(36 days)
No
The document explicitly states "Mentions AI, DNN, or ML: Not Found" and the device description focuses on basic controls and Bluetooth connectivity for app control, not intelligent algorithms.
Yes
The stated intended use of the device is to "temporarily relieve minor muscle aches and to temporarily increase circulation to the treated areas," which aligns with the definition of a therapeutic device.
No
The device description clearly states its purpose is to "temporarily relieve minor muscle aches" and "temporarily increase circulation," which are therapeutic functions, not diagnostic ones. There is no mention of the device identifying or detecting any medical condition.
No
The device description clearly states it is a "powered, inflatable tube, calf massager" and details hardware components like a battery, control unit, buttons, and a display screen. While it has a companion app, the core medical device is a physical hardware product.
Based on the provided information, the Normatec Go is not an IVD (In Vitro Diagnostic) device.
Here's why:
- Intended Use: The intended use is to temporarily relieve minor muscle aches and increase circulation. This is a physical therapy/massage function, not a diagnostic test performed on samples from the human body.
- Device Description: The device is an air pressure massager that applies external pressure to the calf. It does not interact with biological samples (blood, urine, tissue, etc.) for diagnostic purposes.
- Lack of IVD Characteristics: The description does not mention any components or functions related to analyzing biological samples, detecting biomarkers, or providing diagnostic information about a disease or condition.
- Product Code: The product code "IRP" is typically associated with physical medicine devices, not IVD devices.
- Performance Studies: The performance studies focus on the device's physical and functional characteristics (air pressure, battery, software, etc.), not on the accuracy or reliability of diagnostic results.
In summary, the Normatec Go is a therapeutic device that applies external physical pressure, not a device used to diagnose conditions by analyzing samples from the body.
N/A
Intended Use / Indications for Use
The Normatec Go is an air pressure massager intended to temporarily relieve minor muscle aches and to temporarily increase circulation to the treated areas.
Product codes
IRP
Device Description
The Normatec Go is a powered, inflatable tube, calf massager (Product Code "IRP"). It is intended to temporarily relieve minor muscle aches and/or pains, and to temporarily increase circulation to the treated areas. The device is to be used by people who are in good health. The device is charged from an external compliant power supply and powered by an internal IEC 62133-2 compliant lithium-ion battery. The user interface on the Normatec Go is a series of buttons with one small display screen, to display the treatment time. located on the control unit mounted on the calf wrap. The user interface provides for:
- Starting and stopping the massage treatment;
- Adjusting time and intensity (pressure) of the treatment;
In addition to the user interface on the proposed device, the device also has Bluetooth capability that allows the use of the NormaTec app to control the device. The Normatec app allows the user to use a compatible Android or iOS phone to select and set device parameters listed above for convenience
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Not Found
Anatomical Site
Calf
Indicated Patient Age Range
Adults
Intended User / Care Setting
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)
The Normatec Go underwent identical performance testing to the predicate Normatec 3 (K220217) with the inclusion of RF pairing testing. The testing included Software V&V, Functional Verification Physical Features Verification, Battery Drain, Battery Charge, System Air Release, Battery Function Verification and RF Pairing Verification. The subject device met all acceptance criteria.
Verification and Validation activities that established the performance, functionality, and reliability characteristics of the Normatec 3 with respect to the predicate were performed. Testing performed demonstrated that the proposed device meets defined requirements and performance claims.
Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)
Not Found
Predicate Device(s)
Reference Device(s)
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).
0
Image /page/0/Picture/0 description: The image shows 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 square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
July 14, 2022
NormaTec Industries, LP % Prithul Bom Most Responsible Person Regulatory Technology Services, LLC 1000 Westgate Drive, Suite 510k Saint Paul, Minnesota 55114
Re: K221666
Trade/Device Name: Normatec Go Regulation Number: 21 CFR 890.5650 Regulation Name: Powered inflatable tube massager Regulatory Class: Class II Product Code: IRP Dated: June 6, 2022 Received: June 8, 2022
Dear Prithul Bom:
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.
1
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 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 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.
for Heather Dean, PhD Assistant Director, Acute Injury Devices Team 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
Enclosure
2
Indications for Use
510(k) Number (if known) K221666
Device Name Normatec Go
Indications for Use (Describe)
The Normatec Go is an air pressure massager intended to temporarily relieve minor muscle aches and to temporarily increase circulation to the treated areas.
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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3
510(k) Summary
Page 1 of 9
NormaTec Industries, LP | Page 1 of 9 | |
---|---|---|
Date of Preparation: | 14-Jul-22 | |
480 Pleasant Street | ||
Suite A200 | ||
Watertown MA 02472 | Tel - 800.355.0960 | |
Fax - 866.279.2579 | ||
Official Contact: | Steve Henderson, Director of Quality & Regulatory Systems | |
Proprietary or Trade | ||
Name: | Normatec Go | |
Proposed Device: | Normatec Go | |
Common/Usual Name: | Massager, Powered Inflatable Tube | |
Classification Name | Powered inflatable tube massager | |
Regulation Number: | 21 CFR 890.5650 | |
Product Code: | IRP | |
Regulation Medical | ||
Specialty: | Physical Medicine | |
Predicate Device: | K220217 – Normatec 3 | |
Secondary | ||
Predicate Device: | K213745 - Air Compression Therapy Device, model: | |
ST-502, Shenzhen Future Electronic Co., Ltd | ||
Classification Name | ||
Common/Usual | Powered inflatable tube massager | |
Regulation Number: | Name Massager, Powered Inflatable Tube | |
Product Code | 21 CFR 890.5650 | |
IRP | ||
Regulation Medical | ||
Specialty: | Physical Medicine |
4
510(k) Summary Page 2 of 9
Device Description
The Normatec Go is a powered, inflatable tube, calf massager (Product Code "IRP"). It is intended to temporarily relieve minor muscle aches and/or pains, and to temporarily increase circulation to the treated areas. The device is to be used by people who are in good health. The device is charged from an external compliant power supply and powered by an internal IEC 62133-2 compliant lithium-ion battery. The user interface on the Normatec Go is a series of buttons with one small display screen, to display the treatment time. located on the control unit mounted on the calf wrap. The user interface provides for:
- . Starting and stopping the massage treatment;
- . Adjusting time and intensity (pressure) of the treatment;
In addition to the user interface on the proposed device, the device also has Bluetooth capability that allows the use of the NormaTec app to control the device. The Normatec app allows the user to use a compatible Android or iOS phone to select and set device parameters listed above for convenience
Intended User ОТС
Patient Population Adults
Indications for Use
The Normatec Go is an air pressure massager intended to temporarily relieve minor muscle aches and/or pains, and to temporarily increase circulation to the treated areas.
Intended Use Environment:
Clinics, hospital, athlete training, and home environments.
5
510(k) Summary Page 3 of 9
Table 1 – Table of Device Comparisons and Differences
Proposed New Device | Predicate Device | Secondary Predicate Device | Comment | |
---|---|---|---|---|
Model Name | ||||
510(k) Number | Normatec Go | |||
510(k) K221666 | Normatec 3 | |||
510(k) K220217 | Air Compression | |||
Therapy Device, | ||||
model: ST-502 | ||||
510(k) K213745 | N/A | |||
Manufacturer | NormaTec Industries, LP | NormaTec Industries, LP | Shenzhen Future Electronic Co., | |
Ltd. | N/A | |||
Prescriptive | ОТС | ОТС | ОТС | Identical |
Indications for use | The Normatec Go is an air | |||
pressure massager intended to | ||||
temporarily relieve minor muscle | ||||
aches and/or pains, and to | ||||
temporarily increase circulation to | ||||
the treated areas. | The Normatec 3 is an air | |||
pressure massager intended to | ||||
temporarily relieve minor | ||||
muscle aches and/or pains, and | ||||
to temporarily increase | ||||
circulation to the treated areas. | The Air Compression Therapy | |||
Device (model: ST-502) is | ||||
indicated for the temporary relief of | ||||
minor muscle aches and pains and | ||||
for temporary increase in | ||||
circulation to the treated areas in | ||||
people who are in good health. | ||||
The Air Compression Therapy | ||||
Device (model: ST-502) simulates | ||||
kneading and stroking of tissues | ||||
by using an inflatable garment. | The proposed and predicate | |||
device have identical | ||||
Indications for Use. The | ||||
secondary predicate device is | ||||
included because the | ||||
maximum pressure is similar | ||||
to the proposed device. | ||||
The difference between the | ||||
proposed and secondary | ||||
predicate device is the | ||||
removal of "simulates | ||||
kneading and | ||||
stroking of tissues by using an | ||||
inflatable garment." | ||||
Anatomical Coverage | Control unit mounted to inflatable | |||
segment with integral hoses. | Not publicly available | Control unit connected to | ||
inflatable segments via a | ||||
hose. | Proposed device is only for | |||
the leg | ||||
Method to secure the | ||||
device to the extremity | The device is laid open and flat. | |||
Place device around calf, then | ||||
secure by pulling tight until Velcro | ||||
provides a snug fit against the calf. | Not publicly available | Place device around calf, | ||
then secure by pulling | ||||
tight until Velcro holds. | The difference in method to | |||
secure the device in place | ||||
does not raise any concerns | ||||
or safety or effectives. Neither | ||||
does it raise any new | ||||
technological characteristics. | ||||
Page 4 of 9 | ||||
Proposed New Device | Predicate Device | Secondary Predicate Device | Comment | |
Intended Use | ||||
Environment | Clinics, hospital, athlete | |||
training, and home | ||||
environments | Clinics, hospital, athlete | |||
training, and home | ||||
environments | Clinics, hospital, athlete training, | |||
and home environments | Similar | |||
Power Source(s) | Charging via 5 VDC compliant | |||
power supply (100-240 VAC input) | ||||
Powered by Integrated | ||||
rechargeable battery | 15 VDC via an IEC 60601-1 | |||
compliant power | ||||
supply (100-240 VAC | ||||
input) | ||||
Integrated rechargeable | ||||
battery | 100-240V, 50-60Hz | Proposed device is not | ||
operational when plugged | ||||
into the power supply. | ||||
Battery | Internal battery | |||
3.6V, 2550mAh | ||||
Internal battery (D610-1-d1-1S1P) | ||||
3.65V, 2600mAh | Internal battery | |||
7.2V, 3200mAh | Battery | Similar, but a smaller | ||
battery. | ||||
Software / Firmware | Microprocessor | Microprocessor | Microprocessor | Similar |
Technology | Compressor and valve system | |||
that sequentially inflates cells. | ||||
Bluetooth communication | ||||
ability. | Compressor and valve system | |||
that sequentially inflates cells. | ||||
Bluetooth communication | ||||
ability. | Consists of an air pump, air | |||
pressure sensor, leg sleeves | ||||
and adapter. | Similar | |||
Compliance with Voluntary | ||||
standards | AAMI ANSI ES60601-1, IEC | |||
60601-1-2, IEC 60601-1-6, | ||||
IEC 60601-1-11 | ||||
ANSI C63.27-2017 | AAMI ANSI ES60601-1, | |||
IEC 60601-1-2, IEC | ||||
60601-1-6, | ||||
IEC 60601-1-11 | ||||
ANSI C63.27-2017 | ANSI AAMI ES606011 | |||
:2005/(R)2012 and A1:2012, IEC | ||||
6060112 Edition 4.0 2014, ANSI | ||||
AAMI HA 60601111:2015 | Similar | |||
Proposed New Device | Predicate Device | Secondary Predicate Device | Comment | |
Performance Testing | V&V Summary | |||
Functional Verification | ||||
Physical Features Verification | ||||
Battery Drain | ||||
Battery Charge | ||||
System Air Release | ||||
Battery Function Verification | ||||
RF Pairing Verification | V&V Summary | |||
Functional Verification | ||||
Physical Features | ||||
Verification Battery | ||||
Drain | ||||
Battery Charge System | ||||
Air Release | ||||
Battery Function Verification | Not available | Performance Testing is | ||
identical, though the | ||||
proposed device includes | ||||
RF pairing testing. | ||||
Clinical Testing | None | None | None | Similar |
Device Pressure Range | 0 – 220 mm Hg | 0 - 110 mm Hg | Up to 240 mm Hg | Increased pressure is |
within range of cleared | ||||
secondary predicate | ||||
device. | ||||
Pressure Levels | Level 1: 40 - 70 mm Hg max | |||
Level 2: 60 - 90 mm Hg max | ||||
Level 3: 80 - 110 mm Hg max | ||||
Level 4: 100 - 140 mm Hg max | ||||
Level 5: 130 - 170 mm Hg max | ||||
Level 6: 150 - 200 mm Hg max | ||||
Level 7: 180 - 220 mm Hg max | Level 1: 40 mm Hg max | |||
Level 2: 50 - 60 mm Hg max | ||||
Level 3: 60 - 70 mm Hg max | ||||
Level 4: 70 - 80 mm Hg max | ||||
Level 5: 80 mm Hg max | ||||
Level 6: 80 - 90 mm Hg max | ||||
Level 7: 100 mm Hg max | Up to 240 mm Hg | Subject device has | ||
higher max pressure | ||||
than the predicate, but | ||||
the Secondary Predicate | ||||
K213745 is up to 240 | ||||
mmHg. | ||||
Treatment Time | Stays on until the user turns it off | |||
or can be set up to turn off in a | ||||
range of 15 minutes to 60 minutes | Stays on until the user turns it off | |||
or can be set up to turn off in a | ||||
range of 15 minutes to 60 minutes | 20 minutes | Similar | ||
Page 6 of 9 | ||||
Proposed New Device | Predicate Device | Secondary Predicate Device | Comment | |
Treatment Area | Calf | Leg, Arm, and Hip | Low limbs (Foot, calf, and | |
upper leg) | The proposed device is | |||
intended for use only on the | ||||
calf. | ||||
The secondary predicate | ||||
device has three (3) | ||||
segments that can | ||||
operate with all (foot, | ||||
calf, and upper leg) or the | ||||
user can activate only one | ||||
segment (e.g., the calf) | ||||
Inflation/Deflation Cycle | ||||
Type | Sequential Gradient, | |||
Peristaltic and Pulsing | Sequential Gradient, | |||
Peristaltic and Pulsing | Sequential/Peristaltic | Similar | ||
Contact Surface | ||||
Material | 200 denier nylon with a | |||
polyurethane | ||||
aminate/extrusion | 200 denier nylon with a | |||
polyurethane | ||||
laminate/extrusion | Polyester | Similar | ||
Number of Inflatable | ||||
segments | 3 | 5 or less | 3 | The proposed device is |
physically smaller and does | ||||
not require more than 3 | ||||
segments. | ||||
Weight | 1.2 lbs | 3.6 lbs | 3.08 and 3.52 pounds | Similar |
Dimensions (W x | ||||
H x D) | 4.94" x 1.27" x 2.76" | 4.17" x 3.66" x 8.25" | L215mm x W65mm x H51mm | Similar |
Materials | Wrap- nylon / polyester Velcro | |||
Controller housing | ||||
Molded ABS enclosure (94V0) | Not publicly available | Sleeve - nylon / polyester | ||
Velcro | ||||
Controller housing | ||||
Molded ABS enclosure (94V0) | Similar | |||
Patient contact | Non-conductive nylon containing | |||
air bladders that when secured | ||||
around the calf by Velcro, form | ||||
zones of air tubes for compression. | Non-conductive appliances | Non-conductive attachments | Similar |
6
510(k) Summary
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510(k) Summary
Page 5 of 9
8
C
510(k) Summary
9
510(k) Summary Page 7 of 9
Determination of Substantial Equivalence
The Normatec Go is substantially equivalent to currently marketed and cleared devices (K220217) because:
Indications for Use
The Normatec Go indications for use are identical to the predicate, Normatec 3, 510(k) K220217.
Prescriptive
The Normatec Go and the predicate Normatec 3 (K220217) and secondary predicate device (K213745) are OTC devices.
Design, Technology, and Principle of Operation
The Normatec Go has equivalent design and features, and similar technology to the predicate, Normatec 3, 510(k) K220217.
Design and Technology
The proposed device Normatec Go differs in design from the predicate Normatec 3 (K220217) in the following ways:
- . Normatec Go has a rechargeable battery that allows the user to operate the device without requiring the device to be connected to power like the predicate Normatec 3 (K220217). Normatec Go will not operate while the device is connected to power and charging the battery.
- The control unit or Display Screen which includes the Start/Stop button. Time Adiustment button. ● and Pressure Adjustment button - is attached directly to Normatec Go.
- The air hoses for the proposed device Normatec Go are contained within the device. The air tubes ● have been relocated in a service pouch to improve the aesthetic look of the device, though they are still directly connected to the control unit. For the predicate device Normatec 3 (K220217), one air hose protruded from the leg, arm, or hip appliance to connect directly to the control unit.
Method to Secure the Device
The proposed device is unfolded, then wrapped around the calf until snug. The proposed device has Velcro to ensure the device is secure and snug prior to starting treatment.
Principle of Operation
The Principle of Operation for the proposed device Normatec Go, predicate device Normatec 3 (K220217), and secondary predicate device – Air Compression Therapy Device (K213745) is identical.
Maximum Pressure
The subject device is capable of reaching up to 220 mm Hg.
The predicate device is capable of reaching up to 110 mmHg. The secondary predicate device is capable of reaching up to 240 mm Hg.
Though the maximum pressure for the proposed device Normatec Go exceeds the maximum pressure for
10
510(k) Summary Page 8 of 9
the predicate device Normatec 3 (K220217), we have included a secondary predicate device with similar technology, principle of operation, and indications for use that has a maximum pressure of 20 mm Hg higher than the Normatec Go. While this pressure is higher than the predicate device Normatec 3 (K220217). this higher pressure does not raise any different safety or effectiveness concerns for the subject device Normatec Go.
Treatment Area
The proposed device Normatec Go is offered as a calf only device.
The predicate device Normatec 3 (K220217) had three models: leg, arm, and hip. While the treatment areas of the body may differ, the fundamental technology and method of treatment is identical.
The secondary predicate device Air Compression Therapy Device (K213745) can treat the foot, calf, and upper leg simultaneously or each zone independently. When operated to one specific area (i.e., calf), this is similar to the proposed device Normatec Go, which is limited to the calf only. We do not believe that treatment of only the calf muscle raises any new safety or effectiveness concerns for the proposed device Normatec Go.
Bluetooth and Smartphone Application
Both the proposed device Normatec Go and the predicate Normatec 3 have identical Bluetooth capability that allow both devices to connect to the NormaTec app. Our app is compatible with both iOS and Android platforms. The app is the identical for both the predicate Normatec 3 and the proposed Normatec Go. The user can adjust the pressure level, time and the starting and stopping of the session. The app has the same functionality as the device. The app acts like a remote control for users who do not want to use the controls located on the device.
Battery
Normatec Go passed testing with a different, smaller battery due to the size of the control unit - the size of the control unit Normatec Go is smaller than the predicate device Normatec 3 (K220217).
Performance and Specifications
The Normatec Go has equivalent specifications of performance when compared to the predicate. Normatec 3, 510(k) K220217 except for the maximum pressure. We have compared to the secondary predicate device K213745 which has similar maximum pressure limits.
Compliance with Standards
Both devices have been tested with AAMI ANSI ES60601-1, IEC 60601-1-2, IEC 60601-1-11 and ANSI C63.27-2017 and passed the acceptance criteria.
Patient Contacting Materials
The patient-contacting materials of the Normatec Go are identical to the predicate Normatec 3 (K220217).
Intended Use Environment
Clinics, hospital, athlete training, and home environments, which are identical to the predicate.
Features
The Normatec Go has equivalent features when compared to the predicate Normatec 3 (K220217).
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510(k) Summary Page 9 of 9
Performance Testing
The Normatec Go underwent identical performance testing to the predicate Normatec 3 (K220217) with the inclusion of RF pairing testing. The testing included Software V&V, Functional Verification Physical Features Verification, Battery Drain, Battery Charge, System Air Release, Battery Function Verification and RF Pairing Verification. The subject device met all acceptance criteria.
Verification and Validation activities that established the performance, functionality, and reliability characteristics of the Normatec 3 with respect to the predicate were performed. Testing performed demonstrated that the proposed device meets defined requirements and performance claims.
Animal testing There was no animal testing.
Clinical Testing There was no clinical testing.
Conclusion
The Normatec Go is substantially equivalent to the predicate Normatec 3 (K220217) in:
- Patient population .
- Environment of use •
- Technology characteristics •
- Patient Contacting Materials •
- Specifications / performance, and
- Compliance with international standards •
The 510(k) summary includes the conclusions drawn from the nonclinical tests (discussed above) that demonstrate that the device is substantially equivalent as compared to the predicate device according to 807.92(b)(3).