the Predicate devices.

[Table 2. Little differnence with Predicate Device]

Justification to Support Substantial Equivalence

The DVT-PRO(Proposed device) is hardly different from the DVT-PRO(Predicate device) except pressure error range, Adaptor power consumption etc.,.

For the power consumption of the adapter,

In the traditional 510(k) of K150980, it was confirmed that it was mislabeled as a typo, So, we want to correct it to the correct numerical value by changing it to 18W.

In the case of the pressure error range, there is no additional risk since it is changed to a tighter condition.

Therefore, differences in technical characteristics do not affect safety and effectiveness.

Non-Clinical Test Summary

The DVT-PRO complies with voluntary standards for electromagnetic compatibility. And a biocompatibility test was conducted for the sleeves, not for device, an accessory used with DVT-PRO. In addition, it was confirmed that the performance of the product was satisfactory by conducting a performance test to prove that it is substantially equivalent to the equivalent device.

The following data were provided in support of the substantial equivalence determination :

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  1. Electrical Safety, Electromagnetic Compatibility and Performance

The DVT-PRO complies with the electrical safety and electromagnetic compatibility requirements established by the standards.

· IEC 60601 : 2005/A1:2012, Medical Electrical Equipment:Part 1: General Requirements for Basic Safety and Essential Performance

  • · IEC 60601-1-2:2014, Medical Electrical Equipment Part 1 1-2: General Requirements for Basic Safety and Essential Performance - Collateral Standard: Electromagnetic Disturbances -Requirements and Tests
    · ISO 10993-5:2009 Third edition 2009-12-15, Biological evaluation of medical devices - Part 5: Tests for in vitro cytotoxicity

· ISO 10993-10 Thrid Edition 2010-08-01, Biological evaluation of medical devices - Part 10: Tests for irritation and skin sensitization

  1. Non-clinical test (Product performance test)

· A test was conducted that reflected the difference from the equivalent device, and after the change, it was confirmed that the product satisfies the existing performance. Therefore, it can be confirmed that the existing predicate device(K150980) and the proposed device(K203353) are substantially equivalent.

Clinical Test Summary

Clinical testing was not required to demonstrate the substantial equivalence of the DVT-PRO to its predicate device.

8. Conclusion [21 CFR 807.92(b)(3)]

The DVT-PRO has same indication for use and technical characteristics to the predicate device except some item. Based on that information, we conclude that the differences between the proposed device and predicate device do not introduce a new intended use and do not raise new issues of safety and effectiveness.

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