(89 days)
The Transtek Blood Pressure Monitor intended for use in measuring blood pressure and heartbeat rate with a wrist circumference ranging from 13.5cm to 23cm. It is intended for adult, indoor use only.
Transtek Wrist Blood Pressure Monitor, TMB-2072 is designed to measure the systolic and diastolic blood pressure and heartbeat rate of an individual by using a non-invasive technique in which an inflatable cuff is wrapped around the wrist. Measurement method to define systolic and diastolic pressure is similar to the auscultatory method but uses an electronic pressure sensor rather than a stethoscope and mercury manometer. The sensor converts tiny alterations in cuff pressure to electrical signals, by analyzing those signals to define the systolic and diastolic blood pressure and calculating heartbeat rate, which is a wellknown technique in the market called the "Oscillometric method". Transtek Wrist Blood Pressure Monitor is single-mounted devices of the main unit and cuff unit. The preformed cuff unit, which is applicable to wrist circumference approximately between 13.5 and 23 cm, includes the inflatable bladder and nylon shell. The device consists of the microprocessor, the pressure sensor, the operation keys, the pump and the electromagnetic deflation control valve. The subject device is powered by 3.7V Built-in rechargeable lithium-ion battery. The device also compares the longest and the shortest time intervals of detected pulse waves to mean time interval and displays a warning signal with the reading to indicate the detection of irregular heartbeat when the difference of the time intervals is over 25%. Transtek Wrist Blood Pressure Monitor TMB-2072 embeds a Bluetooth module that allows it to connect to nearby BT receiving end. The mobile application displays results. And once measurement is over, the device will start transmission data by BT. Thus, users can receive, and display/storage, measurement data from TMB-2072 unit through their end devices that embedded BT module.
The provided text describes the 510(k) submission for the Transtek Wrist Blood Pressure Monitor (Model TMB-2072). Here's an analysis of the acceptance criteria and study information:
1. Acceptance Criteria and Reported Device Performance
The primary clinical performance acceptance criteria for the blood pressure monitor are based on the ISO 81060-2:2018 standard for clinical validation of automated measurement type. While the specific numerical acceptance criteria (e.g., mean difference and standard deviation thresholds) are not explicitly stated in the document, the conclusion indicates that the device met these criteria.
| Acceptance Criterion (Based on ISO 81060-2:2018) | Reported Device Performance |
|---|---|
| Mean error and standard deviation of differences for systolic blood pressure not exceeding specified limits. | "All data's mean error and standard deviation of differences for systolic... pressure is not over the limits of ISO 81060-2: 2018" |
| Mean error and standard deviation of differences for diastolic blood pressure not exceeding specified limits. | "...and diastolic pressure is not over the limits of ISO 81060-2: 2018" |
| Accuracy better than the predicate device. | "and the accuracy of subject device is better than predicate device." |
| No adverse effects/complications during the study. | "No adverse effect and/or complication is found in this study." |
Additional Performance Criteria (Non-Clinical):
The device also claims compliance with various non-clinical standards for electrical safety, electromagnetic compatibility, usability, and wireless testing. These are not presented in a table with specific acceptance values, but rather as statements of compliance.
2. Sample Size and Data Provenance
- Sample Size for the Test Set: 85 qualified healthy adult subjects.
- Data Provenance: The document does not explicitly state the country of origin for the clinical study data or whether it was retrospective or prospective. However, based on the manufacturer's location (Guangdong, China) and the submission's context, it's highly likely the study was conducted prospectively in China.
3. Number of Experts and Qualifications for Ground Truth
The document specifies that the clinical study was conducted according to ISO 81060-2:2018. This standard typically requires "reference blood pressure measurements obtained by two trained observers using a reference sphygmomanometer against which the automated device measurements are compared."
- Number of Experts: The document does not explicitly state the number of experts used to establish the ground truth. However, based on the adherence to ISO 81060-2, it would involve at least two trained observers (likely medical professionals or technicians specifically trained in auscultatory blood pressure measurement).
- Qualifications of Experts: Not specified in the document, but ISO 81060-2 mandates "trained observers." These observers would be qualified to perform accurate auscultatory blood pressure measurements.
4. Adjudication Method for the Test Set
The document does not explicitly describe an "adjudication method" in the context of expert consensus (like 2+1 or 3+1). For blood pressure measurement validation under ISO 81060-2, the ground truth is established by concurrent measurements from reference sphygmomanometers read by trained observers. The standard outlines specific methods for comparing the automated device readings against these observer readings. Discrepancies between the two observers' readings typically have pre-defined limits within the standard, and if these limits are exceeded, the measurements might be discarded or re-taken. This is more of a concordance assessment rather than adjudication to resolve differing opinions on a single diagnosis.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. This study is a standalone performance validation of the device against a reference standard (observers), not an assessment of human readers' improvement with or without AI assistance. The device in question is an automatic measuring device, not an AI-assisted diagnostic tool for interpretation by human readers.
6. Standalone Performance Study
Yes, a standalone performance study was done. The entire clinical study described, based on ISO 81060-2:2018, is a standalone (algorithm only without human-in-the-loop performance) assessment of the device's accuracy in measuring blood pressure. The device's measurements were compared directly to the reference measurements obtained by trained observers.
7. Type of Ground Truth Used
The type of ground truth used was expert consensus (from trained observers) using reference sphygmomanometers, as mandated by the ISO 81060-2:2018 standard. This is considered a gold standard for blood pressure measurement validation.
8. Sample Size for the Training Set
The document does not provide information on the sample size for a training set. This submission is for a medical device that measures blood pressure using the "Oscillometric method," which is a well-established technique. While the internal algorithms of such devices are developed and likely refined using data, the document focuses on the clinical validation of the final device, not the development data. Therefore, details about a "training set" in the context of, for instance, a deep learning AI model, are not applicable or provided here.
9. How the Ground Truth for the Training Set Was Established
As noted above, information on a "training set" in the context of an AI model is not provided. For the clinical validation (test set) ground truth, it was established by trained human observers using reference sphygmomanometers following the protocols of ISO 81060-2:2018.
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December 6, 2020
Guangdong Transtek Medical Electronics Co., Ltd. % Kevin Wang Consultant Chonconn Medical Device Consulting Co., Ltd. Room 508, Block C, No. 1029 Nanhai Avenue, Nanshan District Shenzhen, Guangdong 518067 China
Re: K202599
Trade/Device Name: Transtek Wrist Blood Pressure Monitor Regulation Number: 21 CFR 870.1130 Regulation Name: Noninvasive Blood Pressure Measurement System Regulatory Class: Class II Product Code: DXN Dated: September 2, 2020 Received: September 8, 2020
Dear Kevin Wang:
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.
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
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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/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
LT Stephen Browning Assistant Director Division of Cardiac Electrophysiology, Diagnostics and Monitoring Devices Office of Cardiovascular Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known) K202599
Device Name Transtek Wrist Blood Pressure Monitor
Indications for Use (Describe)
The Transtek Blood Pressure Monitor intended for use in measuring blood pressure and heartbeat rate with a wrist circumference ranging from 13.5cm to 23cm. It is intended for adult, indoor use only.
| Type of Use (Select one or both, as applicable) |
|---|
| ------------------------------------------------- |
Prescription Use (Part 21 CFR 801 Subpart D)
X Over-The-Counter Use (21 CFR 801 Subpart C)
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510(K) Summary
Prepared in accordance with the requirements of 21 CFR Part 807.92
Prepared Date: 2020/09/02
1. Submission sponsor
Name: Guangdong Transtek Medical Electronics Co., Ltd. Address: Zone B, No.105, Dongli Road, Torch Development District, Zhongshan, Guangdong, China Contact person: Nicole Hu Title: RA Engineer E-mail: nicole.hu(@transtekcorp.com
2. Submission correspondent
Name: Chonconn Medical Device Consulting Co., Ltd.
Address: Room 508, Block C, No. 1029 Nanhai Avenue, Nanshan District, Shenzhen, Guangdong, P. R. China 518067
Contact person: Kevin Wang
E-mail: kevin(@chonconn.com
Tel: +86-755 33941160
| Trade/Device Name | Transtek Wrist Blood Pressure Monitor |
|---|---|
| Model | TMB-2072 |
| Common Name | Automatic Blood Pressure Monitor |
| Regulatory Class | Class II |
| Product Code | DXN |
| Submission type | Traditional 510(K) |
Subject Device Information 3.
4. Predicate Device
Guangdong Transtek Medical Electronics Co., Ltd., Transtek Wrist Blood Pressure Monitor, Model TMB-1014-BT under K123669.
ട്. Device Description
Transtek Wrist Blood Pressure Monitor, TMB-2072 is designed to measure the systolic and diastolic blood pressure and heartbeat rate of an individual by using a non-invasive technique in which an inflatable cuff is wrapped around the wrist. Measurement method to define systolic and diastolic pressure is similar to the auscultatory method but uses an electronic pressure sensor rather than a stethoscope and mercury manometer. The sensor converts tiny alterations in cuff pressure to electrical signals, by analyzing those signals to define the systolic and diastolic blood pressure and calculating heartbeat rate, which is a wellknown technique in the market called the "Oscillometric method". Transtek Wrist Blood Pressure Monitor is single-mounted devices of the main unit and cuff unit. The preformed cuff unit, which is applicable to
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wrist circumference approximately between 13.5 and 23 cm, includes the inflatable bladder and nylon shell. The device consists of the microprocessor, the pressure sensor, the operation keys, the pump and the electromagnetic deflation control valve. The subject device is powered by 3.7V Built-in rechargeable lithium-ion battery. The device also compares the longest and the shortest time intervals of detected pulse waves to mean time interval and displays a warning signal with the reading to indicate the detection of irregular heartbeat when the difference of the time intervals is over 25%. Transtek Wrist Blood Pressure Monitor TMB-2072 embeds a Bluetooth module that allows it to connect to nearby BT receiving end. The mobile application displays results. And once measurement is over, the device will start transmission data by BT. Thus, users can receive, and display/storage, measurement data from TMB-2072 unit through their end devices that embedded BT module.
Intended use & Indication for use 6.
The Transtek Blood Pressure Monitor is a digital monitor intended for use in measuring blood pressure and heartbeat rate with a wrist circumference ranging from 13.5cm to 23 cm. It is intended for adult indoor use only.
| Features | Subject DeviceTMB-2072 | Predicate Device K123669Model: TMB-1014-BT | Remark |
|---|---|---|---|
| Applicant | Guangdong Transtek MedicalElectronics Co., Ltd. | Guangdong Transtek MedicalElectronics Co., Ltd. | / |
| ClassificationRegulation | 21CRF 870.1130 | 21CRF 870.1130 | Same |
| Classificationand Code | Class II,DXN | Class II,DXN | Same |
| Commonname | Automatic Arm Blood PressureMonitor | Automatic Arm Blood PressureMonitor | Same |
| Intended use | The Transtek Blood PressureMonitor is a digital monitorintended for use in measuringblood pressure and heartbeat ratewith a wrist circumferenceranging from 13.5cm to 23 cm.It is intended for adult indoor useonly. | Transtek Wrist Blood PressureMonitor TMB-1014-BT is adigital monitor intended for use inmeasuring blood pressure andheartbeat rate in adult patientpopulation with wristcircumferenceranging from 13.5 cm to 21.5 cm(about 5 1/4-S8 1/2 inches).This device detects theappearance of irregular heartbeatsduring measurement and gives awarning | Different1) |
| Features | Subject DeviceTMB-2072 | Predicate Device K123669Model: TMB-1014-BT | Remark |
| signal with readings.The Wrist Blood PressureMonitor compares average bloodpressure results to pre-establishedAHA (American HeartAssociation) hypertensionguideline of 135/85 mmHg.Transtek Wrist Blood PressureMonitor, TMB-1014-BT is notintended to be a diagnosticdevice. Contact your physician ifhypertensive values are indicated. | |||
| Principle | Oscillometric method | Oscillometric method | Same |
| Targetpopulation | Adult | Adult | Same |
| Anatomical sites | Wrist | Wrist | Same |
| Where used(hospital, home,ambulance, etc.) | Home | Home | Same |
| Energy used and/ or delivered | 3.7V 420mAH Built-inrechargeable lithium-ion battery,5V 1A USB AC Adaptor | 2 × 1.5V AA Battery | Different2) |
| Human factors | Blood pressure | Blood pressure | Same |
| Performance | Measuring systolic and diastolicblood pressure and pulse rate ofadult individual, Includingirregular pulse rhythm detection | Measuring systolic and diastolicblood pressure and pulse rate ofadult individual, Includingirregular pulse rhythm detection | Same |
| Biocompatibility | Cuff, according to ISO-10993 | Cuff, according to ISO-10993 | Same |
| Compatibilitywith theenvironment andother devices | Operation Environment:5°C~40°C,15% | Operation Environment:5°C~40°C,15% | Same |
| Electrical safety | According to IEC60601-1-2According to IEC60601-1 | According to IEC60601-1-2According to IEC60601-1 | Same |
| Blood PressureMeasurement | 0mmHg-299mmHg, ±3mmHg | 0mmHg-300mmHg, ±3mmHg | Different3) |
| Pulse ratemeasurement | 40-199 beats/minute, ±5% | 40-199 beats/minute, ±5% | Same |
| Cuff Deflation | Automatic deflation | Automatic deflation | Same |
| Features | Subject DeviceTMB-2072 | Predicate Device K123669Model: TMB-1014-BT | Remark |
| Wireless | Bluetooth | Bluetooth | Same |
7. Comparison to the Predicate Device
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Justification of difference:
Different 1): The wrist circumference is different. The clinical study of blood pressure can demonstrate the subject device can meet the requirement on this wrist range. The clinical study was conducted by ISO 81060-2. So, the different does not raise different questions of safety and effectiveness.
Different 2): The power supply is different. The subject device was tested accordance with IEC 60601-1. The clinical study can demonstrate the subject device can meet the requirement on this power supply. So, the different does not raise different questions of safety and effectiveness.
Different 3): The subject device's blood pressure is restricted to 299 mmHg for safety purpose. So, the different does not raise different questions of safety and effectiveness.
8. Performance Data
The following performance data were provided in support of the substantial equivalence determination.
Biocompatibility testing
The biocompatibility evaluation for the subject device was conducted in accordance with the FDA Guidance for Industry and Food and Drug Administration Staff: Use of International Standard ISO 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process". The battery of testing included the following tests:
- Cytotoxicity .
- . Sensitization
- Irritation .
The subject device is considered surface contacting for a duration of not exceed 24 hours.
Non-clinical data
The subject device has been tested according to the following standards:
- IEC 60601-1: Medical Electrical Equipment - Part 1: General Requirements for Basic Safety and essential performance
- 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
- IEC 80601-2-30: Medical electrical equipment - Particular requirements for the basic safety and essential performance of automated non-invasive sphygmomanometers.
- IEC 60601-1-11: Medical electrical equipment -- Part 1-11: General requirements for basic safety and essential performance -- Collateral standard: Requirements for medical electrical equipment and medical electrical systems used in the home healthcare environment
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- IEC 60601-1-6: Medical Electrical Equipment Part 1-6: General requirements for safety -● Collateral Standard: Usability.
- IEC 62366-1: Medical devices – Application of usability engineering to medical devices.
- FDA Guidance for Non-Automated Sphygmomanometer.
Wireless testing:
- Bluetooth test according to FCC CFR Title 47 Part 15 Subpart C.
- ANSI C63.27L: 2017: American National Stand for Evaluation of Wireless Coexistence.
- AAMI TIR69: 2017 Risk management of radio-frequency wireless coexistence for medical devices and systems.
- Radio Frequency Wireless Technology in Medical Devices: Guidance for Industry and Food and Drug Administration Staff (August 14, 2013)
Reprocessing validation:
- AAMI TIR12: 2010-designing, testing, and labeling reusable medical devices for reprocessing in health care facilities: A guide for medical device manufactures
- AAMI TIR30: 2011-A compendium of processes, materials, test methods, and acceptance criteria for cleaning reusable medical devices
- Reprocessing Medical Devices in Health Care Settings: Validation Methods and Labeling: Guidance for Industry and Food and Drug Administration Staff
Clinical data
This device was tested to ISO 81060-2: 2018 Non-invasive sphygmomanometers - Part 2: Clinical validation of automated measurement type. The study population consisted of 85 qualified healthy adult subjects. All data's mean error and standard deviation of differences for systolic, diastolic pressure is not over the limits of ISO 81060-2: 2018, and the accuracy of subject device is better than predicate device. No adverse effect and/or complication is found in this study.
9. Conclusion
It has been shown in this 510(k) submission that the difference between the proposed devices and the predicate devices do not raise any questions regarding safety and effectiveness. Performance testing and compliance with voluntary standards demonstrate that the proposed are substantially equivalent to the relevant aspects of the predicate devices in terms of design, components, materials, principals of operation, biocompatibility, performance characteristics, and intended use.
§ 870.1130 Noninvasive blood pressure measurement system.
(a)
Identification. A noninvasive blood pressure measurement system is a device that provides a signal from which systolic, diastolic, mean, or any combination of the three pressures can be derived through the use of tranducers placed on the surface of the body.(b)
Classification. Class II (performance standards).