K Number
K020399
Device Name
RESPERATE; MODEL RR-150
Manufacturer
Date Cleared
2002-07-02

(146 days)

Product Code
Regulation Number
882.5050
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The RESPeRATE is intended for use as a relaxation treatment for the reduction of stress by leading the user through interactively guided and monitored breathing exercises. The device is indicated for use only as an adjunctive treatment for high blood pressure, together with other pharmacological and/or non-pharmacological interventions.
Device Description
Biofeedback Device
More Information

Not Found

No
The summary describes a biofeedback device for guided breathing exercises and does not mention AI or ML.

Yes

The device is indicated as an "adjunctive treatment for high blood pressure" and clinical studies demonstrated a "clinically significant, reduction in high blood pressure," indicating a direct therapeutic effect.

No

The device is described as a "relaxation treatment" for stress reduction and an "adjunctive treatment for high blood pressure," not for diagnosing any condition.

No

The device description is "Biofeedback Device," which typically implies hardware components to measure physiological signals. The summary does not explicitly state it is software-only.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is described as a "relaxation treatment for the reduction of stress by leading the user through interactively guided and monitored breathing exercises" and as an "adjunctive treatment for high blood pressure." This involves interacting with the user and guiding a physiological process (breathing) for therapeutic purposes.
  • Device Description: It's described as a "Biofeedback Device." Biofeedback devices typically measure physiological signals and provide feedback to the user to help them learn to control those signals.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples (blood, urine, tissue, etc.) or providing diagnostic information based on such analysis. IVDs are designed to examine specimens derived from the human body to provide information for diagnosis, monitoring, or screening.

The RESPeRATE device is clearly focused on a therapeutic intervention (guided breathing for stress reduction and blood pressure management) rather than diagnostic testing.

N/A

Intended Use / Indications for Use

The RESPeRATE is intended for use as a relaxation treatment for the reduction of stress by leading the user through interactively guided and monitored breathing exercises. The device is indicated for use only as an adjunctive treatment for high blood pressure, together with other pharmacological and/or non-pharmacological interventions.

Product codes (comma separated list FDA assigned to the subject device)

HCC

Device Description

Not Found

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Clinical testing in the OTC setting has shown that the RESPeRATE device can be properly used without the direction of a physician. This difference in the specific indications for use of the RESPeRATE (for OTC use) compared to the predicate (for prescription use), however, does not raise new questions of safety or efficacy and does not alter its therapeutic effect. Moreover, the clinical study demonstrated a safe, clinically significant, reduction in high blood pressure with use of the RESPeRATE over a period of 8 weeks without the guidance of a physician.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K000495

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 882.5050 Biofeedback device.

(a)
Identification. A biofeedback device is an instrument that provides a visual or auditory signal corresponding to the status of one or more of a patient's physiological parameters (e.g., brain alpha wave activity, muscle activity, skin temperature, etc.) so that the patient can control voluntarily these physiological parameters.(b)
Classification. Class II (special controls). The device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter when it is a prescription battery powered device that is indicated for relaxation training and muscle reeducation and prescription use, subject to § 882.9.

0

020399 1/2

ATTACHMENT 9

510(k) Summary For The InterCure Ltd. RESPeRATE

Submitter's Name, Address, Telephone Number, and Contact Person

ﺴﺮ

InterCure Ltd. 9 Hamelacha st. Kislev building Northern Industrial area, Lod, 71520 Israel

| Contact: | Dr. Benjamin Gavish
Chief Scientist, InterCure Ltd |
|------------|-------------------------------------------------------|
| Phone: | 972-8-9212126 |
| Facsimile: | 972-8-9204001 |
| Email: | bgavish@intercure.com |

Date Prepared: January 2002

Name of the Device

RESPeRATE

Common or Usual Name

Biofeedback Device

Predicate Device

Respi-Low Model RL-108 (K000495) manufactured by InterCure Ltd .;

Intended Use

The RESPeRATE is intended for use as a relaxation treatment for the reduction of stress by leading the user through interactively guided and monitored breathing exercises. The device is indicated for use only as an adjunctive treatment for high blood pressure, together with other pharmacological and/or non-pharmacological interventions.

1

Summary of the Basis for the Finding of Substantial Equivalence

The RESPeRATE is substantially equivalent to InterCure's previously cleared Respi-Low biofeedback device (K000495) for use in stress reduction and adjunctive treatment to reduce blood pressure. The device shares the same general intended use in relaxation and/or stress reduction and the same indications for use except for OTC use. Moreover, the principles of operation are identical to the predicate device and there are only minor differences in technological characteristics. Clinical testing in the OTC setting has shown that the RESPeRATE device can be properly used without the direction of a physician. This difference in the specific indications for use of the RESPeRATE (for OTC use) compared to the predicate (for prescription use), however, does not raise new questions of safety or efficacy and does not alter its therapeutic effect. Moreover, the clinical study demonstrated a safe, clinically significant, reduction in high blood pressure with use of the RESPeRATE over a period of 8 weeks without the guidance of a physician. Therefore, the devices are substantially equivalent.

2

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2

Image /page/2/Picture/1 description: The image shows the logo for the Department of Health & Human Services USA. The logo features a stylized representation of a human figure with three profiles overlapping each other. The profiles are arranged in a way that creates a sense of depth and continuity. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" is arranged in a circular fashion around the figure.

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

JUL = 2 2002

InterCure LTD. c/o Jonathan S. Kahan Hogan and Hartson, L.L.P. 555 13th Street, N.W. Washington, D.C. 20004-1109

Re: K020399 Trade Name: RESPeRATE Regulation Number: 882.5050 Regulation Name: Biofeedback device Regulatory Class: II Product Code: HCC Dated: May 9, 2002 Received: May 9, 2002

Dear Mr. Kahan:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and we have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to 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.

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.

3

Page 2 -- Mr. Jonathan S. Kahan

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) 594-4659. 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,

Celia M. Witten, Ph.D., M.D.
Director

Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

4

510(k) Number (if known):_ K 020 399

Device Name: InterCure Ltd. RESPeRATE

Indications for Use:

The RESPeRATE is intended for use as a relaxation treatment for the reduction of stress by leading the user through interactively guided and monitored breathing exercises. The device is indicated for use only as an adjunctive treatment for high blood pressure, together with other pharmacological and/or non-pharmacological interventions.

(PLEASE DO NOT WRITE BELOW THIS LINE -- CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

Prescription Use

OR

Over-The-Counter Use X

(Per 21 C.F.R. 801.109) (Optional Format 1-2-96)

Hyatt Murda

(Division Sign-Off) Division of General, Restorative and Neurological Devices

KOZO3999 510(k) Number_