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510(k) Data Aggregation
(247 days)
Primary lymphedema (for example, congenital lymphedema/ milroy's disease) Secondary lymphedema (for example, post-mastectomy, chronic edema, post-traumatic edema) Venous disorders (for example, venous insufficiency, varicose veins, venous stasis ulcers) Dysfunction of the muscle pump (for example, promotion of wound recovery, reduction of edema and lower limb pain following trauma and sports injuries)
SLK Varilymph 12 Pro Compression Therapy Device utilizes a software-controlled air compression pump, which sequentially inflates and deflates cells within a compression garment (sleeve) that is put around a limb. This helps to push excessive interstitial fluid in the treated limb, back into the venous and lymphatic systems; improve limb circulation; and thus, treat the symptoms of a variety of lymphatic disorders, venous disorders and dysfunction of the "muscle pump". The device consists of a main console and compression garments. The main control contains an air compressor that is regulated by an electro-mechanical mechanism, including pressure sensors and a rotating dis controlling air outflow. The regulated compressed air is transferred via an air distributor through a series of hoses to a sleeve garment. Each garment contains 12 pressure cells. The sleeve fits on the affected limb and can easily adjusted to any limb size within the sleeve tolerance. The devices are powered from a system supply voltage (230V / 110V).
The SLK VariLymph 12 Pro (SLK V12 Pro) consist of an air compressor unit with a control system, an inflatable garment (arms, legs, trouser and jacket), silicon air tubing with proprietary connectors for connecting the device to the appliance; and a power cord.
The user interface on the SLK VariLymph 12 Pro is a Membrane Keypad with dome switches. The settings are shown on a 3,2" LCD Screen.
The device is intended to be used by the patient at home, as well as by physicians at clinics or hospitals.
The SLK VariLymph 12 Pro is a compressible limb sleeve device. The provided text indicates that its predicate device is the LYMPHA PRESS OPTIMAL MODEL 1201AP COMPRESSIBLE LIMB SLEEVE DEVICE (K082149). The justification for substantial equivalence relies on non-clinical performance data and a comparison to the predicate device.
1. Table of Acceptance Criteria and Reported Device Performance:
The document does not explicitly present a table of "acceptance criteria" with numerical targets for performance metrics. Instead, it describes various tests and concludes that the device performs similarly to the predicate. The overall acceptance criterion is demonstrating substantial equivalence in safety and efficacy to the predicate device.
Here's a summary of the performance claims based on the non-clinical data:
| Test/Characteristic | Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|---|
| Technological Principle | Same as predicate (Intermittent pneumatic compression). | Both subject and predicate devices use intermittent pneumatic compression. |
| Biocompatibility | Complies with ISO 10993-1, 10993-5, 10993-10 for contact with intact skin (<24 hours). | Cytotoxicity, Irritation, and Sensitization tests conducted. The type and scope of tests comply with ISO 10993-1:2009 specifications. |
| Electrical Safety | Complies with IEC 60601-1, IEC 60601-2:2014, and IEC 60601-1-11. | The system complies with IEC 60601-1. Justification for meeting EN 60601-1 was provided. IEC 60601-2:2014 (EMC) and IEC 60601-1-11 were tested as well. |
| Software Verification & Validation | Complies with FDA's "Guidance for the Content of Premarket Submission for Software Contained in Medical Devices" for "minor" level of concern. | Software verification and validation testing were conducted, and documentation was provided. The software was considered a "minor" level of concern. |
| Usability | Complies with IEC 60601-1-6 / IEC 62366. | Usability Test Protocol IEC 60601-1-6 / IEC 62366 was followed. |
| Mechanical & Acoustic Testing | Complies with IEC 60601-1-11 and IEC 60068-2-27 (Shock test), and IEC 60601-1-11 and IEC 60068-2-64 (Vibration test). | Shock and vibration tests were performed according to the specified IEC standards. |
| Pressure Distribution Comparison | Pressure distribution is comparable to the predicate device, ensuring similar safety and effectiveness. | An Expert Report by Berlin Cert GmbH concluded that there are a few differences but both products show a similar compression pressure curve in longitudinal direction. This indicates similar technological characteristics, safety, and effectiveness. |
| Overall Safety & Efficacy | Substantially equivalent to the predicate device. | The SLK VariLymph 12 Pro was found to have a safety and effectiveness profile similar to the predicate device. The device performs comparably to the predicate for the same intended use. |
2. Sample Size Used for the Test Set and Data Provenance:
The document describes non-clinical performance data and a comparison to a predicate device. There is no mention of a "test set" in the context of patient data or clinical trials for the SLK VariLymph 12 Pro. The primary "test" to show equivalence was a "Pressure distribution Comparison Test."
- Sample Size for Pressure Distribution Test: Not explicitly stated as a number of devices or measurements. It refers to "the test" and "pressure curves," implying a comparison of the pressure output of the SLK VariLymph 12 Pro against the Lympha Press Optimal predicate device.
- Data Provenance: The "Expert Report by Berlin Cert GmbH" suggests the testing was conducted by an external German certification body. The document does not specify a country of origin for any "data" beyond this. The data is based on device performance, not patient data, so "retrospective or prospective" is not applicable in the typical clinical sense.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts:
- Number of Experts: One "Expert Report by Berlin Cert GmbH" is mentioned. It's unclear if this refers to a single expert or a team/committee from Berlin Cert GmbH.
- Qualifications of Experts: Not explicitly stated beyond being an "Expert Report by Berlin Cert GmbH." Berlin Cert GmbH is a recognized certification body, implying their expertise in medical device testing and conformity assessment.
4. Adjudication Method for the Test Set:
Not applicable. The "Pressure distribution Comparison Test" involved comparing technical pressure curves, not expert adjudication of clinical outcomes or images.
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 compressible limb sleeve, not an AI-powered diagnostic or decision support system that would involve human readers or AI assistance.
6. If a Standalone (i.e. algorithm only without human-in-the loop performance) was done:
Not applicable. The device is a physical therapeutic device, not an algorithm.
7. The Type of Ground Truth Used:
The "ground truth" for the performance comparison was the performance characteristics (specifically pressure distribution) of the legally marketed predicate device (Lympha Press Optimal Model 1201AP). The SLK VariLymph 12 Pro's pressure curves were compared to those of the predicate.
8. The Sample Size for the Training Set:
Not applicable. There is no mention of an algorithm or AI model requiring a training set.
9. How the Ground Truth for the Training Set was Established:
Not applicable. No training set was used.
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