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510(k) Data Aggregation

    K Number
    K231569
    Manufacturer
    Date Cleared
    2023-11-03

    (156 days)

    Product Code
    Regulation Number
    882.5890
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    ManaMed, Inc

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    For Over-The-Counter Use:

    TENS:

    ManaFlexx 2 (MF002-OTC) is used for temporary relief of pain associated with sore and aching muscles in the shoulder, waist, back, arm, and leg, due to strain from exercise or normal household and work activities. ManaFlexx 2 (MF002-OTC) is also intended for symptomatic relief and management of chronic, intractable pain and relief of pain associated with arthritis.

    PMS/NMES:

    ManaFlexx2 (MF002-OTC) is used to stimulate healthy muscles in order to improve and facilitate muscle performance. To be used for the improvement of muscle tone and firmness, and for strengthening muscles in the arms, abdomen, legs, and buttocks. Not intended for use in any therapy or for the treatment of any medical conditions or diseases. ManaFlexx2 (MF002-OTC) is also intended to temporarily increase local blood circulation in the healthy muscles of lower extremities.

    For Prescription Use:

    TENS:

    ManaFlexx2 (MF002-RX) is intended for the following use:

    • Symptomatic relief and management of chronic, intractable pain
    • Adjunctive treatment for post-surgical and post-trauma acute pain
    • Relief of pain associated with arthritis

    PMS/NMES:

    ManaFlexx2 (MF002-RX) is intended for the following use:

    • Temporary relaxation of muscle spasm
    • Prevention or retardation of disuse atrophy
    • Muscle re-education
    • Maintaining or increasing range of motion
    • Increase of local blood flow in the treatment area
    • Prevention of post-surgical venous thrombosis through immediate stimulation of calf muscles
    Device Description

    The ManaFlexx 2 delivers electric pulse generated to the user's body areas through the electrodes. The device has two program modes of different pulse frequencies, covering TENS and PMS/NMES. The main unit is egg shape, includes operating elements, such as the ON/OFF button, intensity increase button and intensity decrease button, and there are two snap connectors on the rear of the device which are for connecting with electrode. The device could be easily operated through its buttons to manually realize its functions, such as turning on/off and increasing/decreasing intensity, and there is a LED screen to display the selected mode, intensity level and charging status.

    The electrode is a long strip shape with a size of 21cm x 5.3cm, its conductive part is black color, and there is white non-conductive area with a width of 1 cm in the middle, which divides the electrode into two parts: positive and negative. There are 2 snap connectors on the electrode used for connection with main unit.

    The device has two models have the same appearance, the identical hardware and software, only the model names are different and model MF002-Rx is for prescription use and MF002-OTC is for OTC use.

    AI/ML Overview

    The provided text is a 510(k) Summary for the ManaFlexx 2 device, a TENS/PMS/NMES unit. It details the device's comparison to predicate devices and summarizes non-clinical performance testing. However, it explicitly states: "Clinical testing was not performed on the device."

    This means there is no study described that proves the device meets acceptance criteria based on human-in-the-loop performance, expert consensus, or clinical outcomes. The acceptance criteria and "study that proves the device meets the acceptance criteria" in this document refer exclusively to non-clinical performance testing against recognized standards.

    Below is a breakdown of the requested information based only on the provided text, focusing on the non-clinical performance testing mentioned. Many points cannot be answered as they relate to clinical studies that were "not performed."


    Device: ManaFlexx 2 (model: MF002-RX, MF002-OTC)

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

    Test TitleAcceptance CriteriaReported Device Performance
    General requirements for basic safety and essential performance (against ANSI AAMI ES60601-1:2005/(R)2012 & A1:2012, C1:2009/(R)2012 & A2:2010/(R)2012 (Cons. Text) [Incl. AMD2:2021])The test is carried out under the test method specified in the standard, and the test result is within the test acceptance range of the standard.Pass
    Electromagnetic disturbances (against IEC 60601-1-2 Edition 4.1 2020-09)No degradation of performance was found during test.Pass
    Requirements for medical electrical equipment and systems used in the home healthcare environment (against IEC 60601-1-11 Edition 2.1 2020-07)The device operates normally, and can provide basic safety and essential performance.Pass
    Requirements for the basic safety and essential performance of nerve and muscle stimulators (against IEC 60101-2-10 Edition 2.1 2016-04)The test is carried out under the test method specified in the standard, and the test result is within the test acceptance range of the standard.Pass
    Dispersion and Shelf Life TestThe impedance change before the new and aging electrode, used electrode should not exceed ± 20% of the initial average impedance.Pass
    Waveform & Output TestAccording to "IEC 60601-2-10, Particular requirements for the safety of nerve and muscle stimulators", the limitation of output parameters with 500Ω resistance load should meet the following requirement:
    ● The output current limit r.m.s. with 500Ω resistance load is 80mA
    ● For pulse durations of less than 0.1s, the pulse energy with 500Ω resistance load shall not exceed 300mJ per pulse.
    ● The output voltage shall not exceed a peak value of 500V, when measured under open-circuit condition.
    Otherwise, the following two Acceptance Criteria for the device according to FDA Guidance:
    ● Maximum Power Density ≤ 0.25 (W/cm²)Pass
    Biocompatibility testing (against predicate SM Electrodes cleared in K183154)The conductive hydrogel electrode of ManaFlexx 2 is identical to the SM Electrodes as it was cleared in K183154, 2019, in formulation, processing, and sterilization, and no other chemicals have been added.Deemed identical
    Usability Testing (against IEC 62366-1 and IEC 60601-1-6)The device complies with IEC 62366-1 and IEC 60601-1-6.Complies
    Software verification and validation testing (against FDA Guidance "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices")Software for this device was considered as a "moderate" level concern, since a malfunction of, or a latent design flaw in, the Software Device leads to an erroneous diagnosis or a delay in delivery of appropriate medical care that would likely lead to Minor Injury. (Implied acceptance is that the V&V was successful for this concern level).Conducted and documented
    CybersecurityNo external interfaces, thus no need for cybersecurity evaluation per FDA guidance "Content of Premarket Submissions for Management of Cybersecurity in Medical Devices."Not applicable
    Shelf-life testingMaintain performance in 2 years (acceptable criteria similar to K171722).Maintain performance

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

    • Sample Size: For performance testing (bench tests), the sample size is stated as "The test sample is the final, finished product." No specific number is given, but typically this means a small number of units (e.g., 3-5) are tested to demonstrate compliance.
    • Data Provenance: The tests are non-clinical, lab-based performance tests against international standards. The 510(k) application is from ManaMed, Inc. (USA) with an application correspondent in Guangzhou, Guangdong, China. The testing likely occurred in a lab affiliated with the manufacturer or a third-party testing facility, potentially in China (where the correspondent is located). The data is generated prospectively as part of the regulatory submission process.

    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)

    • Not applicable. Ground truth as typically understood in AI/clinical studies (e.g., expert consensus on medical images or patient outcomes) was not established because "Clinical testing was not performed on the device." The "ground truth" for these tests is defined by the technical specifications and performance limits set by the referenced international standards (e.g., IEC, ANSI AAMI).

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

    • Not applicable. This concept applies to human consensus or expert review processes, which were not part of the described non-clinical testing.

    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

    • No. "Clinical testing was not performed on the device."

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

    • No. This device is a physical TENS/PMS/NMES unit, not an AI algorithm. The performance tests are for the electrical and mechanical functions of the device itself.

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

    • The "ground truth" for the non-clinical tests is the adherence to the published performance specifications and limits defined by the referenced international consensus standards (e.g., IEC 60601 series, ANSI AAMI ES60601-1). This is a technical standard compliance model, not a clinical "ground truth."

    8. The sample size for the training set

    • Not applicable. The device is a physical stimulator, not an AI/ML model that requires a training set of data.

    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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    K Number
    K222098
    Device Name
    ManaSport+
    Manufacturer
    Date Cleared
    2023-03-08

    (233 days)

    Product Code
    Regulation Number
    890.5300
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    ManaMed, Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Apply stationary use of ultrasound to:

    Generate deep heat within body tissues for the treatment of selected medical conditions such as the relief of muscle spasms, the treatment of joint contractures, and the local increase in circulation.

    Apply continuous movement of ultrasound for:

    1. Pain.
      1. Pain relief, muscle spasms, and joint contractures.
      1. Relief of pain, muscle spasms, and joint contractures that may be associated with:
    • · Adhesive capsulitis,
    • · Bursitis with slight calcification,
    • · Myositis,
    • · Soft tissue injuries, and
    • · Shortened tendons due to past injuries and scar tissues.
      1. Relief of pain, muscle spasms, and joint contractures resulting from:
    • · Capsular tightness, and
    • · Capsular scarring.
      1. Localized increase in blood flow.
      1. Increased range of motion of contracted joint using heat and stretch techniques.
    Device Description

    The ManaSport+ is an adaptation of the previously cleared ManaSport device, which was cleared under K210284. A wireless control option was added to the ManaSport+ and the subject device was evaluated for home use. As a portable and rechargeable prescriptive device in the home or clinical/hospital setting, the subject device is intended to apply ultrasound to the patient's treatment site for selected medical conditions such as the relief of pain, the relief of muscle spasms, the treatment of joint contractures, and the local increase in circulation. Ultrasound can be used to apply therapeutic deep heat for the treatment of selected medical conditions such as soft tissue injuries, shortened tendons due to past injuries and scar tissues, relief of pain, muscle spasms and joint contractures.

    AI/ML Overview

    The provided text is a 510(k) summary for the ManaSport+ device, an ultrasonic diathermy device. It discusses the device's substantial equivalence to predicate devices, focusing on its technical characteristics and indications for use. However, it explicitly states that "Clinical testing was not provided in support of this 510(k) application," and therefore, there is no study described that proves the device meets specific performance acceptance criteria via clinical data, nor is there information on ground truth establishment, expert consensus, or MRMC studies.

    The document primarily relies on non-clinical testing and comparison to predicate devices, demonstrating substantial equivalence rather than proving performance against quantified clinical acceptance criteria.

    Therefore, many of the requested details about acceptance criteria, the study proving the device meets them, sample sizes for test sets, data provenance, expert involvement, adjudication methods, MRMC studies, standalone performance, and ground truth establishment cannot be found in the provided text.

    The document focuses on demonstrating that the ManaSport+ is substantially equivalent to legally marketed predicate devices, meaning it is as safe and effective as those devices, and does not require a new Premarket Approval Application (PMA). This is achieved through non-clinical testing and a comparison of technical specifications.

    Here's what can be extracted based on the provided text, while noting the limitations:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not present a table of clinical performance acceptance criteria and reported device performance against those criteria. Instead, it provides a "Summary of Substantial Equivalence" comparing the ManaSport+ (Subject Device) to its primary predicate (ManaSport) and another predicate (sam 2.0 Long Duration Ultrasound System) based on various technical parameters. The "Equivalence" column in this table indicates if the subject device's parameter is identical, similar, or different, and explains why any differences do not affect safety or effectiveness.

    Below is a partial example of how the provided table could be structured to show the comparison, but it's crucial to understand these are technical specifications for substantial equivalence, not clinical performance metrics against acceptance criteria.

    Parameter & Predicate Device(s)Subject Device (ManaSport+) Reported ValuePrimary Predicate Device (ManaSport) Reported ValuePredicate Device (sam 2.0) Reported ValueEquivalence (as stated in document)
    Product CodeIMI, PFWIMI, PFWPFWIdentical
    Indications for Use(Detailed list provided in text)(Detailed list provided in text)(Detailed list provided in text)Identical
    Power Source(s)120/240 Vac with 5Vdc Input and rechargeable 3.7Vdc batteryNot Publicly Available120/240 VAC with 5V DC Input Power Jack and Lithium Battery PoweredIdentical
    Frequency (MHz)1.5Not Publicly Available3Identical or small. The frequency of the subject device is identical to that of the primary predicate device, and smaller than that of the predicate device. Therefore, the frequency does not affect the safety or effectiveness.
    Maximum Value of the Output Power (W ± 20%)0.60Not Publicly AvailableSingle Applicator: 0.65W ± 20% Dual Applicator: 1.3W ± 20%Identical or similar. Therefore, the maximum power does not affect the safety or effectiveness.
    Compliance with Voluntary Standards?Yes (lists IEC standards)Not Publicly AvailableYes (lists IEC standards)Identical
    Wireless Control via Bluetooth AppYesNot Publicly AvailableNoDifferent. Although the primary predicate and predicate devices do not have the wireless option, such a wireless option is optional to the subject device. Just like the primary predicate device, the subject device can be operated independently to realize all its features, and completely does not rely on the optional wireless communication to realize any of its features.

    2. Sample Sizes Used for the Test Set and Data Provenance

    • Sample Size for Test Set: Not applicable. The document states, "Clinical testing was not provided in support of this 510(k) application." The testing primarily involved non-clinical, bench testing to verify compliance with electrical safety, EMC, and biocompatibility standards, and software verification. There are no "test sets" in the context of clinical or AI performance evaluation.
    • Data Provenance: Not applicable for a clinical test set. The document refers to compliance with ISO and IEC standards, which are international standards.

    3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Experts

    • Not applicable. As no clinical testing was performed, no ground truth was established by experts for a test set.

    4. Adjudication Method for the Test Set

    • Not applicable. No clinical test set.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done

    • No, an MRMC study was not done. The document explicitly states "Clinical testing was not provided."

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

    • Not applicable. The ManaSport+ is a physical device (ultrasonic diathermy), not an AI algorithm. Its performance is related to its physical outputs (e.g., ultrasound frequency, power, temperature rise in tissue), which were evaluated through non-clinical bench testing for compliance with standards.

    7. The Type of Ground Truth Used

    • Not applicable for clinical ground truth. For the non-clinical tests, the "ground truth" refers to the established requirements and specifications of the cited voluntary standards (e.g., IEC 60601-1, ISO 10993) which the device's measured performance was compared against.

    8. The Sample Size for the Training Set

    • Not applicable. This is not an AI/algorithm device that requires a training set.

    9. How the Ground Truth for the Training Set was Established

    • Not applicable. No training set for an AI algorithm.

    Summary of Device Performance and Acceptance Criteria (Based on Non-Clinical Data):

    The ManaSport+ device demonstrated performance primarily through non-clinical tests to ensure compliance with recognized voluntary standards for medical devices. The "acceptance criteria" here are the requirements outlined in these standards for:

    • Electrical Safety: IEC 60601-1, IEC 60601-2-5 (for ultrasonic physiotherapy equipment)
    • Electromagnetic Compatibility (EMC): IEC 60601-1-2
    • Biocompatibility: ISO 10993-5 (cytotoxicity), ISO 10993-10 (irritation and skin sensitization)
    • Home Healthcare Environment Requirements: IEC 60601-1-11
    • Usability: IEC 60601-1-6
    • Software Verification: FDA Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices.

    The document asserts that the device conformed to or complied with these standards. For example, regarding temperature rise, it states "Meets IEC 60601-2-5, section 201.11 Protection against excessive temperature and other HAZARDS." Specific values for temperature rise in tissue are also given (e.g., "7.6°C at 1 cm / 3.3°C at 2 cm / 1.4°C at 3 cm / Max treatment time: 20 min"), and these are compared to the predicate devices as "Identical or similar. This value of the subject device is identical to that of the primary predicate device, and smaller than that of the predicate device. Therefore, it does not affect the safety or effectiveness."

    In conclusion, for the ManaSport+ device, its "acceptance criteria" were primarily defined by compliance with a comprehensive set of international electrical safety, EMC, biocompatibility, and usability standards, and its "performance" was demonstrated through non-clinical testing against these standards, as well as by showing substantial equivalence to existing cleared devices with similar indications for use. No clinical trial data was submitted or required for its 510(k) clearance.

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    K Number
    K210284
    Device Name
    ManaSport
    Manufacturer
    Date Cleared
    2022-04-26

    (448 days)

    Product Code
    Regulation Number
    890.5300
    Reference & Predicate Devices
    N/A
    Why did this record match?
    Applicant Name (Manufacturer) :

    ManaMed, Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Apply stationary use of ultrasound to:

    Generate deep heat within body tissues for the treatment of selected medical conditions such as the relief of muscle spasms, the treatment of joint contractures, and the local increase in circulation.

    Apply continuous movement of ultrasound for:

    1. Pain.
      1. Pain relief, muscle spasms, and joint contractures.
      1. Relief of pain, muscle spasms, and joint contractures that may be associated with:
    • · Adhesive capsulitis.
    • · Bursitis with slight calcification,
    • · Myositis,
    • · Soft tissue injuries, and
    • · Shortened tendons due to past injuries and scar tissues.
      1. Relief of pain, muscle spasms, and joint contractures resulting from:
    • · Capsular tightness, and
    • · Capsular scarring.
      1. Localized increase in blood flow.
      1. Increased range of motion of contracted joint using heat and stretch techniques.
    Device Description

    Not Found

    AI/ML Overview

    This is a medical device clearance letter for the ManaSport ultrasonic diathermy device. The provided text is not a clinical study report and does not contain the information requested about acceptance criteria, study design, or performance metrics for an AI/algorithm-based device.

    The document discusses the regulatory clearance process for a traditional medical device (ultrasonic diathermy) under a 510(k) submission, confirming its substantial equivalence to previously marketed devices. It outlines general regulatory requirements and lists the device's indications for use.

    Therefore, I cannot provide the requested information, such as:

    1. Table of acceptance criteria and reported device performance: This information is not present.
    2. Sample size for test set and data provenance: Not applicable to this type of regulatory document.
    3. Number of experts and qualifications for ground truth: Not applicable.
    4. Adjudication method: Not applicable.
    5. MRMC comparative effectiveness study or effect size: This is not an AI-assisted device, so this is not relevant.
    6. Standalone (algorithm only) performance: This device is not an algorithm.
    7. Type of ground truth used: Not applicable.
    8. Sample size for training set: Not applicable.
    9. How ground truth for training set was established: Not applicable.

    The document focuses on the regulatory clearance of a physical device, not the performance evaluation of an AI algorithm.

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    K Number
    K211253
    Device Name
    PlasmaWave
    Manufacturer
    Date Cleared
    2021-05-26

    (30 days)

    Product Code
    Regulation Number
    870.5800
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    ManaMed, Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The PlasmaWave is intended to be an easy to use portable system, prescribed by a physician, for use in the home or clinical setting to help prevent the onset of DVT in patients blood flow in the extremities (stimulating muscle contractions). This device can be used to:

    • · Aid in the prevention of DVT;
    • · Enhance blood circulation:
    • · Diminish post-operative pain and swelling;
    • · Reduce wound healing time;
    • Aid in the treatment and healing of stasis dermatitis, venous stasis ulcers, arterial and diabetic leg ulcers, chronic venous insufficiency and reduction of edema in the lower limbs.
      The unit can also be used as an aid in the prophylaxis for DVT by persons expecting to be stationary for long periods of time.
    Device Description

    The PlasmaWave is a lightweight, portable, rechargeable battery powered prescriptive device. It is intended to be used in the home or clinical setting by or under the direction of a medical professional to help stimulate blood flow as an aid in the prevention of deep vein thrombosis (DVT).
    The PlasmaWave utilizes pneumatically controlled, single-chamber wraps actuated by an electronically controlled unit of the air pump and solenoid valve via the tubing. All pump, battery and control components are protectively housed in a plastic case that is connected to a single use inflatable wrap via tubing. A Power On/Off button, a Mode (M) button, a Leg button, three LED indicators (Working, Charging, and Warming), and a LCD display provide user interface. There are also two tubing ports for connecting the tubing and a charging port for connecting the battery charger/AC adapter at the bottom of the control unit.

    AI/ML Overview

    The provided text does not contain detailed information about a study proving the device meets acceptance criteria. Instead, it describes a 510(k) premarket notification for the "PlasmaWave" device, asserting its substantial equivalence to predicate devices (PlasmaFlow and Cirona 6200 Deep Vein Thrombosis Prevention System).

    Therefore, I cannot provide all the requested information. However, I can extract what is available regarding acceptance criteria and the methods used to demonstrate substantial equivalence.

    Here's a summary based on the provided text:

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

    The document presents a comparison table (Table 1) between the subject device (PlasmaWave) and two predicate devices (PlasmaFlow, K160318; Cirona 6200, K141578) to demonstrate substantial equivalence. It implies that the "acceptance criteria" are met if the subject device is either identical or sufficiently similar to the predicate devices without raising new issues of safety or effectiveness.

    Feature / CriteriaSubject Device (PlasmaWave)Primary Predicate Device (PlasmaFlow, K160318)Predicate Device (Cirona 6200, K141578)Equivalence / Performance Statement
    Intended UseAid in prevention of DVT; Enhance blood circulation; Diminish post-operative pain and swelling; Reduce wound healing time; Aid in treatment and healing of stasis dermatitis, venous stasis ulcers, arterial and diabetic leg ulcers, chronic venous insufficiency and reduction of edema in lower limbs. Aid in DVT prophylaxis for stationary persons.(Identical statement as Subject Device)Preventatively to increase venous blood flow in patients at risk of DVT.Identical (to PlasmaFlow); Similar (to Cirona 6200)
    Prescription or OTCPrescriptionPrescriptionPrescriptionIdentical
    Power Source(s)Rechargeable batteryRechargeable batteryRechargeable batteryIdentical
    Battery Specifications3.7V rechargeable battery3.7V rechargeable battery10.8V rechargeable batteryIdentical or similar. Voltage difference will not raise any new safety/effectiveness issue.
    Battery Charge Time~4 hours (from depleted)~4 hours (from depleted)~5 hours (from depleted)Identical or similar. Charging time difference does not change product performance/parameters, will not raise new safety/effectiveness issue.
    Power SupplyInput: 100-240 Vac, 50-60 Hz; Output: 12 Vdc @ 2 AInput: 100-240 Vac, 50-60 Hz; Output: 5 Vdc @ 1 AInput: 100-240 Vac, 50-60 Hz; Output: 14 Vdc @ 2 ASimilar. Voltage difference does not change product performance/parameters, will not raise new safety/effectiveness issue.
    Internal Recharg. Batt.YesYesYesIdentical
    Compliance Std.YesYesYesIdentical
    Safety (Elec, Mech, Chem, Therm, Rad)YesYesYesIdentical
    Functions and designAids venous return by cyclic, intermittent, pneumatic pressure application (inflation followed by deflation) to compress lower extremities.(Identical statement as Subject Device)(Identical statement as Subject Device)Identical
    Contraindication(s)Persons with suspected, active or untreated DVT, ischemic vascular disease, severe arteriosclerosis, pulmonary edema, severe congestive heart failure, thrombophlebitis, active infection. On legs where cuffs interfere with: vein ligation, gangrene, dermatitis, open wounds, recent skin graft, massive edema, extreme deformity. On any neuropathy. On insensitive extremities. Where increased venous or lymphatic return is undesirable.(Identical statement as Subject Device)Severe atherosclerosis or other ischemic vascular diseases, suspected/known acute DVT, severe CHF, existing pulmonary edema/embolisms, extreme limb deformity. Local skin/tissue condition where garments interfere: gangrene, untreated/infected wounds, recent skin graft, dermatitis, known malignancy in legs, limb infections (cellulitis) without antibiotic coverage, lymphangiosarcoma.Identical (to PlasmaFlow); Similar (to Cirona 6200)
    Target PopulationPatients who need venous return.Patients who need venous return.Patients who need venous return.Identical
    Where UsedHome, Hospital, Surgery Center, Altitude travel, areas of limited mobility.Home, Hospital, Surgery Center, Altitude travel, areas of limited mobility.Home, Hospital, Surgery Center, Altitude travel, areas of limited mobility.Identical
    ApplicationNon-invasive / externalNon-invasive / externalNon-invasive / externalIdentical
    PortabilityPortable, ambulantPortable, ambulantPortable, ambulantIdentical
    Basis of operationAids venous return by cyclic, intermittent, pneumatic pressure application (inflation followed by deflation) to compress lower extremities.(Identical statement as Subject Device)(Identical statement as Subject Device)Identical
    Anatomical SiteLower extremitiesLower extremitiesLower extremitiesIdentical
    System managementElectronic, microprocessor controlledElectronic, microprocessor controlledElectronic, microprocessor controlledIdentical
    Pressure SourceMicro pump controlled by electronic processorMicro pump controlled by electronic processorMicro pump controlled by electronic processorIdentical
    Operating ModeContinuous OperationContinuous OperationContinuous OperationIdentical
    Working PressurePreset at 55 mmHgPreset at 55 mmHgPreset at 40 mmHgIdentical (to PlasmaFlow); Similar (to Cirona 6200). Will not raise new safety/effectiveness issue.
    Cycle TimeApproximately 60 secondsApproximately 60 secondsApproximately 60 secondsIdentical
    System diagnosticsAudible and visual alarms prompt recognition of system faultsAudible and visual alarms prompt recognition of system faultsAudible and visual alarms prompt recognition of system faultsIdentical
    Air delivery from pump to cuff bladderVia flexible plastic tube(s) connected to the air bladder.Via flexible plastic tube(s) connected to the air bladder.Via flexible plastic tube(s) connected to the air bladder.Identical
    SterilityClean / non-sterileClean / non-sterileClean / non-sterileIdentical
    Leg cuff usageSingle Patient UseSingle Patient UseSingle Patient UseIdentical
    Material UsedSingle air bladder encased in soft, nonlatex, non-woven medical fabric or equivalent, for comfort and biocompatibility.(Identical statement as Subject Device)(Identical statement as Subject Device)Identical
    BiocompatibilityBiocompatibleBiocompatibleBiocompatibleIdentical. No issue or concern of biocompatibility due to identical materials/formulation.
    SoftwareModerateModerateModerateIdentical
    Dimensions220x70x48.5 mm116x65x19 mm110x180x270 mmDifferent. Difference in dimensions does not change product performance/parameters, will not raise new safety/effectiveness issue.
    WeightApprox. 0.38kg0.23kg2.3kgDifferent. Difference in weight does not change product performance/parameters, will not raise new safety/effectiveness issue.
    Temperature+10 °C (50 °F) to +40 °C (104 °F)+10 °C (50 °F) to +40 °C (104 °F)+5 °C (41 °F) to +40 °C (104 °F)Identical or similar
    Humidity30%-75%30%-75%15%-93%Identical or similar

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

    The document does not describe a clinical "test set" in the sense of patient data used for evaluating the device's clinical performance. The evaluation is based on a comparison to predicate devices and non-clinical bench tests.

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

    Not applicable. There is no mention of experts establishing ground truth for a clinical test set.

    4. Adjudication method for the test set

    Not applicable. There is no clinical test set 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

    Not applicable. The device is a pneumatic compression pump, not an AI-assisted diagnostic or imaging device. There is no mention of human readers or AI assistance.

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

    Not applicable. This is not an algorithm-only device. The submission relies on demonstrating substantial equivalence to a mechanically similar predicate device.

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

    For the purpose of the 510(k) submission, the "ground truth" for "acceptability" is implicitly established by the legally marketed predicate devices. The subject device is deemed acceptable if it can demonstrate substantial equivalence to these predicates without raising new questions of safety or effectiveness. This is supported by:

    • Comparison of technical characteristics: Detailed feature-by-feature comparison.
    • Compliance with voluntary standards: Adherence to established safety and electromagnetic compatibility standards (ANSI AAMI ES60601-1, IEC 60601-1-2).
    • Bench tests: Verification of physical, electrical, and performance requirements.
    • Software verification: According to FDA guidelines.

    8. The sample size for the training set

    Not applicable. This device does not involve machine learning or AI that would require a "training set."

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

    Not applicable. No training set is mentioned.

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    K Number
    K200353
    Device Name
    ManaFlow
    Manufacturer
    Date Cleared
    2020-08-06

    (175 days)

    Product Code
    Regulation Number
    870.5800
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    ManaMed, Inc

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The ManaFlow system, part numbers MFLOW51 and MFLOW52, is comprised of a gradient compression sleeve and a portable intermittent pump to provide graduated compression in both sustained and intermittent settings for use in both the hospital and outpatient setting. ManaFlow 51 is pre-set to the default setting of 50 mmHg and cannot be adjusted, whereas the ManaFlow 52 can be adjusted by the physician to a pressure within the specified range. It is intended for use in:

    • · Treatment of lymphedema
    • · Treatment of chronic venous insufficiency
    • · Treatment and promotion of healing of stasis dermatitis and venous stasis ulcers
    • · Reducing venous leg ulcer healing time
    • · Reducing edema due to venous stasis
    • Enhancing venous return
      The device is intended for home, and hospital use.
    Device Description

    The ManaFlow system, part numbers MFLOW51 and MFLOW52, is a portable and rechargeable prescriptive device. It is intended to be used in the home or clinical/hospital setting by or under the direction of a medical professional to apply pressure to treat lymphedema and other edematous conditions and to prevent Deep Vein Thrombosis (DVT).
    The ManaFlow, supplied clean and non-sterile, utilizes the pneumatically controlled cuff actuated by an electronically controlled air pump unit. All pump, battery and control components are protectively housed in a plastic case of the control unit that is attached to an inflatable cuff/sleeve. An ON/OFF button, a SET button, and a display provide for user interface. There is also a port for connecting the battery charger/AC adapter plug. The cuff component consists of multiple (four or so) air chambers/bladders encased inside a soft medical fabric or equivalent medical for increased patient comfort and biocompatibility compliance.
    In operation, the user simply turns the power on via the ON/OFF button. A cuff containing air chambers/bladders is connected to the control unit. And the control unit then inflates the cuff to the default pre-determined pressure (50 mmHg), which could be adjusted/calibrated via the SET button. The cuff pressure is monitored by an internal pressure switch and system software. Once the cuff pressure of the multiple air chambers/bladders reaches the pre-determined or adjusted level, the pump is turned OFF for a rest period, and the cuff deflates to ambient pressure through a valve inside the plastic case. After the rest period, the cycle of inflation and deflation repeats until the device is turned off.

    AI/ML Overview

    The provided text is a 510(k) summary for the ManaFlow device, a compressible limb sleeve system. It primarily focuses on demonstrating substantial equivalence to predicate devices rather than proving the device meets specific performance acceptance criteria through clinical studies. Therefore, much of the requested information regarding "acceptance criteria and the study that proves the device meets the acceptance criteria" in terms of clinical performance (e.g., sample size for test set, number of experts for ground truth, MRMC studies, effect size, standalone performance, type of ground truth) is not present in this document.

    The document describes non-clinical tests performed to validate the design and assure conformance with voluntary design standards related to electrical safety and electromagnetic compatibility, as well as bench tests for physical, electrical, and performance requirements, and software verification. However, it does not provide specific performance metrics or acceptance criteria for those tests.

    Here's what can be extracted based on the provided text, and where information is missing:


    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not present specific acceptance criteria for clinical performance or detailed quantitative results from those tests. Instead, it relies on demonstrating substantial equivalence to predicate devices based on intended use, indications for use, functions, design, and adherence to electrical safety and EMC standards.

    The closest to a "table of performance" is the comparison table (Table 1) which highlights identical or similar characteristics between the ManaFlow device and its predicates. This table, however, is for comparison of features and design principles, not for reporting quantitative performance against defined acceptance criteria.

    Feature / CharacteristicAcceptance Criteria (Implied by Substantial Equivalence to Predicates)Reported ManaFlow Performance / Characteristic
    Intended UseIdentical to Predicate Devices (ACTitouch™, PlasmaFlow, medi pcs-brio, SC-3004FC-DL)Identical. For treatment of lymphedema, chronic venous insufficiency, stasis dermatitis, venous stasis ulcers, reducing ulcer healing time, reducing edema, enhancing venous return.
    Functions and DesignAids venous return by cyclic, intermittent, pneumatic pressure application (inflation followed by deflation) to compress extremities.Identical. Aids venous return by using cyclic, intermittent, pneumatic pressure application (inflation followed by deflation) to compress the extremities.
    ContraindicationsSimilar to Predicate Devices (specific conditions listed in Table 1)Identical or similar to various predicates. Must NOT be used in active DVT, ischemic vascular disease, severe arteriosclerosis, pulmonary edema, severe CHF, thrombophlebitis, active infection, or where cuffs interfere with vein ligation, gangrene, dermatitis, open wounds, recent skin graft, massive edema, or extreme leg deformity.
    Target PopulationPatients who need venous return and lymphedema treatment.Identical. Patients who need venous return and lymphedema treatment.
    Where UsedHome, Hospital, Surgery Center, Altitude travel, areas of limited mobility.Identical. Home, Hospital, Surgery Center, Altitude travel, areas of limited mobility.
    ApplicationNon-invasive / external.Identical. Non-invasive / external.
    PortabilityPortable, ambulant.Identical. Portable, ambulant.
    Pressure SourceMicro pump controlled by microprocessor.Identical. Micro pump controlled by microprocessor.
    Operating ModesPreset and adjustable modes.Identical. Preset and adjustable modes. (ManaFlow 51: 50 mmHg fixed; ManaFlow 52: adjustable 20-80 mmHg)
    Working PressureAdjustable range similar to predicates (e.g., ACTitouch 20-50 mmHg, medi pcs-brio 20-80 mmHg, SC-3004FC-DL 30-120 mmHg).Preset at 50 mmHg and adjustable from 20-80 mmHg. (Identical or similar to predicates)
    Cycle TimeCyclic inflation/deflation sequences, similar to predicates.Identical or similar descriptions to predicates. Specifics detailed for 50mmHg mode and adjustable modes (sequential inflation, then deflation of all chambers).
    System DiagnosticsAudible and visual alarms for system faults.Identical. Audible and visual alarms prompt recognition of system faults.
    Air DeliveryVia flexible plastic tube(s) connected directly to air bladder.Identical. Via flexible plastic tube(s) connected directly to the air bladder.
    SterilityClean / non-sterile.Identical. Clean / non-sterile.
    Leg cuff usageSingle Patient Use.Identical. Single Patient Use.
    BiocompatibilityBiocompatible materials.Identical. Biocompatible. Materials are identical to those of legally marketed devices K160318 and K142640.
    SoftwareModerate level of concern.Identical. Moderate.
    Electrical SafetyConformance to ANSI AAMI ES60601-1 and IEC 60601-1-2.Conforms. Non-clinical tests were performed.
    EMCConformance to IEC 60601-1-2.Conforms. Non-clinical tests were performed.
    Physical RequirementsDemonstrated conformance through bench tests.Bench tests performed.
    Electrical RequirementsDemonstrated conformance through bench tests.Bench tests performed.
    Performance RequirementsDemonstrated conformance through bench tests.Bench tests performed.
    Software VerificationPerformed according to FDA Guidance.Verification performed.

    Regarding Clinical Study Details (information missing from this 510(k) summary):

    1. Sample sizes used for the test set and the data provenance: This document does not describe any clinical test set using patient data. The tests mentioned are non-clinical (bench tests, electrical safety, EMC).
    2. 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 using expert opinion for ground truth is described.
    3. Adjudication method for the test set: Not applicable, as no clinical test set requiring adjudication is described.
    4. 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 medical device (compressible limb sleeve and pump), not an AI/imaging diagnostic device that would typically undergo MRMC studies.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable. This is not an algorithm-only device.
    6. The type of ground truth used: For the non-clinical tests and substantial equivalence determination, the "ground truth" is largely defined by established engineering and safety standards (e.g., ANSI AAMI ES60601-1, IEC 60601-1-2) and the performance characteristics of predicate devices. There is no mention of clinical ground truth (e.g., pathology, outcomes data).
    7. The sample size for the training set: Not applicable, as this is not a machine learning device requiring a training set in the AI sense.
    8. How the ground truth for the training set was established: Not applicable.

    Summary of available information related to "proof":

    The document demonstrates that the ManaFlow device meets the requirements for 510(k) clearance by proving substantial equivalence to legally marketed predicate devices. This is achieved by:

    • Showing identical intended use and indications for use.
    • Comparing design features and specifications: Table 1 meticulously compares ManaFlow's characteristics (e.g., operating principles, contraindications, target population, portability, pressure source, operating modes, working pressure, cycle time, alarms, sterility, materials) to its four predicate devices, highlighting they are identical or similar, and arguing that any differences do not raise new safety or effectiveness concerns.
    • Conducting non-clinical tests:
      • Electrical Safety: Conformance to ANSI AAMI ES60601-1 standards.
      • Electromagnetic Compatibility (EMC): Conformance to IEC 60601-1-2 standards.
      • Bench Tests: Performed for physical requirements, electrical requirements, and performance requirements. (Specific results or acceptance criteria for these bench tests are not detailed in this summary).
      • Software Verification: Carried out according to FDA guidance for software in medical devices.
    • Biocompatibility: Stated that skin contact components are identical to those of previously cleared devices (K160318 and K142640), thus confirming biocompatibility without new concerns.

    The core of the "proof" is that the ManaFlow device functions fundamentally the same way, has the same intended use, and has passed the necessary engineering and safety tests as similar devices already on the market, thereby establishing it as "substantially equivalent" rather than requiring a de novo clinical trial to prove a new performance claim.

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    K Number
    K200351
    Device Name
    PlasmaFlight
    Manufacturer
    Date Cleared
    2020-08-05

    (175 days)

    Product Code
    Regulation Number
    890.5650
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    ManaMed, Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The PlasmaFlight is intended to be an over-the-counter portable inflatable tube massage system which simulates kneading and stroking of tissue with the hands by use of inflatable pressure cuffs. This device can be used to:

    • Temporarily increase blood circulation in the treated areas;
    • Temporary relief of minor muscle aches and pains.
    Device Description

    The PlasmaFlight is a portable and rechargeable device. It is intended to be an over-the-counter portable inflatable tube massage system which simulates kneading and stroking of tissue with the hands by use of inflatable pressure cuffs. It can be used to temporarily increase blood circulation and temporarily relieve minor muscle aches and pains.
    The PlasmaFlight, supplied clean and non-sterile, utilizes the pneumatically controlled air bladder cuff actuated by an electronically controlled air pump unit. All pump, battery and control components are protectively housed in a plastic case of the control unit that is permanently attached to an inflatable cuff. An ON/OFF button and LED indicators/displays provide for user interface. There is also a port for connecting the battery charger/AC adapter plug. The cuff component consists of an air bladder encased inside a soft medical fabric or equivalent medical material for increased patient comfort and biocompatibility compliance.
    In operation, the user simply turns the power on via the ON/OFF button. A cuff containing the air bladder is permanently connected to the control unit. And the control unit then inflates the cuff to the default predetermined pressure (55 mmHg). The cuff pressure is monitored by an internal pressure switch and system software. Once the cuff pressure of the air bladder reaches the proper level, the pump is turned off for a rest period, and the cuff deflates to the ambient pressure through a valve inside the plastic case. After the rest period, the cycle of inflation and deflation repeats until the unit is turned off.

    AI/ML Overview

    The provided text describes the 510(k) summary for the device "PlasmaFlight," a portable inflatable tube massager. The submission focuses on demonstrating substantial equivalence to a predicate device, primarily through comparison of technical characteristics and compliance with voluntary standards, rather than extensive clinical efficacy studies with specific acceptance criteria and detailed performance claims.

    Therefore, many of the requested details about acceptance criteria, specific performance metrics, sample sizes for test/training sets, expert involvement for ground truth, and MRMC studies are not present in this document. The document's purpose is to show equivalence and safety/effectiveness via design and performance testing against standards, not to prove clinical performance against new acceptance criteria.

    However, I can extract information related to the device's technical specifications and the non-clinical testing performed to establish its safety and effectiveness relative to the predicate device.

    Here's an attempt to answer your questions based on the provided text, indicating "Not explicitly stated" where the information is not available in the document:


    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not present a table of specific acceptance criteria for clinical performance or a reported device performance in terms of efficacy metrics (e.g., specific percentage increase in blood circulation, or reduction in pain levels). Instead, it focuses on demonstrating that the PlasmaFlight's specifications and functions are "Identical or similar" to the predicate device, thereby showing "Substantial Equivalence".

    The "acceptance criteria" for this submission would implicitly be that the device's characteristics and performance, as demonstrated through non-clinical tests and comparison, do not raise new questions of safety or effectiveness compared to the predicate device.

    Here's a table summarizing the comparisons (which serve as the basis for "acceptance" in a substantial equivalence claim):

    Characteristic / "Acceptance Criteria" (via Equivalence)Subject Device (PlasmaFlight) SpecificationPrimary Predicate Device (PowerPlay Muscle Massager) SpecificationEquivalence Status
    Intended Use"Temporarily increase blood circulation in the treated areas; Temporary relief of minor muscle aches and pains.""Temporarily increase blood circulation in the treated areas; Temporary relief of minor muscle aches and pains."Identical
    Prescription or OTCOTCOTCIdentical
    Power Source(s)5V DC power supply (100-240 VAC input) and 3.7V rechargeable batteryNot publicly availableIdentical or similar. "The voltage difference of power supply used does not change the product performance or parameters, which does not raise any new issue of the safety or effectiveness."
    Battery Charge TimeApprox. 2-5 hoursNot publicly availableIdentical or similar. "The difference of charging time does not change the product performance or parameters, which does not raise any new issue of the safety or effectiveness."
    Internal rechargeable batteriesYesYesIdentical
    Compliance with Voluntary StandardsYes (ANSI AAMI ES60601-1, IEC 60601-1-2)YesIdentical (for listed types: Electrical Safety, Mechanical Safety, etc.)
    Functions and DesignSimulates kneading and stroking of tissue with the hands by use of inflatable pressure cuffs.Simulates kneading and stroking of tissue with the hands by use of inflatable pressure cuffs.Identical to the Primary Predicate Device
    ContraindicationsIdentical to primary predicateSuspected, active or untreated: Neuropathy, deep vein thrombosis, ischemic vascular disease, severe arteriosclerosis, pulmonary edema, congestive heart failure, thrombophlebitis or an active infection. On a leg where wraps would interfere with conditions (vein ligation, gangrene, dermatitis, open wounds, etc.), insensitive to pain, where increased circulation is undesirable.Identical
    Target Population / Intended UsersUsers who need temporary increase of blood circulation in the treated area and temporary relief of minor muscular aches and pains.Users who need temporary increase of blood circulation in the treated area and temporary relief of minor muscular aches and pains.Identical to the Primary Predicate Device
    Where UsedHome, Altitude travel, areas of limited mobilityHome, Altitude travel, areas of limited mobilityIdentical to the Primary Predicate Device
    ApplicationNon-invasive / externalNon-invasive / externalIdentical
    PortabilityPortable, ambulantPortable, ambulantIdentical
    Basis of OperationUsing cyclic, intermittent, pneumatic pressure application (inflation followed by deflation) to compress the extremities.Using cyclic, intermittent, pneumatic pressure application (inflation followed by deflation) to compress the extremities.Identical
    Anatomical Site / Location of Treatment ApplicationLower limb(s) (Calf)Calf, ankle, knee, hip or shoulderIdentical on the calf
    System ManagementMicroprocessorMicroprocessorIdentical
    Pressure SourceMicro pump controlled by microprocessorMicro pump controlled by microprocessorIdentical
    Operating ModesTwo preset modes of 55mmHgNot publicly availableIdentical or similar. "The subject device has the compression pressure within the range of the primary predicate device, which does not raise any new issue of the safety or effectiveness."
    Working PressurePreset at approximately 55 mmHgAdjusted at 30 - 70 mmHgIdentical or similar. "The subject device has the compression pressure within the range of the primary predicate device, which does not raise any new issue of the safety or effectiveness."
    Cycle TimeApprox. 60 seconds/leg (inflation + rest, deflation)Approx. 30 - 60 seconds/leg (inflation + rest, deflation)Identical or similar. "The subject device has the cycle time within the range of the primary predicate device, which does not raise any new issue of the safety or effectiveness."
    System DiagnosticsAudible and visual alarms prompt recognition of system faultsVisual alarms prompt recognition of system faultsIdentical (implies the subject device meets or exceeds the predicate's fault recognition)
    Air delivery from pump to cuff bladderVia flexible plastic tube(s) connected directly to the air bladderVia flexible plastic tube(s) connected directly to the air bladderIdentical
    SterilityClean / non-sterileClean / non-sterileIdentical
    Leg cuff usageSingle Patient UseSingle Patient UseIdentical
    Material UsedAir bladder chambers encased in a covering of soft and nonlatex medical fabric or equivalent medical material for increased patient comfort and biocompatibility compliance.Air bladder chambers encased in a covering of soft and nonlatex medical fabric or equivalent medical material for increased patient comfort and biocompatibility compliance.Identical or similar
    BiocompatibilityBiocompatibleBiocompatibleIdentical
    SoftwareModerateModerateIdentical
    Dimensions116x65x19mmNot publicly availableIdentical of similar. "The difference of dimensions does not raise any new issue of safety or effectiveness"
    WeightApprox. 0.23kgNot publicly availableIdentical or similar. "The difference of weight does not raise any new issue of safety or effectiveness"
    Temperature+10 °C (50 °F) to +40 °C (104 °F)Not publicly availableIdentical
    Humidity30%-75%Not publicly availableIdentical
    Cleaning and DisinfectingSpecified cleaning instructions (soft cloth, soapy water/70% isopropyl alcohol, air dry)Not publicly availableIdentical or similar (compared to the PlasmaFlow, K160318)
    DisposalInstructions for electromechanical device disposal including circuit boards and rechargeable batteries; not in landfill, contact local recycle center or ManaMed, Inc.Not publicly availableIdentical or similar (compared to the PlasmaFlow, K160318)

    2. Sample Size Used for the Test Set and Data Provenance

    • Sample Size for Test Set: Not explicitly stated. The submission relies on "Non-Clinical Tests" (bench tests) and comparison to the predicate device, not a specific clinical test set involving human subjects to evaluate new performance metrics.
    • Data Provenance: Not applicable for clinical data. The "tests" mentioned are non-clinical (bench tests) and compliance with standards.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts

    • Not applicable. This is a 510(k) submission for a physical therapy device demonstrating substantial equivalence, not an AI/imaging device requiring expert ground truth for diagnostic accuracy.

    4. Adjudication Method for the Test Set

    • Not applicable. There is no clinical test set requiring adjudication in this document.

    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

    • No. This is not an AI/imaging device, and no MRMC study was conducted or is relevant for this type of submission.

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

    • Not applicable. This is a physical therapy device, not an algorithm.

    7. The Type of Ground Truth Used

    • The "ground truth," in the context of this submission, is effectively the established safety and effectiveness profile of the legally marketed predicate device and compliance with recognized voluntary standards for medical device safety and performance. There is no "ground truth" derived from expert consensus, pathology, or outcomes data for new clinical claims.

    8. The Sample Size for the Training Set

    • Not applicable. This is not a machine learning/AI device that requires a training set.

    9. How the Ground Truth for the Training Set Was Established

    • Not applicable. This is not a machine learning/AI device, so there is no training set or associated ground truth.

    Summary of the Study Proving Substantial Equivalence:

    The study proving the device meets the "acceptance criteria" (defined as substantial equivalence to the predicate) is primarily a comparative analysis of technical characteristics and non-clinical bench testing.

    • Non-Clinical Tests Performed:

      • Design Validation and Conformance with Voluntary Standards:
        • ANSI AAMI ES60601-1 "Medical Electrical Equipment Part 1: General requirements for basic safety and essential performance (IEC 60601-1)" - for electrical safety.
        • IEC 60601-1-2 "Medical Electrical Equipment Part 1-2: General Requirements for Basic Safety and Essential Performance - Collateral standard: Electromagnetic Compatibility - Requirements and Tests" - for electromagnetic compatibility.
      • Bench Tests: Performed on physical requirements, electrical requirements, and performance requirements.
      • Software Verification: Carried out according to the FDA Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices (as the device uses a microprocessor).
    • Conclusion: The tests and comparison performed demonstrate that the PlasmaFlight is substantially equivalent to the predicate device, implying it is as safe and effective as the legally marketed predicate device. The minor differences noted (e.g., in power supply details, charging time, dimensions, weight, operating modes, working pressure, cycle time, cleaning, disposal) were deemed not to raise any new issues of safety or effectiveness.

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    K Number
    K160318
    Device Name
    PlasmaFlow
    Manufacturer
    Date Cleared
    2016-04-01

    (56 days)

    Product Code
    Regulation Number
    870.5800
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    MANAMED, INC

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The PlasmaFlow, model PF0001, is intended to be an easy to use portable system, prescribed by a physician, for use in the home or clinical setting to help prevent the onset of DVT in patients by stimulating blood flow in the extremities (simulating muscle contractions). This device can be used to:

    • · Aid in the prevention of DVT;
    • · Enhance blood circulation;
    • · Diminish post-operative pain and swelling;
    • · Reduce wound healing time;
    • Aid in the treatment and healing of: stasis dermatitis, venous stasis ulcers, arterial and diabetic leg ulcers, chronic venous insufficiency and reduction of edema in the lower limbs.
      The unit can also be used as an aid in the prophylaxis for DVT by persons expecting to be stationary for long periods of time.
    Device Description

    The PlasmaFlow is an ambulatory, portable, light weight, prescriptive intermittent pneumatic compression system intended to provide sequential compression therapy to a patient's lower limbs. All pump control unit components are protectively enclosed in a plastic casing which is fixated to a single chamber cuff. The unit is supplied with a nonserviceable, rechargeable battery, to allow user portability, and a power supply transformer for main connection.

    The PlasmaFlow is an ambulatory, portable, light weight, prescriptive device intermittent pneumatic compression system intended to provide sequential compression therapy to a patient's lower limbs. The housing on the garment is a lightweight, rechargeable battery-powered, electromechanical control unit intended to provide and digitally monitor through two LED screens the inflation cycle for enhanced circulation therapy. The controller on the sleeve allows the unit to inflate distal to proximal. It is intended to be used in the home, travel situations where altitude or lack of mobility occurs, or clinical setting by or under the direction of a medical professional to help stimulate blood flow as an aid in the prevention of deep vein thrombosis (DVT).

    All pump control unit components are protectively enclosed in a plastic casing which is fixated to a single chamber cuff. The unit is supplied with a non-serviceable, rechargeable battery, to allow user portability, and a power supply transformer for main connection. The pump has two LED screens. The screen allows the prescriber and or patient to verify the pressure, the mode, and total run time.

    The Patient Sleeve is a single Polyvinyl Chloride (PVC) air bladder intended to be attached directly to the patient's lower limb. It is intended to provide compression action to the tissue surrounding the venous vasculature in the calf of a patient. A compression unit with two LED screens is connected to sleeve for a completely ambulatory system. The compression unit has the ability to produce different compression modalities.

    Default modality will be the same as the predicated devices, which is, a slow inflation up to 55 mmHg of air through the bladder cells. Once pressure is reached, the unit will deflate for approximately 50 seconds. Then the cycle repeats.

    Another compression modality will be the step up technology that inflates the air cells at an increase of 10 mmHg pausing at increments of ten to 50 mmHg, with a final increase of 5 mmHg to 55mmHg. Once 55 mmHg is reached, the unit will decrease to 50 mmHg and then decrease in increments of 10 mmHg.

    A single touch control switch located on the top of the unit powers on the unit and switches the mode.

    Above the power button, a dual color LED light allows the user to verify for power on, low battery, charging and charge completed indication, and an audible alarm (for indicating a leak or low pressure alarm) provides for user interface. There is also a port for connecting the battery charger/AC adapter plug/USB chord.

    The leg wrap (cuff) component consists of a Polyvinyl Chloride (PVC) air bladder encased inside a soft, non-woven medical fabric made from a Polyester blended medical fabric or equal, which is adhered to the PVC air bladder. The units are supplied clean, non-sterile, packaged in pairs.

    In operation, the user simply runs the power ON via the multi-purpose control button. A single user "cuff containing air bladders is connected to the unit. The control unit then fills the cuff to a pressure of 55 mmHg. Cuff pressure is visually monitored by user pressure LED screen, internal pressure switch, and system software. Once the pressure reaches the proper level, the pump is deflated for an approximately 50 second deflate period. The device software ensures the cycle time is a minimum of 60 seconds (the cycle time is the length of time for one complete cycle on one cuff including fill time, exhaust, and relaxation time). The cycle repeats until the unit is turned off.

    AI/ML Overview

    This document is a 510(k) Premarket Notification for the PlasmaFlow device, which is an intermittent pneumatic compression system intended for preventing Deep Vein Thrombosis (DVT) and improving blood circulation. The submission argues for substantial equivalence to a predicate device, the Innovamed Health Venapro (K133274).

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


    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly present a table of "acceptance criteria" in the format of specific thresholds for device performance metrics. Instead, it argues for substantial equivalence by comparing the PlasmaFlow (subject device) with the Venapro (predicate device) across various characteristics and showing that they are either identical or that any differences do not raise new questions of safety or effectiveness.

    However, based on the non-clinical testing performed, we can infer some performance aspects:

    Acceptance Criteria (Inferred from Predicate Equivalence)PlasmaFlow Reported Performance
    Device ClassificationCompressible Limb Sleeve, 21 CFR 870.5800
    FDA Product CodeJOW
    FunctionAids venous return by using cyclic, intermittent, pneumatic pressure application (inflation followed by deflation) to compress the lower limb(s).
    Working PressureMode one and Mode two are preset at 55 mmHg. (Predicate: 50 mmHg)
    Cycle Time60 seconds
    System DiagnosticsAudible and visual alarms prompt recognition of system faults.
    Battery Specifications7.4 volt Li-ion battery pack rechargeable (made of 2 x 3.7 volt cells).
    SterilityClean / non-sterile
    Leg Cuff UsageSingle Patient Use
    BiocompatibilityMust pass Cytotoxicity, Sensitization, and Irritation tests according to ISO 10993-1, -5, -10, -12, and USP 35.
    Electrical Safety & EMCMust conform to IEC 60601-1, AAMI ES 60601-1, IEC 60601-1-2, IEC 60601-1-11, IEC 60601-1-6, IEC 62366.
    SoftwareSoftware verification and validation conducted; considered "moderate" level of concern.
    Risk ManagementMust conform to ISO14971, IEC 60812, ISO 13485.
    Performance (Bench Testing)Equivalent pressure delivery, cuff (bladder) fill time, cycle time and overall system performance as the predicate devices listed.
    Leak Burst PressureResults of outside testing of pressure, leak, and burst should be similar to predicates.

    2. Sample Size Used for the Test Set and Data Provenance

    The submission explicitly states: "No clinical testing was performed on the PlasmaFlow to support the decision of substantial equivalence."

    Therefore, there is no specific sample size or test set derived from clinical data for the PlasmaFlow device itself mentioned in this document. The data provenance related to "clinical studies" refers to results from predicate devices and not studies conducted on the PlasmaFlow. The non-clinical testing was in-house bench testing and outside laboratory testing.


    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications

    As no clinical testing was performed on the PlasmaFlow and no specific test set data is presented for human interpretation, this information is not applicable to the PlasmaFlow device within this 510(k) submission.


    4. Adjudication Method for the Test Set

    Again, since no clinical test set for human interpretation was used for the PlasmaFlow device, this information is not applicable.


    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

    The PlasmaFlow is an intermittent pneumatic compression device, not an AI-powered diagnostic or interpretive device. Therefore, an MRMC comparative effectiveness study is not applicable as there are no "human readers" interpreting images or data with or without AI assistance in this context.


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

    The PlasmaFlow is a mechanical compression device, not an algorithm. Therefore, standalone algorithm performance is not applicable. The non-clinical testing (bench testing, electrical safety, EMC, etc.) can be considered "standalone" in the sense that it evaluates the device's technical performance independently.


    7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.)

    For the PlasmaFlow device based on non-clinical testing:

    • Bench Testing: The ground truth for performance metrics like pressure delivery, cuff fill time, and cycle time was established through objective measurements against defined specifications (e.g., 55 mmHg pressure, 60-second cycle time). These are quantifiable engineering parameters.
    • Biocompatibility: Ground truth was established through laboratory testing protocols (e.g., ISO 10993 series) to detect cytotoxicity, sensitization, and irritation.
    • Electrical Safety & EMC: Ground truth was established by conformance to international safety standards (e.g., IEC 60601 series), involving specific test procedures and measurements.
    • Risk Management: Conformance to quality management system standards (e.g., ISO 14971, ISO 13485).

    For the clinical effectiveness for similar devices (predicates): The document refers to published clinical studies evaluating intermittent pneumatic compression devices, which would typically rely on clinical outcomes data (e.g., DVT incidence, blood flow measurements, reduction in pain/swelling). However, these studies were not specific to PlasmaFlow.


    8. The Sample Size for the Training Set

    As the PlasmaFlow is a mechanical medical device and not an AI/algorithm-based system requiring a "training set" of data, this concept is not applicable.


    9. How the Ground Truth for the Training Set Was Established

    Since a "training set" is not applicable, this information is not relevant.

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