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510(k) Data Aggregation

    K Number
    K191862
    Date Cleared
    2019-10-29

    (110 days)

    Product Code
    Regulation Number
    890.5650
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K161907

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

    Compression Therapy Device LGT-2200SP is intended for the temporary relief of minor muscle aches and for the temporary increase in circulation to the treated areas, it can simulate kneading and stroking of tissues by using an inflatable garment.

    Device Description

    Compression therapy device LGT-2200SP is a powered inflatable tube massager, comprised of an air compressor with intermittent pneumatic controller, 4-chamber sleeves covered with Polyether Nylon Fabric, and a connectable hose for connecting the device to the sleeves. The case of main unit body is made from ABS plastic. The device can be powered by an external power supply, or be powered by an internal lithium ion battery. The sleeves have 4-chambers and different applicable body areas, such as the Arm/ Leg/ Waist, hip and thigh/ Calf and foot. The sleeves can be inflating sequentially to apply the circulating pressure on the target body areas which controlled by the main unit. The device simulates manual kneading and stroking of tissues by sequential inflated sleeves, to temporarily relieve minor muscle aches and/or pains and to temporarily increase circulation to the treated areas.

    AI/ML Overview

    The provided text is a 510(k) Summary for the Compression Therapy Device Model LGT-2200SP. It asserts substantial equivalence to predicate devices and focuses on technical specifications and adherence to safety standards.

    Here's an analysis of the provided text in relation to your request:

    The document does not include detailed acceptance criteria or a study that rigorously proves the device meets those criteria in a clinical performance context. Instead, it focuses on demonstrating safety and effectiveness through compliance with recognized standards and comparison to predicate devices.

    Let's break down your specific points based on the available information:

    1. A table of acceptance criteria and the reported device performance:
      The document doesn't provide a typical "acceptance criteria" table for device performance in a clinical sense (e.g., accuracy, sensitivity, specificity). Instead, it compares the subject device's technical specifications and features to predicate devices, and asserts that differences do not raise new questions of safety or effectiveness.

      Here's a table summarizing the comparison of the device's technical specifications and features to the predicate devices, which act as a form of "acceptance" by demonstrating substantial equivalence:

      Elements of ComparisonSubject Device (LGT-2200SP)Predicate Device (Primary: NormaTec Pulse/Pro)Predicate Device (II: Rapid Reboot System)Predicate Device (III: Senyang Pt 1002)Verdict (Equivalence Claim)
      Classification NamePowered inflatable tube massagerPowered inflatable tube massagerPowered inflatable tube massagerPowered inflatable tube massagerSubstantially Equivalent (SE)
      Regulation Class2222SE
      Regulation Number21 CFR 890.565021 CFR 890.565021 CFR 890.565021 CFR 890.5650SE
      OTC & RxOTCOTCOTCRxMinor different (Noted in Remarks below)
      Indications for UseTemporary relief of minor muscle aches and pains, temporary increase in circulation. Simulates kneading/stroking.Temporary relief of minor muscle aches/pains, temporary increase in circulation.Temporary relief of minor muscle aches/pains, temporary increase in circulation in healthy people. Simulates kneading/stroking.Treating primary lymphedema, edema, venous insufficiencies, lymphedema (Rx use).Minor different (Noted in Remarks below)
      Power SourceAC100-240V, Battery 11.1V, 6500mAh12 VDC via IEC 60601-1 PSU, Optional rechargeable battery110 V, 60Hz110 V, 60HzMinor different (Noted in Remarks below)
      Power Consumption90VA14W30W30WMinor different (Noted in Remarks below)
      Dimensions (WHD)270148129mm4"*5" *9"10" x 6.5" x 5"260170130mmMinor different (Noted in Remarks below)
      Weight2.0 Kg (4.4 pounds)3.6 pounds5.8 pounds5.8 poundsMinor different (Noted in Remarks below)
      Housing MaterialsMolded ABS enclosureMolded ABS enclosureMolded ABS enclosureMolded ABS enclosureSE
      Number of Chambers4-chamber5 or less4 Chambers4 ChambersSE
      Sleeve MaterialsPolyether Nylon Fabric200 denier nylon with polyurethane laminate/extrusionNylon with a Polyurethane laminateThermoplastic UrethaneMinor different (Noted in Remarks below)
      Mode of CompressionSequentialSequentialSequentialSequentialSE
      Device Pressure Range30-150mmHg30-110 mmHg0-200 mmHg0-250mmHgMinor different (Noted in Remarks below)
      Treatment Time1min-99min, default 30min, step of 5minStays on until user turns off or 10mins to continuous10, 20, or 30 minute, with option to add 10 minutes0 - 30minsMinor different (Noted in Remarks below)
      Work Mode6 modes (SEQUENTIAL, SQUEEZE, FLUSH, FLOW, RELEASE, WAVE)Sequential, Zone pulses (2 modes)Model A, Model B (2 modes)Model A, Model B (2 modes)Minor different (Noted in Remarks below)
      Patient ContactNon-conductive appliancesNon-conductive appliances(Image of Predicate II)(Image of Predicate III)SE
      Software/Firmware/Microprocessor ControlMicroprocessorMicroprocessorMicroprocessorMicroprocessorSE
      TechnologyCompressor and valve system inflates cells of appliance sequentiallyCompressor and valve system inflates cells of appliance sequentiallyCompressor and valve system inflates cells of appliance sequentiallyCompressor and valve system inflates cells of appliance sequentiallySE
      FDA-Recognized StandardsANSI/AAMI ES60601-1, IEC 60601-1-2, IEC 60601-1-11, IEC 62133, ISO 10993-5, ISO 10993-10ES 60601-1, IEC 60601-1-2, IEC 60601-1-11IEC 60601-1:2014, IEC 60601-1-2:2014, EN ISO 10993-5:2009, EN ISO 10993-10:2010IEC 60601-1, IEC 60601-1-2, ISO10993-5, ISO10993-10Minor different (Noted in Remarks below)

      Remarks on "Minor different" Verdicts:

      • Indications for Use: The document states, "Although there is a little difference about the indication for use, the meanings are the same. This difference does not affect the safety and effectiveness." (Note 1)
      • Power Source, Consumption, Dimensions, Weight: "Although the subject device design and specification parameter between the predicate are different, they are both complied with ANSI/AAMI ES60601-1. So the minor differences on such parameters do not affect the safety and effectiveness." (Note 2)
      • Sleeve Materials, Sleeves (dimensions/types): "Although the device provides four kind sleeves which have minor difference about size and appearance, the sleeve chamber number are the same and the applicable body areas are included in the predicate... the biocompatibility of sleeves is also complied with ISO 1099-5 and ISO 10993-10. Therefore, the difference would not raise adversely impact on safety and effectiveness." (Note 3)
      • Device Pressure Range: "Although the pressure range of subject devices, the range is smaller and contained by the predicate device (1), so the difference of pressure range would not raise adversely impact on safety and effectiveness." (Note 4). (There seems to be an error in the text where it ambiguously says "range is smaller and contained by the predicate device (1)" when for PD(II) and PD(III) the subject device's range is within a larger range.)
      • Treatment Time: "Although the treatment time range of subject device is to 99mins, which seems to be longer than the predicated with is suitable for daily use. And the treatment time is optionally set by user with 5mins step, which is more exact to the difference of pressure range would not raise adversely impact on safety and effectiveness." (Note 5). (There seems to be an error in the text where it mentions "difference of pressure range" instead of treatment time range).
      • Work Mode: "Although the subject device provides six kinds of work mode, the SEQUENTIAL and FLUSH mode are the same with the other work modes of subject device just have different about the different chambers. The treatment pressure range are the same under different work modes, so the difference of pressure range would not raise adversely impact on safety and effectiveness." (Note 6).
      • FDA-Recognized Standards: "The subject device references more sufficient safety standards than the 'safety of the safety' of the device is verified via tests." (Note 7 - this implies the subject device meets or exceeds the standards referenced by predicates, further supporting SE).
    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):
      The document explicitly states: "Clinical performance is not deemed necessary." (Section 7. Summary for clinical test). Therefore, there is no test set, sample size, or data provenance regarding clinical performance. The evaluation was based on bench testing and comparison to predicates.

    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):
      As no clinical test set was used, there were no experts establishing ground truth in a clinical context.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
      As no clinical test set was used, there was no adjudication method.

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:
      This device is a physical therapy device (compression therapy device), not an AI imaging or diagnostic algorithm. Thus, an MRMC study and AI assistance effectiveness are not applicable and were not performed.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
      This is a physical therapy device. The concept of "standalone algorithm performance" is not applicable.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):
      As no clinical studies were performed, there was no clinical ground truth established (such as expert consensus, pathology, or outcomes data). The "ground truth" for demonstrating substantial equivalence was adherence to recognized safety standards and functional comparison to legally marketed predicate devices.

    8. The sample size for the training set:
      As no machine learning or AI component is mentioned, there is no training set, and therefore no associated sample size.

    9. How the ground truth for the training set was established:
      As there is no training set for an AI/ML model, this question is not applicable.

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    K Number
    K182668
    Date Cleared
    2018-12-14

    (80 days)

    Product Code
    Regulation Number
    890.5650
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K161907

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

    The Rapid Reboot Compression Therapy System is indicated for the temporary relief of minor muscle aches and pains and for temporary increase in circulation to the treated areas in people who are in good health. The Rapid Reboot Compression Therapy System simulates kneading and stroking of tissues by using an inflatable garment.

    Device Description

    Rapid Reboot Compression Therapy System ("Rapid Reboot") consists of an air pump, air pressure sensor, and sleeves working together as one unit. The air pump is connected to the dedicated sleeves via a series of hoses; each sleeve has four (4) compression chambers. 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. Software controls the timing and pressure reflected by the sensor, cycling airflow into and out of the sleeves to compress body

    AI/ML Overview

    The provided text describes the "Rapid Reboot Compression Therapy System" and its substantial equivalence determination. However, it does not include detailed acceptance criteria or a specific study proving the device meets those criteria in the way typically found for AI/ML-driven medical devices (e.g., performance metrics like sensitivity, specificity, or AUC, alongside sample sizes for test and training sets, expert qualifications for ground truth, etc.). This document solely focuses on demonstrating substantial equivalence to predicate devices based on indications for use, technological characteristics, and compliance with general medical device standards.

    Therefore, most of the requested information regarding acceptance criteria and performance study details for an AI/ML device is not present in the provided text.

    Here's an attempt to answer based only on the available information:

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

    The document does not specify quantitative acceptance criteria in terms of performance metrics (e.g., sensitivity, specificity, accuracy) or device performance against such metrics. Instead, it demonstrates compliance with general medical device standards and substantial equivalence to predicate devices.

    Acceptance Criteria (from text)Reported Device Performance (from text)
    Electrical Safety IEC 60601-1:2014Met the requirements of the standard
    EMC IEC 60601-1-2:2014Met the requirements of the standard
    Biocompatibility EN ISO 10993-5:2009Met the requirements of the standard
    Biocompatibility EN ISO 10993-10:2010Met the requirements of the standard
    Substantial Equivalence to Predicates for Indications for Use, and similar technological and performance characteristics"Substantially equivalent to the legally marketed Relaxor Perfect Touch Air Massaging System (primary predicate) and Normatec Pulse and Pulse Pro (secondary predicate) for Indication for Use, and it is substantially equivalent in technological and performance characteristics to Pt 1002 Pressure Therapy System (reference device)."
    "It is at least as safe and effective as the predicate devices and technologically comparable to the reference device, and doesn't raise any new safety and/or effectiveness concerns."

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

    Not applicable. The document describes performance testing based on compliance with general safety, EMC, and biocompatibility standards for the device itself, not on analyzing patient data or clinical images. It's a physical device, not an AI/ML diagnostic or prognostic system.

    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. This is not a study requiring expert-established ground truth on patient data.

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

    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

    No, an MRMC study was not done. The device is a compression therapy system, not an AI-assisted diagnostic tool.

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

    Not applicable. The device is a physical therapy system, not an algorithm.

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

    Not applicable. Ground truth as typically understood for AI/ML performance on clinical data is not relevant here. The "ground truth" equivalent would be the established requirements of the referenced IEC and ISO standards that the device was tested against.

    8. The sample size for the training set

    Not applicable. The device is not an AI/ML model trained on data.

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

    Not applicable.

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