K Number
K051007
Device Name
ACCU02 SYSTEM
Manufacturer
Date Cleared
2005-06-16

(57 days)

Product Code
Regulation Number
868.5905
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The AccuO2 System, which provides oxygen therapy on demand, based on continuous, non-invasive monitoring of oxygen saturation, is indicated for home use by adult Chronic Obstructive Pulmonary Disease (COPD) patients who are prescribed low-flow (0-3 L/min) supplemental oxygen via nasal cannula and USP portable oxygen.
Device Description
The AccuO2 System is a portable, battery-operated system consisting of a proprietary demand oxygen delivery module combined with a commercially available pulse oximeter module. The system is used with a standard nasal cannula and USP portable oxygen. The proprietary software in the AccuO2 demand oxygen delivery module is designed to deliver oxygen on inhalation only and to maintain the patients at an oxygen saturation (SpO2) level of 90% while conserving oxygen.
More Information

Not Found

No
The summary describes a system that uses a pulse oximeter to monitor oxygen saturation and a proprietary software to deliver oxygen on inhalation and maintain a target SpO2 level. There is no mention of AI, ML, or any learning algorithms. The system appears to be based on pre-programmed logic and sensor feedback rather than adaptive or learning technology.

Yes
It delivers oxygen therapy on demand to maintain oxygen saturation levels, which directly treats a medical condition.

No.
The description indicates that the system provides oxygen therapy based on monitoring oxygen saturation, but its primary function is to deliver oxygen, not to diagnose a condition. The pulse oximeter module is used for monitoring, which is part of the therapy delivery, not diagnosis.

No

The device description explicitly states the system consists of a "proprietary demand oxygen delivery module combined with a commercially available pulse oximeter module," indicating it includes hardware components beyond just software.

Based on the provided information, the AccuO2 System is not an In Vitro Diagnostic (IVD).

Here's why:

  • IVDs are used to examine specimens derived from the human body. The AccuO2 System directly interacts with the patient (via nasal cannula and pulse oximeter) to monitor oxygen saturation and deliver oxygen. It does not analyze blood, urine, tissue, or any other bodily fluid or substance in vitro (outside the body).
  • The intended use is for oxygen therapy and monitoring. The system's purpose is to provide supplemental oxygen and monitor the patient's oxygen levels in real-time, not to diagnose a condition based on laboratory analysis of a specimen.
  • The device description focuses on oxygen delivery and monitoring components. The description details a demand oxygen delivery module and a pulse oximeter module, both of which are used for direct patient interaction and therapy, not for in vitro testing.

The AccuO2 System is a medical device used for patient monitoring and therapy, specifically oxygen delivery and saturation monitoring.

N/A

Intended Use / Indications for Use

The AccuO2 System, which provides oxygen therapy on demand, based on continuous, non-invasive monitoring of oxygen saturation, is indicated for home use by adult Chronic Obstructive Pulmonary Disease (COPD) patients who are prescribed low-flow (0-3 L/min) supplemental oxygen via nasal cannula and USP portable oxygen.

Product codes

NFB

Device Description

The AccuO2 System is a portable, battery-operated system consisting of a proprietary demand oxygen delivery module combined with a commercially available pulse oximeter moduleᵃ. The system is used with a standard nasal cannula and USP portable oxygen. The proprietary software in the AccuO2 demand oxygen delivery module is designed to deliver oxygen on inhalation only and to maintain the patients at an oxygen saturation (SpO2) level of 90% while conserving oxygen.

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

adult

Intended User / Care Setting

home use

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)

Functional testing included verification of the AccuO2 System's ability to accurately and reliably detect each inhaled breath, and actuate the valve correctly, as well as verification of the accuracy of the pulse oximeter readings and oxygen amount calculations when used with the system. Clinical testing was conducted to evaluate the ability to maintain patients at or above 90% SpO2 as designed.
In addition, all functional, environmental and safety testing performed on the device demonstrated that it met its performance objectives and complies with applicable FDA guidelines and standards.
Conclusion: The bench studies verified that the AccuO2 System works as designed with back-up safety features functioning correctly. Furthermore, clinical studies demonstrated the AccuO2 maintains patients at or above a pre-set oxygenation level. Clinical studies also showed the Accu02 does not increase the amount of time the patient spends in an hypoxic state when compared to commercially available devices. Finally, as part of the AccuO2 system, the pulse oximeter functions in a manner equivalent to commercially available pulse oximeters in sensing oxygen levels in patients.
Clinical data demonstrate that the AccuO2 System is substantially equivalent to previously cleared devices and raises no new questions of safety and efficacy over commercially available oxygen conserving systems.

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

Not Found

Predicate Device(s)

Not Found

Reference Device(s)

K021138, K982776, K970763

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 868.5905 Noncontinuous ventilator (IPPB).

(a)
Identification. A noncontinuous ventilator (intermittent positive pressure breathing-IPPB) is a device intended to deliver intermittently an aerosol to a patient's lungs or to assist a patient's breathing.(b)
Classification. Class II (performance standards).

0

JUN 16 2005

K051007

11

SECTION 2. SUMMARY AND CERTIFICATION

510(k) Summary A.

Submitter:MITI Corp.
Contact Person:Matthew F. Schmidt, Ph.D.
MITI Corp.
738 Country Lakes Drive
Lino Lakes, MN 55014
Phone: 651-592-8493
Fax: 952-826-0876
Date Prepared:April 19, 2005
Trade Name:MITI Corp. AccuO2 System
Classification Name:
and Number:Class II, 21 CFR 868.5905
Product Code:NFB
Predicate Device(s):The AccuO2™ Pulse Oximeter and Demand Oxygen
Delivery System is substantially equivalent to the Pulse
Dose Series Oxygen Conserving device manufactured by
DeVilbiss Health Care, Inc. and the Model 8500A Pulse
Oximeter, manufactured by Nonin® Medical, Inc.).
Device Description:The AccuO2 System is a portable, battery-operated system
consisting of a proprietary demand oxygen delivery module
combined with a commercially available pulse oximeter
moduleᵃ. The system is used with a standard nasal cannula
and USP portable oxygen. The proprietary software in the
AccuO2 demand oxygen delivery module is designed to
deliver oxygen on inhalation only and to maintain the
patients at an oxygen saturation (SpO2) level of 90% while
conserving oxygen.
Intended Use:The AccuO2 System, which provides oxygen therapy on
demand based on continuous, non-invasive monitoring of
oxygen saturation, is indicated for home use by adult

4 Pulse oximeter module from Nonin Medical, and is the same as the pulse oximeter module used in the following FDA-cleared devices: Sleep Screen/ApnoeScreen Cardio manufactured by Erich Jaeger GmbH (K021138); Model 9303 Neonatal/Adult Vital Signs Monitor, manufactured by CAS Medical (K982776); and the MTS Option for the ESCORT II Monitor manufactured by Medical Data Electronics (K970763).

Premarket Notification (510(k)) for the AccuO2 System CONFIDENTIAL

1

COPD patients who are prescribed low-flow (0-3 L/min) supplemental oxygen via nasal cannula and USP portable oxygen.

Functional testing included verification of the AccuO2 System's ability to accurately and reliably detect each inhaled breath, and actuate the valve correctly, as well as verification of the accuracy of the pulse oximeter readings and oxygen amount calculations when used with the system. Clinical testing was conducted to evaluate the ability to maintain patients at or above 90% SpO2 as designed.

In addition, all functional, environmental and safety testing performed on the device demonstrated that it met its performance objectives and complies with applicable FDA guidelines and standards.

Conclusion: The bench studies verified that the AccuO2 System works as designed with back-up safety features functioning correctly. Furthermore, clinical studies demonstrated the AccuO2 maintains patients at or above a pre-set oxygenation level. Clinical studies also showed the Accu02 does not increase the amount of time the patient spends in an hypoxic state when compared to commercially available devices. Finally, as part of the AccuO2 system, the pulse oximeter functions in a manner equivalent to commercially available pulse oximeters in sensing oxygen levels in patients.

Clinical data demonstrate that the AccuO2 System is substantially equivalent to previously cleared devices and raises no new questions of safety and efficacy over commercially available oxygen conserving systems.

MITI Corp.

WDC - 86138/0001 - 2102849 v1

Functional and

Safety Testing:

2

Image /page/2/Picture/1 description: The image shows the seal of the U.S. Department of Health and Human Services. The seal features a stylized eagle with three stripes representing the three branches of government. The eagle is surrounded by the words "DEPARTMENT OF HEALTH AND HUMAN SERVICES, USA" in a circular arrangement. The image is in black and white.

Public Health Service

JUN 16 2005

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

MITI Corporation C/O Mr. Jonathan S. Kahan Hogan & Hartson L.L.P. 555 13th Street, NW Washington, DC 20004-1109

Re: K051007

Trade/Device Name: AccuO2 System Regulation Number: 868.5905 Regulation Name: Noncontinuous Ventilator (IPPB) Regulatory Class: II Product Code: NFB Dated: April 19, 2005 Received: April 21, 2005

Dear Mr. Kahan:

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

3

Page 2 - Mr. Kahan

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). please contact the Office of Compliance at (240) 276-0120. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). You may obtain other general information on your responsibilities under the Act 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/industry/support/index.html.

Sincerely yours.

Suite Marian Ones

Chiu Lin, Ph.D. Director Division of Anesthesiology, General Hospital, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

4

INDICATIONS FOR USE PAGE

Device Name: AccuO2 System

Indications for Use:

The AccuO2 System, which provides oxygen therapy on demand, based on continuous, non-invasive monitoring of oxygen saturation, is indicated for home use by adult Chronic Obstructive Pulmonary Disease (COPD) patients who are prescribed low-flow (0-3 L/min) supplemental oxygen via nasal cannula and USP portable oxygen.

Prescription Use X (Part 21 CFR 801 Subpart D) AND/OR

Over-The-Counter Use (21 CFR 807 Subpart C)

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

Mitchel Vahdat

(Division Sign-Off) Division of Anesthesiology, General Hospital, Infection Control, Dental Devices

510(k) Number:

MITI Corp.

Premarket Notification (510(k)) for the AccuO2 System CONFIDENTIAL