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510(k) Data Aggregation

    K Number
    K212169
    Date Cleared
    2021-11-23

    (134 days)

    Product Code
    Regulation Number
    890.5650
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Air compression therapy system FO3002 is intended for home to temporarily relieve minor muscle aches and/or pains, and to temporarily increase circulation to the treated areas.

    Device Description

    Air compression therapy system FO3002 is consist of air pressure sensor, air pump, sleeves etc working together as one unit. The air pump is connected to the dedicated sleeves via a series of hoses. The compression massage direction is from limb end to body center by inflating the air chambers sequentially and then deflating as one cycle, the pressure can be adjusted to avoid any discomfort to the patient. The sleeve works under the action of sensor and microprocessor.

    Air compression therapy system FO3002, in medical market, it has a sequential squeezing from distal to proximal, thus help to improve circulation to the treated areas. Clothing should be worn between the device and the patient's skin.

    AI/ML Overview

    This document is a 510(k) Premarket Notification from the FDA for an "Air compression therapy system FO3002". It demonstrates the device's substantial equivalence to a legally marketed predicate device (NormaTec Pulse and NormaTec Pulse Pro, K160608).

    Based on the provided text, the device does not involve an AI algorithm or performance criteria that would require a study as described in the prompt. The "acceptance criteria" discussed are related to technical specifications and safety standards, rather than diagnostic accuracy or human performance with AI assistance.

    Therefore, many of the requested sections (2-9) are not applicable to this document as it pertains to a physical medical device (an air compression therapy system) that does not incorporate AI or require assessment of its diagnostic performance through a test set and ground truth.

    However, I can extract the acceptance criteria in terms of the device's characteristics and how it compares to the predicate, which serves as its "performance" in the context of this 510(k) submission.

    1. A table of acceptance criteria and the reported device performance

    In a 510(k) submission, "acceptance criteria" are implicitly met by demonstrating substantial equivalence to a predicate device. This is primarily shown through a comparison of technological characteristics and indications for use. The "reported device performance" in this context refers to how closely the subject device's characteristics match or are explained in relation to the predicate.

    Feature/CriteriaAcceptance Criteria (Predicate: NormaTec Pulse/Pulse Pro, K160608)Reported Device Performance (Air compression therapy system FO3002)Discussion/Equivalence
    Indications for UseTemporarily relieve minor muscle aches and/or pains, and to temporarily increase circulation to the treated areas.Temporarily relieve minor muscle aches and/or pains, and to temporarily increase circulation to the treated areas.Same
    Pressure Range30-110mmHg30-110mmHgSame
    Treatment TimeStays on until the user turns it off or can be set up to turn off in a range of 10 mins to continuous / User controlled 10 minutes to 175 minutes or continuous - total time over 4 segments.10-60minSimilar (Subject device's range is smaller, which does not raise adverse impact on safety/effectiveness).
    Standard ComplianceES 60601-1, IEC 60601-1-2, IEC 60601-1-11ANSI AAMI ES60601-1:2005/(R)2012 and A1:2012, C1:2009/(R)2012 and A2:2010/(R)2012, IEC 60601-1-2, IEC 60601-1-11, IEC 62133-2, ISO 10993-5, ISO 10993-10Similar (Subject device tested to more standards, indicating robust compliance).
    Mode of CompressionSequential Gradient, Peristaltic and PulsingSequential (The document lists various modes for the subject device: Normal, Sequential, Double, Whole, Combined A+B, which are compared to the predicate's modes, stating A and C are the same with the predicate).Same (with additional modes or variations whose differences don't adversely impact safety/effectiveness).
    Power Source12 VDC via an IEC 60601-1 compliant power supply (100-240 VAC input) Optional Integrated rechargeable batteryAdaptor: AC 100-240V, 50/60Hz; Main unit: DC 15V, 1.5ASimilar
    Power Consumption14W22.5VASimilar
    Dimensions (Main unit)4" x 5" x 9"265 x 130 x 100mmSimilar
    Housing MaterialsMolded ABS enclosureMolded ABS enclosureSame
    Number of Chambers (Sleeves)5 or less6Similar (The additional chamber is likely an enhancement not impacting fundamental safety/effectiveness for the stated indications).
    Safety FeaturesButton on display allows user to stop or pause therapy session at any timeButton on display allows user to stop or pause therapy session at any timeSame
    TechnologyCompressor and valve system which sequentially inflates inflatable chambersCompressor and valve system which sequentially inflates inflatable chambersSame
    Intended Population/EnvironmentNot explicitly stated in comparison table but implied OTC/Home use.Intended for home use. Over-The-Counter Use.Same

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    This information is Not Applicable (N/A). The device is an air compression therapy system, not an AI/software device that processes data for diagnostic purposes requiring a test set for performance evaluation. The submission relies on technical and safety testing to demonstrate equivalence, not clinical performance data from a patient population.

    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)

    N/A. No diagnostic "ground truth" or expert review of patient data was necessary for this device type.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    N/A. No test set or adjudication process as described for AI/diagnostic devices was performed.

    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

    N/A. This is not an AI-assisted diagnostic device.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    N/A. Not an algorithm-based device.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    N/A. No ground truth of this nature was established. The "ground truth" for this type of submission is the established safety and effectiveness of the predicate device, against which the subject device's technical specifications and safety profile are compared for substantial equivalence.

    8. The sample size for the training set

    N/A. No training set was used as this is not a machine learning/AI device.

    9. How the ground truth for the training set was established

    N/A. No training set or associated ground truth was established.

    Summary of Study that Proves the Device Meets Acceptance Criteria:

    The study that proves the device meets the "acceptance criteria" (i.e., is substantially equivalent to a legally marketed predicate) is presented as a comparative analysis of technical specifications and safety standards compliance.

    • Evidence Type: The submission relies on non-clinical performance testing (compliance with electrical safety, EMC, biocompatibility standards like IEC 60601-1-11, IEC 60601-1-2, ANSI AAMI ES60601-1, ISO 10993-5, ISO 10993-10, IEC 62133-2) and a direct comparison of the subject device's features to those of the predicate device.
    • Methodology: The manufacturer states "Performance Testing - Clinical" and "Performance Testing - Animal" are "Not Applicable". This indicates that no human or animal studies were conducted to prove performance for this 510(k) submission. Instead, the demonstration of substantial equivalence is built upon:
      • Identical Indications for Use.
      • Similar (or identical) technological characteristics: as detailed in the comparison table (e.g., pressure range, mode of compression, power source, materials, safety features). Any differences are argued not to raise new questions of safety or effectiveness.
      • Compliance with recognized electrical safety and biocompatibility standards.
    • Conclusion of the Study (FDA's Determination): The FDA's letter (K212169) signifies that based on the provided information, the device is considered "substantially equivalent" to predicate devices, meaning it is "as safe, as effective, and performs as well as the legally marketed predicate devices." This substantial equivalence is the ultimate "proof" required for market clearance under the 510(k) pathway for this type of device.
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    K Number
    K201982
    Date Cleared
    2021-03-25

    (251 days)

    Product Code
    Regulation Number
    890.5650
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Air compression therapy system Models FO-3001 and FO-3008: Intended for home to temporarily relieve minor muscle aches and/or pains, promote blood circulation in the treated areas.

    Device Description

    Air Pressure Therapy System is consist of air pressure sensor, air pump, sleeves etc working together as one unit. The air pump is connected to the dedicated sleeves via a series of hoses. The compression massage direction is from limb end to body center by inflating the air chambers sequentially and then deflating as one cycle, the pressure can be adjusted to avoid any discomfort to the patient. The sleeve works under the action of sensor and microprocessor.

    Air Pressure Therapy System, in medical market, it has a sequential squeezing from distal to proximal, thus help to improve the circulation of blood.

    AI/ML Overview

    The provided FDA 510(k) summary (K201982) indicates that the Air compression therapy system FO-3001 and FO-3008 are substantially equivalent to the NormaTec Pulse and NormaTec Pulse Pro (K160608) predicate device.

    Here's an analysis of the acceptance criteria and study information based on the provided document:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly state "acceptance criteria" as a separate, quantified list with pass/fail thresholds. Instead, the substantial equivalence is established by comparing the subject device's characteristics against those of the predicate device (K160608). The underlying assumption is that if the subject device's performance, safety features, technological characteristics, and intended use are similar or equivalent to a legally marketed predicate, it meets the necessary criteria for market clearance.

    The "acceptance criteria" are implicitly derived from the characteristics of the predicate device and the recognized consensus standards. The "reported device performance" is then the subject device's characteristics as described.

    CharacteristicAcceptance Criteria (Predicate Device K160608)Reported Device Performance (FO-3001/FO-3008)Discussion of Differences
    Indications for UseIntended to temporarily relieve minor muscle aches and/or pains, and to temporarily increase circulation to the treated areas.Intended for home to temporarily relieve minor muscle aches and/or pains, promote blood circulation in treated areas.Same
    Rx or OTCOTCOTCSame
    Pressure Range30-110mmHg30-110mmHgSame
    Treatment TimeStays on until the user turns it off, or can be set up to turn off in a range of 10 mins to continuous / User controlled 10 minutes to 175 minutes or continuous – total time over 4 segments.1-60minsSimilar: Subject device's treatment time is smaller. Concluded not to adversely impact safety and effectiveness.
    Standards AppliedES 60601-1, IEC 60601-1-2, IEC 60601-1-11IEC 60601-1-11:2015, IEC 60601-1-2:2014, IEC 60601-1:2005, ISO 10993-10:2010, ISO 10993-5:2009, ISO 10993-12:2012Similar: Both devices adhere to relevant electrical safety, EMC, and biological evaluation standards. The subject device lists additional ISO standards for biological evaluation.
    Mode of CompressionSequential Gradient, Peristaltic and PulsingSequential (FO-3001 has 6 modes including "Normal Mode" which is sequential; FO-3008 has 4 modes including "Normal Mode" which is sequential)Same (regarding sequential): While the subject device offers more "work modes" (e.g., Double Wave, Whole Squeeze, Combined modes), the "Mode A (Normal Mode)" for both FO-3001 and FO-3008 aligns with the predicate's sequential compression. The differences in other modes and chamber inflation order are argued not to adversely impact safety and effectiveness due to the same pressure range.
    Power Source12 VDC via an IEC 60601-1 compliant power supply (100-240 VAC input) Optional Integrated rechargeable battery100-127V/220-240V, 50/60HzSimilar: Both use standard power supplies. Differences are in specific voltage/Hz and the predicate's optional battery. Concluded as similar.
    Power Consumption14W65WSimilar: Different wattage, but implies it's not a safety/effectiveness concern.
    Safety FeatureButton on display allows user to stop or pause therapy session at any timePower button on main unit allows user to stop therapy session at any timeSame
    TechnologyCompressor and valve system which sequentially inflates inflatable chambersCompressor and valve system which sequentially inflates inflatable ChambersSame
    Dimensions4" x 5" x 9"FO-3001: 220190113MM; FO-3008: 240200110MMSimilar: Different physical dimensions.
    Number of Chambers5 or lessFO-3001: 4, 6, 8 Chambers for each unit; FO-3008: 4 Chambers for each unitSimilar: FO-3001 offers more chambers. This difference is not stated to adversely impact safety and effectiveness.
    Housing MaterialsMolded ABS enclosureMolded ABS enclosureSame

    2. Sample size used for the test set and the data provenance

    The document states "Performance Testing - Clinical: Not Applicable" and "Performance Testing - Animal: Not Applicable" (Page 4). This indicates that no clinical or animal studies were conducted for this 510(k) submission to demonstrate performance. The clearance is based on substantial equivalence to the predicate device through technological comparison and adherence to recognized consensus standards.

    Therefore, there is no test set, sample size, or data provenance information provided in this document as it was not required for this type of submission.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    As no clinical or animal performance testing was conducted, there was no test set, and therefore no experts were used to establish ground truth in the context of device performance. The evaluation was primarily engineering and regulatory.

    4. Adjudication method for the test set

    Not applicable, as no dedicated test set or clinical performance study was conducted.

    5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, and the effect size of how much human readers improve with AI vs without AI assistance

    Not applicable. This device is an air compression therapy system, not an AI-powered diagnostic or assistive tool for human readers. No MRMC study was performed.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    Not applicable. This device is hardware-based for physical therapy, not an algorithm or software. No standalone performance study was conducted.

    7. The type of ground truth used

    Not applicable, as no performance studies with a ground truth component were conducted. The "ground truth" for this 510(k) is effectively the established safety and effectiveness of the legally marketed predicate device (K160608), supported by the subject device's adherence to relevant technical standards.

    8. The sample size for the training set

    Not applicable, as this device does not involve machine learning or AI models with training sets.

    9. How the ground truth for the training set was established

    Not applicable, as this device does not involve machine learning or AI models with training sets.

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