(125 days)
The Oxygen Concentrators are indicated for the delivery of supplemental oxygen in the home or medical institutions. The devices are not intended for life support nor do they provide any patient monitoring capabilities.
The Merits Health Products Oxygen Concentrators are prescription devices designed to provide an inexpensive supply of supplemental oxygen in a home or institution without a continuous source of purified oxygen. They are not for life-supporting nor life-sustaining devices. The devices operate through the use of molecular sieve material that binds with the water and nitrogen in filtered room air to leave a gas that is approximately 93% oxygen when delivered to the patient. The compressor creates a vacuum to draw room air into a holding tank. At the same time, downstream of the compressor, the air from the previous cycle is pressurized into first chamber of the dual-chambers aluminum extruded molecular sieve tank. As the oxygen is forced out of the end of the first chamber and then enters the Oxygen tank for patient use. As the remaining Oxygen flush the nitrogen out of the first molecular sieve chamber into the ambient air, the air is directed into the second molecular sieve chamber and continuing the supply to the patient. This repetitive cycle generates the oxygen necessary to flush and prepare the saturated sieve tank while supplying the patient with a continuous flow of high concentration oxygen. Optional oxygen-driven-nebulizer is provided for patients who are prscribed for oxygen aerosol therapy by physician, using higher purity oxygen to drive a nebulizer while oxygen therapy is being undertaken. Optional oxygen-driven-nebulizer allows a single wnit to meet the different needs of oxygen or oxygen-aerosol therapy patients. This submission covers a model that will have a maximum output of 10-liters per minute as compared to the currently marketed model. Options will include an Oxygen alarm, pediatric flowmeter and nebulizer.
The provided text describes a 510(k) submission for the Merits Health Products Oxygen Concentrators. This type of submission focuses on demonstrating substantial equivalence to a predicate device, rather than proving novel clinical effectiveness through extensive studies with acceptance criteria and statistical analysis typical of new drug or high-risk device approvals. Therefore, the information requested in the prompt, particularly regarding acceptance criteria, sample sizes, expert ground truth, adjudication, and MRMC studies, is largely not applicable or not present in this document.
Here's an analysis based on the available information:
1. A table of acceptance criteria and the reported device performance
The document states: "The results of the testing confirm that the device meets specifications and is substantially equivalent to the predicate device." However, specific acceptance criteria (e.g., oxygen purity within a certain range at specific flow rates) and a detailed table of measured performance against these criteria are not provided in this summary. The assessment of equivalence is based on "design, performance specifications, testing and intended use."
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
The document does not mention a "test set" in the context of clinical data or human subjects. The testing performed would likely have been engineering and performance testing on the device itself (e.g., oxygen purity, flow rate, pressure, noise levels, internal component specifications). Details about the sample size of devices tested or the provenance of any data beyond the general manufacturing location (Taichung, Taiwan R.O.C.) are not provided. This was likely internal validation testing.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
This concept is not applicable to this type of device and submission. "Ground truth" established by experts is typically for diagnostic imaging devices or other medical technologies where human interpretation or a gold standard diagnosis is involved. For an oxygen concentrator, the "ground truth" would be objective measurements of its physical performance parameters.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This is not applicable as there is no mention of a human-interpreted "test set" or diagnostic assessment requiring adjudication.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
An MRMC study is not applicable here. This type of study is relevant for AI-powered diagnostic tools or imaging interpretation software where multiple human readers assess cases with and without AI assistance. This device is an oxygen concentrator, not a diagnostic AI tool.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This is not applicable as the device is a physical medical device (an oxygen concentrator), not an algorithm or AI system.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
For an oxygen concentrator, the "ground truth" for performance would be objective engineering measurements of parameters such as:
- Oxygen purity (%)
- Flow rate (LPM)
- Output pressure
- Noise levels
- Power consumption
- Alarm functionality (e.g., low oxygen purity alarm)
These would be measured using calibrated equipment according to industry standards. The document states "The results of the testing confirm that the device meets specifications," implying these types of objective measurements were performed.
8. The sample size for the training set
This is not applicable. "Training set" refers to data used to train machine learning models. This device is not an AI/ML product.
9. How the ground truth for the training set was established
This is not applicable as there is no training set for an AI/ML model.
Summary of Device Performance (Based on Substantial Equivalence Claim):
The document does not provide specific numerical performance data against acceptance criteria. Instead, it makes a general statement of compliance and substantial equivalence:
- Claim: "The results of the testing confirm that the device meets specifications and is substantially equivalent to the predicate device."
- Basis for Substantial Equivalence:
- Key Performance Area (Implicit): The device is intended to provide "supplemental oxygen up to 10 LPM" with an oxygen purity of "approximately 93%." The testing would have verified these parameters against the predicate devices or established specifications.
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SUMMARY OF SAFETY AND EFFECTIVENESS 9.0
"510(k) SUMMARY"
9.1 Submitter: Steve Chao Merits Health Products Co., LTD. 9, Road 36, Taichung Industrial Park Taichung, Taiwan R.O.C. Tel: 886-4-2359-4985 ext. 240 Fax: 886-4-2359-4992 E-mail: stevechao@merits.com.tw
Prepared - March 1, 2005
- 9.2 Trade/Proprietary Name:
- વે 3 Common/Usual Name:
- 9.4 Classification Name:
- Merits Health Products Oxygen Concentrators Oxyqen Concentrator
- Oxygen Generator
- 9.5 Comparison to Currently Marketed Devices
The modified 10-liter Merits Health Products Oxygen Concentrators are substantially equivalent to the currently marketed 5-liter Merits Health Products Oxygen Concentrators (K011844) in main structure. And the functions are substantially equivalent to the 10-liter INTEGRA OXYGEN CONCENTRATOR, MODEL 6323A-OM-10 (K042262). The oxygen driven nebulizer option are substantially equivalent to the currently marketed 5-liter AIRSEP NEWLIFE AIR OUTLET OPTION (K944020) which incorporates a nebulizer with concentrator. The equivalence is supported by the attached documentation.
9.6 Device Description
The Merits Health Products Oxygen Concentrators are prescription devices designed to provide an inexpensive supply of supplemental oxygen in a home or institution without a continuous source of purified oxygen. They are not for life-supporting nor life-sustaining devices. The devices operate through the use of molecular sieve material that binds with the water and nitrogen in filtered room air to leave a gas that is approximately 93% oxygen when delivered to the patient. The compressor creates a vacuum to draw room air into a holding tank. At the same time, downstream of the compressor, the air from the previous cycle is pressurized into first chamber of the dual-chambers aluminum extruded molecular sieve tank. As the oxygen is forced out of the end of the first chamber and then enters the Oxygen tank for patient use. As the remaining Oxygen flush the nitrogen out of the first molecular sieve chamber into the ambient air, the air is directed into the second molecular sieve chamber and continuing the supply to the patient. This repetitive cycle generates the oxygen necessary to flush and prepare the saturated sieve tank while supplying the patient with a continuous flow of high concentration oxygen.
Optional oxygen-driven-nebulizer is provided for patients who are prscribed for oxygen aerosol therapy by physician, using higher purity oxygen to drive a nebulizer while oxygen therapy is being undertaken. Optional oxygen-driven-nebulizer allows a single wnit to meet the different needs of oxygen or oxygen-aerosol therapy patients.
This submission covers a model that will have a maximum output of 10-liters per minute as compared to the currently marketed model. Options will include an Oxygen alarm, pediatric flowmeter and nebulizer.
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9.7 Intend Use
The Oxyqen Concentrators are intended for the administration of supplemental oxygen up to 10 LPM. Our proposed Oxygen-Driven Nebulizer option is intended to provide higher purity of oxygen to drive the nebulizer, pursuant to prescribed oxygen-aersol therapy application by physician. The device is not intended for life support nor does it provide any patient monitoring capabilities.
Technological Characteristics 9.8
The oxygen concentrator operates by using molecular sieve material to absorb water and nitrogen from filtered air. The resulting gas has an increased oxygen purity. This technology is well established and has been used in other legally marketed products. There are no major technological differences.
ਰ ਰ Performance Data
The results of the testing confirm that the device meets specifications and is substantially equivalent to the predicate device.
9.10 Conclusion
Based on the design, performance specifications, testing and intended use, the Merits Health Products Oxygen Concentrators are substantially equivalent to the currently marketed device.
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Image /page/2/Picture/1 description: The image shows the seal of the Department of Health and Human Services. The seal features an abstract image of an eagle with its wings spread, and the words "DEPARTMENT OF HEALTH AND HUMAN SERVICES, USA" are written around the eagle in a circular pattern. The seal is black and white.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
MAR 2 3 2006
Mr. Steve Chao Merits Health Products Company, Limited 9. Road 36 Taichung Industrial Park Taichung China (Taiwan) 407
Re: K053229
Trade/Device Name: Merits Health Products Oxygen Concentrator Regulation Number: 868.5440 Regulation Name: Respiratory gas humidifier Regulatory Class: II Product Code: CAW Dated: February 17, 2006 Received: February 21, 2006
Dear Mr. Chao:
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 (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 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
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Page 2 -- Mr. Steve Chao
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 continue 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) 276-0115. 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/dsma/dsmamain.html
Sincerely yours,
Suen Runo
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
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Indications for Use
| 510(k) File Number: | K053229 |
|---|---|
| Device Name: | Merits Health Products Oxygen Concentrator |
| Indications For Use: | The Oxygen Concentrators are indicated for the delivery ofsupplemental oxygen in the home or medical institutions. Thedevices are not intended for life support nor do they provide anypatient monitoring capabilities. |
Prescription Use _ V (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use _________________________________________________________________________________________________________________________________________________________ (Part 21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Auy Salem
ology General Hospital
cal Dental Devices
K052229
§ 868.5440 Portable oxygen generator.
(a)
Identification. A portable oxygen generator is a device that is intended to release oxygen for respiratory therapy by means of either a chemical reaction or physical means (e.g., a molecular sieve).(b)
Classification. Class II (performance standards).