FDA Approval vs. 510(k) Clearance: How HBOT Is Regulated

HBOT chambers have FDA 510(k) clearance as devices. Individual indications go through a separate FDA process. Here's how the regulatory system actually works.

Updated February 22, 2026 · 5 min read
Medical Disclaimer: This content is for informational purposes only and does not constitute medical advice. Always consult a qualified healthcare provider before starting any treatment. Read full disclaimer.

FDA Approval vs. 510(k) Clearance: How HBOT Is Regulated

When someone says HBOT is “FDA-approved,” they’re often describing two different things simultaneously — and sometimes confusing them. The device is regulated one way. The indications are recognized another way. These aren’t the same process, and the distinction matters for anyone evaluating HBOT’s evidence base.

Device Clearance: The 510(k) Pathway

Hyperbaric chambers are Class II medical devices. FDA regulates them under 21 CFR Part 880. Before a manufacturer can sell a hyperbaric chamber commercially in the US, they need 510(k) clearance.

The 510(k) pathway doesn’t require the same evidence as a new drug approval. Instead, the manufacturer demonstrates that their device is substantially equivalent to a “predicate device” — an existing legally marketed device with the same intended use. FDA reviews whether the new device is as safe and performs as claimed relative to that predicate.

This is a different evidence standard than a Phase III randomized clinical trial. It’s appropriate for devices — where performance and safety can be evaluated through bench testing, engineering analysis, and limited clinical data. It’s not designed to evaluate whether a specific clinical indication works. That’s a separate question.

All clinical-grade hyperbaric chambers and most compliant home soft chambers have 510(k) clearance. The clearance is on the device itself.

Indication Recognition: How “FDA-Approved” Conditions Happen

When people say HBOT is “FDA-approved for diabetic wounds” or “FDA-approved for CO poisoning,” they mean something more specific than a drug approval process.

The path from clinical evidence to recognized indication works like this:

The UHMS (Undersea and Hyperbaric Medical Society) clinical committee reviews evidence and adds conditions to the UHMS Approved Indications list. Medicare establishes National Coverage Determination 20.29 based on those indications, creating a coverage standard. The 510(k) clearance for the chamber device may include specific labeling referencing those indications.

This chain is real and meaningful. The 14 conditions Medicare covers have substantial clinical evidence behind them. But the evidence threshold for device indication labeling is not the same as the Phase III RCT requirement for drug approval. Saying HBOT is “FDA-approved” in the same sense that Ozempic is “FDA-approved” creates a misleading impression of the evidence level.

This isn’t a criticism of HBOT — it’s how the medical device regulatory system works. Many important and well-evidenced medical interventions are device-based and follow this pathway.

Why Wellness Spas Can Legally Offer HBOT

Once a device has 510(k) clearance, it can be operated legally for wellness purposes without a physician’s order. FDA doesn’t regulate the use of cleared devices by consumers in the same way it regulates drug prescriptions.

This is why hyperbaric spas, biohacking studios, and wellness centers can offer HBOT sessions to the general public without a prescription. They’re operating a cleared device for wellness purposes — not making drug claims for a specific medical indication.

The legal line is in the marketing. A spa can say “HBOT sessions available.” A spa cannot say “our HBOT cures autism” or “HBOT eliminates cancer” — those are disease claims for unapproved indications, and that’s where FDA enforcement begins.

Home Chamber Clearance vs. Medical Indication

Home soft chambers have their own 510(k) clearances — as devices. They’re cleared at 1.3 to 1.5 ATA with ambient air.

The 510(k) clearance on a home chamber does not mean it’s cleared for the medical indications that clinical HBOT treats. Those indications require 2.0 to 3.0 ATA with 100% oxygen. A home chamber’s clearance confirms the device is safe and performs as claimed at its specified parameters — not that it meets the clinical criteria for wound healing or CO poisoning treatment.

This is a common point of confusion in home chamber marketing. “FDA cleared” on a soft chamber box refers to the device, not to any medical indication.

FDA Enforcement for Off-Label Claims

FDA has issued warning letters and pursued enforcement against HBOT providers making specific disease claims for unapproved indications. High-risk areas for enforcement have included claims about autism, cancer, Lyme disease, Alzheimer’s disease, and COVID-19.

FTC has also pursued action against HBOT marketers for deceptive advertising claims. Hedge language (“may help,” “some patients report”) doesn’t fully protect against enforcement if the base claim is unsubstantiated or implies a level of evidence that doesn’t exist.

Clinics and wellness centers operating in good faith — offering HBOT as a wellness service without making specific disease claims for unapproved indications — are operating legally. Those that market HBOT as a cure or definitive treatment for unapproved conditions take on real regulatory risk.

See what the UHMS does for how UHMS indications feed into this regulatory framework, and choosing a clinic for how to evaluate providers.


FAQ

Does 510(k) clearance mean FDA tested the chamber? FDA doesn’t typically test devices itself. The manufacturer submits documentation demonstrating substantial equivalence to a predicate device. FDA reviews the submission and either clears or rejects it. Third-party testing labs often verify performance claims.

Can a doctor prescribe HBOT for any condition? A physician can order HBOT for off-label conditions. Prescribing off-label is legal in medicine. The issue is coverage: insurance won’t pay for off-label HBOT, and the facility needs to be willing to provide it. Many clinical facilities only treat approved indications.

If my condition isn’t on the UHMS list, can FDA still cover it? Coverage through Medicare/Medicaid follows NCD 20.29, which is based on UHMS indications. A condition not on the UHMS list won’t be covered under NCD 20.29. Private insurance coverage for off-label HBOT is extremely rare.

What’s the difference between Class I, II, and III devices? Class I devices (low risk): general controls. Class II (moderate risk): general plus special controls, often requiring 510(k). Class III (high risk): requires Premarket Approval (PMA) with extensive clinical data — similar to drug approval. Hyperbaric chambers are Class II.


Medical Disclaimer: The content on this page is for informational purposes only. It is not medical advice and does not create a doctor-patient relationship. Regulatory status doesn’t determine whether HBOT is appropriate for your specific condition. Consult a licensed physician for that evaluation.