OrthoGold 100

K182682 · Tissue Regeneration Technologies · ISA · Dec 21, 2018 · Physical Medicine

Device Facts

• Record ID: K182682
• Device Name: OrthoGold 100
• Applicant: Tissue Regeneration Technologies
• Product Code: ISA · Physical Medicine
• Decision Date: Dec 21, 2018
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 890.5660
• Device Class: Class 1
• Attributes: Therapeutic

Intended Use

The OrthoGold 100 is intended for the activation of connective tissue.

Device Story

OrthoGold 100 is a pulsed acoustic wave device used for connective tissue activation. It utilizes an electrically powered generator to create transient compressed air that expands to produce acoustic waves; these waves are propagated through a water-filled coupling membrane in a hand-held applicator. The applicator is placed against the treatment area using a silicone membrane and ultrasound transmission gel to reflect acoustic waves into the tissue. Operated by a clinician in a clinical setting, the device provides unfocused pressure pulses. The output is controlled via intensity settings (1-16) and frequency (1-8 Hz). By delivering these acoustic pulses, the device aims to stimulate connective tissue, potentially aiding in therapeutic outcomes. The device is intended for professional use.

Clinical Evidence

Bench testing only. Performance testing included verification and validation of design specifications, software validation (Moderate level of concern), and conformance to IEC 60601-1:2005, IEC 60601-1-2:2014, and 60601-2-36. In-vitro testing measured applicator displacement, force, and penetration depth (25.4 mm at max energy), demonstrating equivalence to the predicate device. No clinical data provided.

Technological Characteristics

Pulsed acoustic wave device; electro-hydraulic spark gap generation via high voltage (2-7 kV) discharge under water. Applicator uses silicone membrane and ultrasound transmission gel. Frequency 1-8 Hz; energy flow density 0.00017-0.04403 mJ/mm2. Conforms to IEC 60601-1, IEC 60601-1-2, and 60601-2-36. Software validated as Moderate level of concern.

Indications for Use

Indicated for the activation of connective tissue.

Regulatory Classification

Identification

A therapeutic massager is an electrically powered device intended for medical purposes, such as to relieve minor muscle aches and pains.

Predicate Devices

• Dermablate Effect (K081541)

Submission Summary (Full Text)

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December 21, 2018

Tissue Regeneration Technologies, LLC % Jennifer Daudelin, MSJ Regulatory Consultant III M Squared Associates, Inc. 575 Eighth Avenue, Suite 1212 New York, New York 10018

Re: K182682

Trade/Device Name: OrthoGold 100TM Regulation Number: 21 CFR 890.5660 Regulation Name: Therapeutic Massager Regulatory Class: Class I Product Code: ISA Dated: September 26, 2018 Received: September 26, 2018

Dear Jennifer Daudelin:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

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Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email ([e-mail]) or phone [phone] or 301-796-7100).

Sincerely,

Vivek J. Pinto -S

for Carlos L. Peña, PhD, MS Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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## Indications for Use

510(k) Number (if known) K182682

Device Name OrthoGold 100

Indications for Use (Describe) The OrthoGold 100 is intended for the activation of connective tissue.

| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------|--|
|-------------------------------------------------|--|

> Prescription Use (Part 21 CFR 801 Subpart D)

| Over-The-Counter Use (21 CFR 801 Subpart C)

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# 510(k) Summary

# Tissue Regeneration Technologies, LLC

# OrthoGold 100™

The following information is provided as required by 21 CFR § 807.87 for the Tissue Regeneration Technologies, LLC 510(k) premarket notification. In response to the Safe Medical Devices Act of 1990, the following is a summary of the safety and effectiveness information upon which the substantial equivalence determination is based.

| Sponsor: | Tissue Regeneration Technologies, LLC<br>251 Heritage Walk<br>Woodstock, GA 30188 | | | |
|--------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------|---------|-------|
| Contact: | Jennifer A. Daudelin, M.S.J.<br>M Squared Associates, Inc.<br>575 Eighth Avenue, Suite 1212<br>New York, NY 10018<br>Ph: 703-562-9800 x251<br>Fax: [phone]<br>Email: [e-mail] | | | |
| Date Prepared: | September 24, 2018 | | | |
| Proposed Class: | I | | | |
| Proprietary Name: | OrthoGold 100TM | | | |
| Common Name: | Therapeutic Massager | | | |
| Classification Name: | Massager, Therapeutic, Electric | | | |
| Regulation Number: | 21 CFR 890.5660 | | | |
| Product Codes: | ISA | | | |
| Predicate Device(s): | | | | |
| Manufacturer | Device Name | 510(k) Number | Procode | Class |
| Asclepion Laser<br>Technologies GmbH | Dermablate Effect | K081541 | ISA | I |

## Indications for Use

The OrthoGold 100™ is intended for the activation of connective tissue.

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#### Device Description

The OrthoGold 100™ is a pulsed acoustic wave device. It includes an electrically powered generator to generate transient compressed air that rapidly expands to create the acoustic waves, which in turn are propagated through a water-filled coupling membrane attached to the hand-held applicator. The hand-held applicator reflects the acoustic waves towards the treatment area through a silicone membrane and ultrasound transmission gel.

### Performance Data

Verification and validation testing was performed and demonstrated that the OrthoGold 100™ meets the design specifications and is safe and effective for its intended use. All tests required by the verification and validation plan were completed and passed. The OrthoGold 100™ software was validated and demonstrated to be of a Moderate level of concern; while hazard analysis / risk management was performed and demonstrated that all risks are mitigated to an acceptable level. The OrthoGold 100 was tested and demonstrated to conform to the general safety requirements of IEC 60601-1:2005; as well as the electromagnetic compatibility requirements of IEC 60601-1-2:2014 (4th Ed.) and 60601-2-36. In-vitro testing was performed to determine applicator displacement, force and penetration depth and was demonstrated to be equivalent to the AW module of the Dermablate predicate device. In addition, probe cover testing and transport verification and validation was also conducted. The performance testing demonstrated that the OrthoGold 100 is substantially equivalent to the predicate device.

| Product Characteristic | Subject Device | Predicate Device | Comparison |
|-----------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------|------------|
| | OrthoGold 100TM | Dermablate Effect | |
| 510(k) Number | To be assigned | K081541 | NA |
| Indications for Use | Activation of connective tissue | Activation of connective tissue | Identical |
| Modes of Action | Unfocused pressure pulses | Radial (unfocused) pressure<br>waves, or extracorporeal pulse<br>activation respectively | Similar |
| Mechanisms of Action | Extracorporeally induced<br>unfocused pressure pulses | Pneumatically generated<br>vibrations + unfocused pressure<br>pulses | Equivalent |
| Maximum and Minimum<br>intensity settings | 1 to 16 | Specific Value Not Available | Similar |
| | Subject Device | Predicate Device | Comparison |
| Product Characteristic | OrthoGold 100™ | Dermablate Effect | |
| Number and size of<br>treatment applicator heads | OP155<br>Size: 230 x ø 70 mm | Specific Value Not Available | Similar |
| Maximum and minimum<br>displacements of<br>applicator heads | Not Applicable | Specific Value Not Available | NA |
| Type of application (e.g.,<br>continuous vibration at a<br>fixed frequency); | Continuous at various frequencies | Specific Value Not Available | Similar |
| Maximum and minimum<br>vibration frequency | Frequency of 1 - 8 Hz in steps of<br>0.5 Hz | Specific Value Not Available | Similar |
| Driving Power | High voltage 2 - 7 kV<br>Capacitor: 0,2 uF | Specific Value Not Available | Similar |
| Power Supply | 115 VAC | Specific Value Not Available | Similar |
| Maximum applicator<br>force | Not Applicable | Specific Value Not Available | NA |
| Maximum applicator<br>displacement | Not Applicable | Specific Value Not Available | NA |
| Maximum penetration<br>depth | 25.4 mm at energy level 16 | 30mm (3cm) | Similar |
| Energy flow density<br>PIIT [mJ/mm2] | 0.00017 - 0.04403<br>at energy level 1 - 16 | 0.018-0.25 | Similar |
| Operating mode | Continuous | Specific Value Not Available | Similar |
| Projectile mass (g) | Not Applicable | Specific Value Not Available | NA |
| Pulse repeat rate (1/s) | 1 - 8 Hz | 1-11 Hz | Similar |
| Number of pulses (min<br>and max) | 500 - 2000 | Specific Value Not Available | Similar |
| Maximum operating<br>temperature | Room temperature | Specific Value Not Available | Similar |
| Type of acoustic wave<br>generation | Electro hydraulic, spark gap<br>under water caused by discharge<br>of high voltage condensers | Ballistic technology, pressurized<br>air pulses accelerate a projectile<br>within a guiding tube | Similar |
| Peak compressional<br>acoustic pressure<br>pc [MPa] | 9.27<br>at energy level 16 | 13.4 | Similar |
| Peak rarefactional<br>acoustic pressure<br>pcr[MPa] | -1.52<br>at energy level 16 | Specific Value Not Available | Similar |
| Description of the spatial<br>distribution of the<br>acoustic pressure and<br>intensity | Unfocused acoustic pressure field,<br>see pressure measurements | Specific Value Not Available | Similar |
| Positive peak pressure<br>amplitude (MPa)<br>pc [MPa] | 0.43 - 9.27<br>at energy level 1 - 16 | 13.4 | Similar |
| | Subject Device | Predicate Device | Comparison |
| Product Characteristic | OrthoGold 100™ | Dermablate Effect | |
| Negative peak pressure<br>amplitude (MPa)<br>$pcr[MPa]$ | -0.17 to -1.52<br>at energy level 1 - 16 | Specific Value Not Available | Similar |
| Derived focal acoustic<br>pulse energy (mJ)<br>$EbT [mJ]$ | 0.022 - 2.278<br>at energy level 1 - 16 | Specific Value Not Available | Similar |
| Derived pulse intensity<br>integral, integrated over<br>total temporal integration<br>limits<br>$PIIT [mJ/mm2]$ | 0.00017 - 0.04403<br>at energy level 1 - 16 | Specific Value Not Available | Similar |
| Rise time (ns)<br>(10% - 90%) tr [us] | 1.89 - 0.28<br>at energy level 1 - 16 | Specific Value Not Available | Similar |
| Compressional pulse<br>duration (us)<br>$tFWHMpc [uS]$ | 1.23 - 0.77<br>at energy level 1 - 16 | Specific Value Not Available | Similar |

The table below compares the OrthoGold 100 characteristics to the predicate device.

Tissue Regeneration Technologies, LLC OrthoGold100TM

510(k) Summary Page 2 of 4

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Tissue Regeneration Technologies, LLC OrthoGold100TM

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## Technological Characteristics and Substantial Equivalence

The OrthoGold 100™ has the same indications for use and similar design features as compared with the predicate system. The bench testing demonstrates that the performance characteristics of the OrthoGold 100™ are equivalent to those of other legally marketed therapeutic massagers, and therefore supports a determination of Substantial Equivalence for the proposed indications for use. Any differences between the subject and predicate device would not render the device NSE, affect the safety or effectiveness, or raise different questions of safety and effectiveness.