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510(k) Data Aggregation
(217 days)
A device intended to temporarily relieve minor muscle aches and for temporary increase in circulation to the treated areas in people who are in good health.
This product is an Intermittent Pneumatic Compression system to temporarily relieve minor muscle aches and pains and for temporary increase in circulation to the treated areas in people who are in good health. The operating principle is that the air from the device will be delivered to the sleeve with 4 air chambers and the air pressurizes sequentially the chambers from 1st to 4th.
The provided document is a 510(k) summary for the LX9max device, which is a powered inflatable tube massager. The document aims to demonstrate that the LX9max is substantially equivalent to a legally marketed predicate device (Rapid Reboot Compression Therapy System) and a reference device (Rapid Reboot REGEN+).
Here's an analysis of the acceptance criteria and the study as requested:
1. Table of acceptance criteria and the reported device performance
The document does not explicitly present a table of "acceptance criteria" in the sense of performance metrics or thresholds for clinical efficacy. Instead, it focuses on demonstrating substantial equivalence to predicate devices. This typically involves showing that the new device has similar indications for use, technological characteristics, and safety and effectiveness profiles as the cleared predicate.
The table provided (Table 1: Comparison of Proposed Device to Predicate / Reference Devices) compares various characteristics:
| Characteristic | Proposed Device (LX9max) | Predicate Device (Rapid Reboot Compression Therapy System) | Reference Device (Rapid Reboot REGEN+) |
|---|---|---|---|
| Indications For Use | A device intended to temporarily relieve minor muscle aches and pains and for temporary increase in circulation to the treated areas in people who are in good health. | Same as proposed device, with added "simulates kneading and stroking of tissues by using an inflatable garment." | Same as predicate device. |
| Intended Use environment | Home environments (Indoor environments) | Clinics, hospital, athlete training, and home environments. | Clinics, hospital, athlete training, and home environments. |
| OTC or Rx only | OTC | OTC | OTC |
| Accessories | Leg sleeves, Arm sleeve, Center body sleeve | Leg sleeve, Arm sleeve, Hip sleeve | Leg sleeve, Arm sleeve, Hip sleeve |
| Power Source | 100-127V~, 50/60Hz | 110 V, 60Hz | 110 V, 60Hz |
| Time | 5-90 min | 10,20,30 min | 1-179 minutes |
| Pressure | 10-180mmHg ± 20 mmHg | 0-200 mmHg | 0-200 mmHg |
| Number of chamber | 4 | 4 | 4 |
The "reported device performance" for the LX9max is implicitly that it meets the safety and effectiveness standards of the predicate devices because its technological characteristics are similar, and any differences (pressure range, time range, sleeve type) do not raise new questions of safety or effectiveness. The justification for these minor differences is presented on page 7.
The document also states that the LX9max complies with several voluntary standards for electrical safety, electromagnetic compatibility, and use in the home healthcare environment (listed on page 8). These standards serve as technical acceptance criteria for safety.
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
The document explicitly states: "Clinical Testing was not required to demonstrate the substantial equivalence of the LX9max to its predicate / reference device." (page 8).
Therefore, there
- was no clinical test set used for this submission to prove substantial equivalence.
- no observational data provenance (country, retrospective/prospective) is applicable.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable, as no clinical testing was performed for substantial equivalence.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable, as no clinical testing was performed for substantial equivalence.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
Not applicable. This device is a physical therapy device (massager), not an AI-assisted diagnostic or therapeutic tool. No MRMC study was conducted.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
Not applicable. This is not an algorithm-based device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
Not applicable. No clinical ground truth was established as no clinical testing was performed. The basis for substantial equivalence relies on comparison of technical characteristics and compliance with safety standards.
8. The sample size for the training set
Not applicable. This is not a machine learning/AI device, so there is no "training set."
9. How the ground truth for the training set was established
Not applicable, as there is no training set for this type of device.
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(129 days)
A device intended to prevent Deep Vein Thrombosis/Pulmonary Embolism (DVT/PE) by increasing venous blood flow to a patient who has a risk of DVT/PE.
A device intended to prevent DVT/PE by increasing venous blood flow to a patient who has a risk of 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.
The provided document is a 510(k) Pre-Market Notification for the DVT-4000S device. It does not contain a study demonstrating acceptance criteria for the device's performance in terms of its intended use (preventing DVT/PE by increasing venous blood flow).
Instead, the document focuses on demonstrating substantial equivalence to a predicate device (DVT-2600) based on technological characteristics and compliance with electrical safety and electromagnetic compatibility standards.
Therefore, many of the requested details about acceptance criteria, device performance against those criteria, sample sizes, expert involvement, and ground truth establishment are not present in this document.
Here's what can be extracted from the document:
1. Table of Acceptance Criteria and Reported Device Performance:
The document does not explicitly state acceptance criteria for DVT/PE prevention or venous blood flow increase, nor does it report performance metrics against such criteria. The "specifications" listed are more about the device's operational parameters rather than clinical outcomes.
| Metric/Characteristic | Acceptance Criteria (Not explicitly stated for clinical outcomes) | Reported Device Performance (Operational Specifications for DVT-4000S) |
|---|---|---|
| Intended Use | Device prevents DVT/PE by increasing venous blood flow | A device designed to prevent DVT/PE by increasing venous blood flow to a patient who has a risk of DVT/PE. (This is the intended use, not a performance metric.) |
| Power Source | N/A (for clinical outcome) | 100-240VAC, 50/60Hz, 90VA |
| Pressure (LEG) | N/A (for clinical outcome) | 20-60mmHg |
| Pressure (FOOT) | N/A (for clinical outcome) | 120-140mmHg |
| Battery | N/A (for clinical outcome) | 3500mAh |
| Number of chambers | N/A (for clinical outcome) | 3 |
| Electrical Safety | Compliance with IEC 60601:2005/A1:2012 | Complies with IEC 60601:2005/A1:2012 |
| Electromagnetic Compatibility | Compliance with IEC 60601-1-2:2014 | Complies with IEC 60601-1-2:2014 |
| Biocompatibility (in vitro cytotoxicity) | Compliance with ISO 10993-5:2009 | Complies with ISO 10993-5:2009 |
| Biocompatibility (irritation and skin sensitization) | Compliance with ISO 10993-10:2010 | Complies with ISO 10993-10:2010 |
2. Sample size used for the test set and the data provenance:
- Clinical Test Set: The document explicitly states: "Clinical testing was not required to demonstrate the substantial equivalence of the DVT-4000S to its predicate device." Therefore, there is no clinical test set mentioned, and thus no sample size or data provenance for such a test.
- Non-Clinical Test Set: For electrical safety, EMC, and biocompatibility, the sample size is not specified, but these are typically tested on a representative number of devices (e.g., a small batch) during product development and regulatory submission. The provenance would be from laboratory testing performed by the manufacturer or a certified testing facility.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
Not applicable, as no clinical test set requiring ground truth establishment by experts was conducted or reported.
4. Adjudication method for the test set:
Not applicable, as no clinical test set requiring adjudication was conducted or reported.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, if so, what was the effect size of how much human readers improve with AI vs without AI assistance:
Not applicable. This device is a mechanical compression device, not an AI-powered diagnostic or assistive tool for human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
Not applicable. This device is a mechanical compression device, not an algorithm.
7. The type of ground truth used:
Not applicable, as no clinical test involving ground truth for disease detection/prevention was performed. The ground truth for electrical safety or biocompatibility would be defined by the standards themselves (e.g., does it conduct electricity safely, does it cause cell death).
8. The sample size for the training set:
Not applicable, as this is a non-AI device; therefore, there is no training set mentioned.
9. How the ground truth for the training set was established:
Not applicable, as this is a non-AI device; therefore, there is no training set mentioned.
Summary of Study (as presented in the document):
The "study" presented is a substantial equivalence comparison to a legally marketed predicate device (DVT-2600). The manufacturer asserts that the DVT-4000S is substantially equivalent to the DVT-2600 based on:
- Identical Indications for Use: Both devices are intended to prevent DVT/PE by increasing venous blood flow.
- Similar Technological Characteristics: The operating principle (sequential inflation of air chambers) is the same. Key specifications like pressure range and number of chambers are identical.
- Minor Differences Justified: The differences (power consumption and inclusion of a battery in DVT-4000S) were deemed not to raise new questions of safety or effectiveness. Performance tests confirmed that the device functions equivalently when using AC power or battery.
- Compliance with Voluntary Standards: The DVT-4000S complies with recognized standards for electrical safety (IEC 60601-1:2012), electromagnetic compatibility (IEC 60601-1-2:2014), and biocompatibility (ISO 10993-5:2009, ISO 10993-10:2010).
The basis for market clearance, in this case, is not a clinical study demonstrating performance against specific clinical acceptance criteria, but rather a demonstration of substantial equivalence to an already cleared device and compliance with relevant safety and performance standards.
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(394 days)
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.
DVT-Pro device is a specialized intermittent pneumatic compression (IPC) system to prevent DVT (Deep Vein Thrombosis) and PE (Pulmonary Embolism) by improving the venous blood flow in at risk patients. The basic set of The Venous Assist System(DVT-PRO) consists of the main body, which includes the air pump that generates air pressure and control panel, air hose that transfers air pressure and sleeve (cuff) for calf and foot.
The provided document is a 510(k) Summary for a medical device called "DVT-Pro," a compressible limb sleeve system used to prevent Deep Vein Thrombosis (DVT). The document outlines the device's characteristics and compares it to a predicate device (DVT-2600) to demonstrate substantial equivalence, but it does not contain information on acceptance criteria or a study proving the device meets specific performance metrics in the way typically expected for an AI/ML device (e.g., sensitivity, specificity, or reader studies). The "performance data" section primarily refers to safety and software validation testing, not clinical performance for its stated indications.
Therefore, I cannot provide the detailed information requested in the prompt, especially points related to:
- A table of acceptance criteria and reported device performance (in terms of clinical efficacy metrics like accuracy, sensitivity, specificity).
- Sample size used for the test set or training set for clinical performance evaluation.
- Data provenance, number of experts, adjudication methods, or ground truth types for clinical performance.
- MRMC comparative effectiveness study or standalone performance.
The document focuses on demonstrating that the DVT-Pro device is substantially equivalent to an existing device (DVT-2600) based on:
- Intended Use: Both devices are for "Circulation Enhancement, Deep Vein Thrombosis Prophylaxis, Edema - Acute, Edema - Chronic, Extremity Pain Incident to Trauma or Surgery, Leg Ulcers, Venous Stasis / Venous Insufficiency." The DVT-Pro explicitly states it's for DVT prevention by improving blood velocity.
- Technological Characteristics Comparison (See the table on page 8-9): This table highlights similarities in mechanical and electrical specifications, such as mode of compression (sequential), pressure ranges (with slight differences in maximums for leg/foot), and general design.
- Safety and Software Validation:
- Biocompatibility testing: ISO10993-5, ISO10993-10 were performed.
- Electrical safety and performance testing: Conducted according to IEC 60601-1:2005 + CORR.1(2006) + CORR(2007).
- EMC testing: Conducted according to IEC 60601-1-2:2007.
- Software Verification and Validation Testing: Documented as per FDA's "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices." The software was classified as "minor" level of concern. All test results were satisfactory.
Key Missing Information (as per your prompt):
The document does not detail any clinical performance study (e.g., to measure the device's effectiveness in preventing DVT) with specific acceptance criteria like accuracy, sensitivity, or specificity. The "performance data" discussed is related to engineering and software validation for safety and proper functioning, not clinical outcomes directly demonstrating DVT prevention efficacy against a defined ground truth.
Therefore, I cannot populate the table or answer the specific questions regarding clinical performance studies, test set/training set sizes, expert involvement, or adjudication methods, as this information is not present in the provided text.
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(101 days)
LF-400 is intended for use by medical professionals and patients at home, who are under medical supervision, in treating many conditions, such as : Primary lymphedema, Edema following trauma and sport injuries, Postimmobilization edema, Venous insufficiencies. Lymphedema.
LF400 is the pressurization system helping to relieve the symptom of lymphedema and prevent aggravation of symptoms by applying the air pressure to limbs. LF400 comprises 4-step sleeves which move the body fluids through the limbs by evenly applying pressure to the limbs. The basic set of Air Compression Therapy System consists of the main body, which includes the air pump that generates air pressure and control panel, air hose that transfers air pressure and cutoff sleeve (cuff) for leg and its accessories include overlapping sleeve (cuff) for leg, cutoff sleeve (cuff) for arm, overlapping sleeve (cuff) for arm, cutoff sleeve (cuff) for waist and pants sleeve (cuff). The device consists of 4 parts-PCB, control panel, air pump (AC motor pump) and distributor (solenoid).
The provided text describes a 510(k) premarket notification for the LF-400 Compressible Limb Therapy System, which is a medical device for treating various lymphedema and edema conditions. The document focuses on demonstrating substantial equivalence to a predicate device, the LX7 (V7), rather than presenting a study specifically designed to establish acceptance criteria and prove the device meets them in the way clinical trials or AI performance evaluations usually do.
Based on the nature of this 510(k) submission, the "acceptance criteria" discussed are primarily related to safety, electrical performance, biocompatibility, and software validation, rather than clinical efficacy metrics like sensitivity or specificity. The "reported device performance" refers to the results of these technical tests, which found the device to be satisfactory and substantially equivalent to the predicate.
Here's an analysis of the requested information based on the provided text:
1. A table of acceptance criteria and the reported device performance
| Acceptance Criteria Category | Specific Criteria/Standard Adhered To | Reported Device Performance |
|---|---|---|
| Biocompatibility | ISO10993-5 (Cytotoxicity test)ISO 10993-10 (LLNA:BrdU-ELISA for sensitization)ISO 10993-10 (Animal Skin Irritation test) | Biocompatibility testing was conducted. No specific results are detailed, but the "Overall Performance Conclusions" state "All test results were satisfactory." |
| Electrical Safety | IEC 60601-1: 2005 + CORR.1(2006) + CORR(2007) | Electrical safety testing was conducted in accordance with the standard. The "Overall Performance Conclusions" state "All test results were satisfactory." Device is Class II, Type BF. |
| EMC (Electromagnetic Compatibility) | IEC 60601-1-2:2007 | EMC testing was conducted in accordance with the standard. The "Overall Performance Conclusions" state "All test results were satisfactory." |
| Software Validation | Followed FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices." Software considered "moderate" level of concern (failure would not directly result in serious injury or death). | Software verification and validation testing were conducted and documented as recommended. The "Overall Performance Conclusions" state "All test results were satisfactory." Software version LF400.c V1.0. |
| Functional Equivalence | Device functionality (e.g., pressure range, modes, sequential compression) and indications for use are substantially equivalent to the predicate device (LX7). Tolerances for cuff sizes (± 2cm). Manufacturer Recommended Pressure Range: 60-120mmHg. | LF-400 pressure range: 20-140mmHg, recommended 60-120mmHg. Modes: A, B, C, Pre-Therapy (new mode described as not for therapy but for reducing fatigue). Therapy time: 5-180 minutes. Cuff material: Nylon (same as predicate). All considered satisfactory and substantially equivalent. |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
The document does not describe a "test set" in the context of clinical data (e.g., patient cases). The performance data cited are from technical tests (biocompatibility, electrical safety, EMC, software). These types of tests typically use specific numbers of samples of the device components or the device itself, rather than a "sample size" of patients or data from medical records. The text does not specify the exact number of units or materials tested for these engineering and materials assessments.
Regarding data provenance:
- The submitter, DaeSung Maref Co., Ltd., is located in the Republic of Korea.
- The standards (ISO, IEC, FDA guidance) are international and US-based.
- The tests are implied to be conducted as part of the device development and regulatory submission process, which would typically be prospective for these types of technical evaluations.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
This is not applicable to the type of performance data presented. The "ground truth" for technical standards is the standard itself, and the performance is measured against objective criteria within that standard by qualified test engineers/labs, not by a panel of medical experts establishing consensus on patient-specific data.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This is not applicable. Adjudication methods are used for expert review of clinical results or imaging data, which are not part of this document's performance section.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
This is not applicable. The LF-400 is a physical medical device (compressible limb therapy system), not an AI/imaging diagnostic tool that involves "human readers" or AI assistance in interpretation.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This is not applicable as the device is not an AI algorithm. Its software validation ensures its control functions operate correctly, but it does not perform diagnostic interpretation or AI-driven decision-making in a "standalone" algorithmic sense.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
For the technical performance data, the "ground truth" is adherence to established international and national standards (ISO, IEC) for biocompatibility, electrical safety, EMC, and FDA guidance for software. These standards define the acceptable parameters and test methodologies.
8. The sample size for the training set
This is not applicable. This device does not use machine learning or AI that would require a "training set" of data. The software components are for control and user interface, verified through traditional software validation methods.
9. How the ground truth for the training set was established
Not applicable, as there is no training set for an AI/ML model for this device.
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(146 days)
MK300L is intended for use by medical professionals and patients at home, who are under medical supervision, in treating many conditions, such as : Primary lymphedema, Edema following trauma and sport injuries, Postimmobilization edema, Venous insufficiencies, Lymphedema.
MK300L is used with four chamber garments for full leg, and period has its own variable duration,pressure, cycle time and gradient setting. Power unit features visual operation statusand fault indicators.
The provided text is a 510(k) summary for the Compressible Limb Therapy System MK300L, which is a medical device and not an AI/ML device. Therefore, the questions related to AI/ML device performance metrics, such as sample sizes for test and training sets, ground truth establishment, expert qualifications, and MRMC studies, are not applicable to this document.
The document focuses on demonstrating substantial equivalence to predicate devices rather than providing detailed performance studies or acceptance criteria in the context of AI/ML evaluation.
However, based on the provided text, I can extract information relevant to the device's regulatory review and intended use:
1. Acceptance Criteria and Reported Device Performance:
The document does not explicitly state quantitative acceptance criteria in terms of performance metrics (e.g., accuracy, sensitivity, specificity) for the device. Instead, it relies on demonstrating substantial equivalence to predicate devices. The "reported device performance" is implicitly that it meets the safety and effectiveness standards comparable to the predicate devices.
| Acceptance Criteria Category | Specific Acceptance Criteria (Not explicitly quantitative) | Reported Device Performance (Implicitly met through substantial equivalence) |
|---|---|---|
| Intended Use Equivalence | Intended use is substantially equivalent to predicate devices. | MK300L has substantial equivalent intended use as the-market-cleared LX-7. |
| Technological Characteristics Equivalence | Technological characteristics are substantially equivalent to predicate devices. | MK300L has substantial equivalent technological characteristics with Lympha press plus and WIC-2008. |
| Performance Characteristics Equivalence | Performance characteristics are substantially equivalent to predicate devices, without new safety/effectiveness concerns. | Confirmed through bench and laboratory testing to applicable standards. Concluded that MK300L is as safe and effective as predicate devices. |
| Safety Standards Compliance | Compliance with relevant medical device safety, quality, and electromagnetic compatibility standards. | Conducted and applied by standards including Council Directive 93/42/EEC, IEC 980:2003, IEC 1041:1998, ISO 13485:2003, ISO 14155-1.2003, ISO 14971:2007, IEC 60601-1, IEC 60601-1-2. |
2. Sample Size Used for the Test Set and Data Provenance:
The document mentions "bench as well as laboratory testing to applicable standards" but does not specify sample sizes for any test sets in terms of patient data or data provenance (e.g., country of origin, retrospective/prospective). This type of detail is typically not included in a 510(k) summary focused on substantial equivalence for a non-AI/ML device.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:
Not applicable. This question pertains to AI/ML device evaluation where expert consensus is often used for ground truth. For a physical medical device like a massager, ground truth would typically relate to physical measurements, engineering standards, or clinical outcomes, not expert interpretation of data.
4. Adjudication Method for the Test Set:
Not applicable. This question is relevant to AI/ML evaluations where disagreements between experts need to be resolved. For a non-AI device, adjudication methods in this context are not described.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and Effect Size:
No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done or described. MRMC studies are specific to evaluating how human readers' performance changes with or without AI assistance, which is not applicable to this device.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done:
Not applicable. This device is a physical massager and does not involve an algorithm or AI component in the sense of a software-as-a-medical-device (SaMD) evaluated for standalone performance.
7. The Type of Ground Truth Used:
The "ground truth" for this device's evaluation is based on compliance with established medical device standards (e.g., electrical safety, quality management, risk management, clinical investigation general requirements) and demonstrating that its performance is comparable to legally marketed predicate devices through "bench as well as laboratory testing." Clinical outcomes data might be inferred from the predicate devices' long-standing safety and effectiveness, but it's not explicitly stated as the ground truth for this specific device's evaluation.
8. The Sample Size for the Training Set:
Not applicable. This device does not use a training set as it is not an AI/ML device.
9. How the Ground Truth for the Training Set Was Established:
Not applicable. This device does not have a training set.
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(121 days)
DVT-2600 is a system to prevent DVT (Deep Vein Thrombosis) by improving the blood velocity of patients. DVT-2600 is Circulation Enhancement, Deep Vein Thrombosis Prophylaxis, Edema - Acute, Edema - Chronic, Extremity Pain Incident to Trauma or Surgery, Leg Ulcers, Venous Stasis / Venous Insufficiency.
DVT-2600 device is a specialized intermittent pneumatic compression (IPC) system to prevent DVT (Deep Vein Thrombosis) and PE (Pulmonary Embolism) by improving the venous blood flow in at risk patients. The system consists of the controller, the tubing sets and 3 types(Non-woven, Fabric, Oxford) garments. The system offers Sequential inflation promoting venous blood movement and metabolism and then has sufficient interval time to refill with blood sufficiently after deflation. The operation of the inflation and deflation is repeated until the stop button is activated.
The provided 510(k) summary for K112677, "The Venous Assist System DVT-2600", does not contain details about specific acceptance criteria or a study that definitively proves the device meets such criteria in terms of performance metrics like sensitivity, specificity, or reader improvement.
Instead, the document focuses on demonstrating substantial equivalence to a predicate device (SCD Express™4 system, K040511) through:
- Comparison of Intended Use: Stating that the DVT-2600 has "substantial equivalent intended use" to the predicate.
- Comparison of Technological and Performance Characteristics: Claiming "substantial equivalent technological and performance characteristics," and that it is "as safe and effective as the predicate devices, has few technological differences, but there are no new indications for use and without raising any new safety and/or effectiveness concerns."
- Adherence to Standards: Listing several international standards (IEC, ISO) that the device complies with, which are general safety and quality management standards rather than specific performance metrics for DVT prevention efficacy. These include:
- Council Directive 93/42/EEC
- IEC 980:2003
- IEC1041:1998
- ISO 13485:2003
- ISO 14155-1:2003
- ISO 14971:2007
- IEC 60601-1
- IEC 60601-1-2
The document explicitly states "After analyzing both bench as well as laboratory testing to applicable standards," but does not provide any specific results or data from these tests, nor does it describe a clinical study measuring performance against acceptance criteria for DVT prevention efficacy. This is typical for a 510(k) submission seeking substantial equivalence for devices of this type, where performance often relies on demonstrating similar operational principles and safety to already-cleared devices, rather than a new clinical efficacy trial with detailed performance metrics.
Therefore, most of the requested information cannot be extracted from the provided text.
Here is a summary of what can be inferred or is stated, and what is missing:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|
| Substantial equivalence to predicate (SCD Express™4 system) | The device is as safe and effective as the predicate. |
| Few technological differences compared to predicate | Few technological differences reported. |
| No new indications for use compared to predicate | No new indications for use reported. |
| No new safety and/or effectiveness concerns compared to predicate | No new safety and/or effectiveness concerns reported. |
| Compliance with relevant international standards (e.g., IEC, ISO) | Bench and laboratory testing to applicable standards completed. (Specific results not provided) |
| Improvement of blood velocity (implied mechanism of action) | Claims to "improve the blood velocity of patients." (Specific metrics not provided) |
Missing: Specific quantitative acceptance criteria (e.g., target increase in blood velocity, DVT incidence reduction, specific pressure ranges, cycle times, etc.) and direct performance data to demonstrate meeting these criteria.
2. Sample size used for the test set and the data provenance
Missing. The document does not describe a clinical "test set" involving human subjects or data that would typically have a sample size for performance evaluation. The "bench as well as laboratory testing" mentioned likely refers to engineering tests and basic safety assessments, not a clinical study on patient outcomes or diagnostic performance.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Missing. No information on experts or ground truth establishment is provided, as no clinical performance study akin to a diagnostic device trial is detailed.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set
Missing. No adjudication method is mentioned.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
Missing. This device is an intermittent pneumatic compression system for DVT prophylaxis, not an AI-powered diagnostic or decision support tool for human readers. Therefore, an MRMC study is not applicable to its function.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done
Missing. This is not an algorithm-only device. It is a physical medical device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
Missing. As no clinical performance study is described with detailed results, no ground truth type is specified. For a device like this, clinical ground truth would typically be DVT incidence or objective measures of blood flow.
8. The sample size for the training set
Missing. This device is not an AI/ML model that would have a "training set."
9. How the ground truth for the training set was established
Missing. Not applicable, as this is not an AI/ML model.
In summary: The provided 510(k) emphasizes substantial equivalence to a predicate device and adherence to general medical device safety and quality standards (e.g., ISO, IEC). It does not detail a specific clinical study with quantitative performance acceptance criteria, sample sizes, or ground truth establishment for measuring the device's efficacy in preventing DVT. This approach is common for devices demonstrating substantial equivalence where the predicate has already established clinical effectiveness.
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(199 days)
LX7(V7) is intended for use by medical professionals and patients at home, who are under medical supervision, in treating many conditions, such as : Primary lymphedema, Edema following trauma and sport injuries, Postimmobilization edema, Venous insufficiencies, Lymphedema.
LX7(V7) is used with four chamber garments for full leg, and period has its own variable duration,pressure, cycle time and gradient setting. Power unit features visual operation statusand fault indicators.
The provided text describes a 510(k) premarket notification for a medical device called the "Compressible Limb Therapy System LX7(V7)". This submission focuses on establishing substantial equivalence to predicate devices rather than proving performance against specific acceptance criteria through a clinical study with statistical endpoints. Therefore, a direct table of acceptance criteria and reported device performance, as typically seen in efficacy studies, is not applicable or present in this document.
The core of this submission is a comparison of the new device (LX7(V7)) to two predicate devices (Lympha Press Plus and WHF-324 (POWER-Q1000 Plus)) to demonstrate that it is "as safe and effective". The "Performance Characteristics" section lists various standards the device applied and conducted tests to, which are related to safety and quality management, but it does not detail specific performance metrics or their acceptance thresholds.
Here's an analysis based on the provided document:
1. Table of Acceptance Criteria and Reported Device Performance
As mentioned, the document does not present quantitative acceptance criteria or numerical performance data of the LX7(V7) in the way one would expect from an efficacy study. Instead, substantial equivalence is established by comparing the new device's features, intended use, and adherence to safety standards with those of legally marketed predicate devices.
The table below summarizes the comparison between the LX7(V7) and its predicate devices, which serves as the basis for the substantial equivalence determination rather than a direct performance acceptance criteria table.
| Feature | LX7(V7) | Lympha Press Plus (Predicate 1) | WHF-324 (POWER-Q1000 Plus) (Predicate 2) |
|---|---|---|---|
| K Number | None yet (being applied for) | K013331 | K100656 |
| Classification | Class II Device / IRP (21 CFR 890.5650) | Class II Device / JOW (21 CFR 870.5800) | Class II Device / IRP (21 CFR 890.5650) |
| Intended Use | Intended for use by medical professionals and patients at home, under medical supervision, in treating: Primary lymphedema, Edema following trauma and sport injuries, Post-immobilization edema, Venous insufficiencies, Lymphedema. | Treatment of Lymphatic disorders, Venous disorder, Post-mastectomy Lymphedema and Dysfunction of the Muscle Pump. | Intended for use by medical professionals and patients at home, under medical supervision, in treating: Primary lymphedema, Edema following trauma and sport injuries, Post immobilization edema, Venous insufficiencies, Lymphedema. |
| Standards Applied | EN ISO 14971, EN 60601-1, EN 60601-2-10, EN 60601-1-2 | EN ISO 14971, EN 60601-1, EN 60601-2-10, EN 60601-1-2 | EN ISO 14971, EN 60601-1, EN 60601-2-10, EN 60601-1-2 |
| Indications | Primary lymphedema, Edema following trauma and sport injuries, Post-immobilization edema, Venous insufficiencies, Lymphedema. | - (Listed under Intended Use) | Primary lymphedema, Edema following trauma and sport injuries, Post immobilization edema, Venous insufficiencies, Lymphedema. |
| Mode of Compression | Sequential | Sequential | Sequential |
| Mode description | 2 modes | 2 modes (Lympha, Gradient12, Wave, Ballancer, and Pre-Therapy) | 1 mode |
| Power Source | 230 V~, 50/60 Hz; 35W | 230 V~, 50/60 Hz | 220~240V 50/60Hz; 25 watts |
| Therapy Time | 0-30 minutes | 0-10 minutes | 0-30 minutes |
| Max/Min Pressure | 0-230mmHg | 0-200mmHg | 0-235mmHg |
| Number of Chambers | 4 to 8 chambers | 12 chambers | 4 to 8 chambers |
| Compression Cycle Time | 30 min | 30 min | 30 min |
| Garment Sleeve Material | Nylon | - | Nylon |
2. Sample size used for the test set and the data provenance
The document does not describe a clinical study with a "test set" in the context of evaluating diagnostic or predictive performance. Instead, it relies on bench and laboratory testing against established safety and quality standards to demonstrate the device's characteristics. Therefore, information on sample size and data provenance for a test set in a performance study is not applicable. The data provenance for the device is from Korea (manufacturer Daesung Maref Co., Ltd.). The study described is a premarket notification for substantial equivalence, not a clinical trial.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This information is not provided because the submission is not based on a clinical study where expert-established ground truth would be necessary for a test set.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set
Not applicable, as no test set data requiring adjudication is presented.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
Not applicable. The device is a 'Powered Inflatable Tube Massager' without AI components or diagnostic capabilities that would involve human readers interpreting images or data.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done
Not applicable, as this is a physical medical device, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
The "ground truth" in this context refers to compliance with recognized international and national standards for medical device safety and quality. The device demonstrated conformance to standards such as:
- Council Directive 93/42/EEC (medical devices)
- IEC 980:2003 (graphical symbols)
- IEC1041:1998 (information supplied by manufacturer)
- ISO 13485:2003 (quality management systems)
- ISO 14155-1:2003 (clinical investigation, Part 1: General requirements - this standard specifies requirements for the design, conduct, recording, and reporting of clinical investigations performed on human subjects to assess the clinical performance or safety of medical devices. Its mention here suggests the potential for clinical investigations, but the document itself doesn't detail one.)
- ISO 14971:2007 (risk management)
- IEC 60601-1 (general requirements for safety)
- IEC 60601-2-10 (safety of nerve and muscle stimulators)
- IEC 60601-1-2 (electromagnetic compatibility)
The "ground truth" for the substantial equivalence claim is that the device's characteristics and performance are comparable to (i.e., "as safe and effective as") the predicate devices, which have already been cleared by the FDA.
8. The sample size for the training set
Not applicable, as there is no mention of an algorithm or machine learning model that would require a training set.
9. How the ground truth for the training set was established
Not applicable for the same reason as above.
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