K Number
K013123
Date Cleared
2002-03-14

(176 days)

Product Code
Regulation Number
868.1840
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

For use with pulmonary function testing. To filter air between the patient's exhaled air and the testing equipment. Single patient use.

Device Description

The EMS PFT Filter is acompact, electrostatic filter with various end-fitting adaptable to various pulmonary function testing circuits. It has 75 ml deadspace and resistance of 07. cm H2O at 720 Ipm per ATS spirometry or 0.5 cm I-120 @ 60 lpm. There are various connectors to allow connection to various PFT equipment. Single patient use.

AI/ML Overview

The provided text describes a Premarket Notification 510(k) for the EMS PFT Filter. This type of submission is for demonstrating substantial equivalence to a predicate device, not typically for reporting on a study that establishes performance against predefined acceptance criteria for a novel device.

However, the document does list performance attributes for the EMS PFT Filter and compares them to those of a predicate device (PDS KoKo K934475), which can be interpreted as demonstrating that the EMS device meets performance levels comparable to a legally marketed device.

Here's an attempt to structure the information according to your request, with the understanding that this is a 510(k) submission, and the "study" is more of a comparison against a predicate, rather than a de novo clinical trial with specific acceptance criteria.


1. Table of Acceptance Criteria and Reported Device Performance

Given this is a 510(k) for substantial equivalence, the "acceptance criteria" are derived from the performance of the predicate device. The EMS PFT Filter is considered acceptable if its performance is comparable to or better than the predicate's.

AttributeAcceptance Criteria (Predicate Device K934475)Reported Device Performance (EMS PFT Filter Model #5813)
Intended useFor use with pulmonary function testing. To filter air between the patient's exhaled air and the testing equipment.Same
Intended for single patientYesYes
PrescriptionYesYes
Intended populationAny patientSame
Intended Environment of UseHospital, sub-acuteSame
Can be used with several different PFT machinesYesYes
Design Features - Compact housingYesYes
Design Features - Various end-fittingsYesYes
Dead Space (ml)60 ml75 ml
Resistance to flow at 720 lpm (per ATS standard for spirometry)<1.5 cm H2O0.7 cm H2O
Resistance to flow at 60 lpm<1.5 cm H2O0.5 cm H2O
Bacterial filtration99.99+%99.9999%
Viral filtration99.99+%99.999+%
Housing materialPolystyrenePolystyrenc
Filter mediaElectrostatic polypropyleneElectrostatic polypropylene

Note on Differences: The dead space of the EMS PFT Filter (75 ml) is higher than that of the predicate (60 ml). However, the resistance to flow (0.7 cm H2O at 720 lpm and 0.5 cm H2O at 60 lpm) is better (lower) than the predicate's criteria of <1.5 cm H2O. The bacterial and viral filtration efficiencies are also better (higher) for the EMS filter. The document states, "There are no significant differences between the intended device and the predicates." This implies that the differences observed (like dead space, which is only slightly higher, and improved filtration/resistance) are not considered clinically significant enough to preclude substantial equivalence.

2. Sample Size Used for the Test Set and Data Provenance

The document does not describe a traditional "test set" in the context of a clinical trial or algorithm validation. The performance data presented (e.g., dead space, resistance, filtration efficiency) are typically derived from laboratory testing of the device itself.

  • Sample size: Not specified. It would usually involve testing a certain number of manufactured units to ensure consistency, but this is not detailed in the summary.
  • Data provenance: The data would originate from bench testing performed by the manufacturer, Engineered Medical Systems, Inc. The country of origin is implied to be the USA (Indianapolis, IN). The data is prospective in the sense that it's generated for the device being submitted, but not from a prospective patient study.

3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications

Not applicable. For a medical device like a PFT filter, "ground truth" for its physical performance (like filtration efficacy or resistance) is established through standardized engineering and microbiological testing methods, not by expert consensus on clinical data.

4. Adjudication Method for the Test Set

Not applicable. As described in point 3, this type of device performance is measured objectively through specified tests, not through expert adjudication of images or clinical outcomes.

5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

No. An MRMC study is relevant for diagnostic imaging or AI algorithms where human readers interpret cases. This device is a passive filter; its performance is measured mechanistically, not through human interpretation.

6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done

Not applicable. This device is a physical filter, not an algorithm or AI system.

7. The Type of Ground Truth Used

The "ground truth" for the performance metrics (e.g., bacterial/viral filtration, resistance, dead space) is established by standardized laboratory testing methods against established industry or regulatory standards (e.g., ATS spirometry standards mentioned for resistance). These are objective physical measurements.

8. The Sample Size for the Training Set

Not applicable. There is no "training set" as this is not an AI/machine learning device.

9. How the Ground Truth for the Training Set Was Established

Not applicable. There is no training set.

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Premarket Notification 510(k)

Section 2 - Certifications and Summaries

MAR 1 4 2002

EMS PFT Filtcr

1013123

Engincered Medical Systems, Inc. 2055 Executive Dr. Indianapolis, IN 46241

Non-Confidential Summary of Safety and Effectiveness

Page i of 2 March 7, 2002

EMSTel (317) 246-5500
2055 Executive Dr.Fax (317) 246-5501
Indianapolis, IN 46241
Official Contact:Bonnic Holly - Quality Manager
Proprietary or Trade Name:EMS Pulmonary Function Testing Filter
Common/Usual Name:PFT filter
Classification Name:Filter, Bacterial, Breathing Circuit
Predicate Devices:Pulmonary Data Services - KoKo – K934475

Device Description:

The EMS PFT Filter is acompact, electrostatic filter with various end-fitting adaptable to various pulmonary function testing circuits. It has 75 ml deadspace and resistance of 07. cm H2O at 720 Ipm per ATS spirometry or 0.5 cm I-120 @ 60 lpm. There are various connectors to allow connection to various PFT equipment. Single patient use.

Intended Use:
Indicated Use --For use with pulmonary function testing. To filterair between the patient's exhaled air and the testingequipment. Single patient use.
Environment of Use --Hospital, Sub-acute Institutions

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Non-Confidential Summary of Safety and Effectiveness

Page 2 of 2

March 7, 2002

Comparison to Predicate Devices:

EMS Proposed deviceFilter - Model # 5813Predicate PDS KoKoK934475
Attribute
Intended useFor use with pulmonary functiontesting. To filterair between the patient's exhaledair and the testingequipmentSame
Intended for single patientYesYes
PrescriptionYesYes
Intended populationAny patientSame
Intended Environment of UseHospital, sub-acuteSame
Can be used with severaldifferent PFT machinesYesYes
Design Features
Compact housingYesYes
Various end-fittingsYesYes
Dead Space (ml)75 ml60 ml
Resistance to flow at 720 lpmper ATS standard forspirometry0.7 cm H2O<1.5 cm H2O
Resistance to flow at 60 lpm0.5 cm H2O<1.5 cm H2O
Bacterial filtration99.9999%99.99+%
Viral filtration99.999+%99.99+%
Weight40 gmN/A
Materials
Housing polystyrencYesYes
Filter mediaElectrostatic polypropyleneElectrostatic polypropylene
Performance
None under Section 514YesYes

Differences between Other Legally Marketed Predicate Devices

There are no significant differences between the intended device and the predicates -- PDS -- Koko K934475.

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Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle with its wings spread, and three horizontal bars below the eagle. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular fashion around the eagle.

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

MAR 1 4 2002

Mr. Paul Dryden Engineered Medical Systems c/o ProMedic, Inc. 6329 W. Waterview Court McCordsville, IN 46055-9501

Re: K013123

Pulmonary Function Testing Filter Regulation Number: 868.1840 Regulation Name: Diagnostic Spirometer Regulatory Class: II (two) Product Code: BZG Dated: December 14, 2001 Received: December 17, 2001

Dear Mr. Dryden:

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. 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.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such 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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Page 2 - Mr. Paul Dryden

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); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 21 CFR Part 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4646. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html

Sincerely yours,

Bram D. Zuckerman, M.D.

Acting Director Division of Cardiovascular and Respiratory Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Premarket Notification 510(k) Section 2 - Certifications and Summaries

adications for Use

EMS Pulmonary Function Filter

Page 1 of 1

(To be assigned) K013123

Device Name:

510(k) Number:

Intended Use:

For use with pulmonary function testing. To filter air between the patient's cxhaled air and the testing equipment.

Single patient use.

Concurrence of CDRH, Office of Device Evaluation (ODE)

Division of Cardiovascular & Respiratory Devices
510(k) Number K013123

Prescription Use - XX
(Per CFR 801.109)

or

Over-the-counter use _________________________________________________________________________________________________________________________________________________________

§ 868.1840 Diagnostic spirometer.

(a)
Identification. A diagnostic spirometer is a device used in pulmonary function testing to measure the volume of gas moving in or out of a patient's lungs.(b)
Classification. Class II (performance standards).