K Number
K122111
Device Name
RESPIRONICS SIMPLYCLEAR DEVICE
Manufacturer
Date Cleared
2012-12-31

(167 days)

Product Code
Regulation Number
868.5665
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Philips Respironics SimplyClear device promotes airway clearance by gradually applying air pulse generated high frequency oscillatory vibrations on the positive and negative pressures applied to the chest wall via the airways. The high frequency oscillatory vibrations release mucus from the bronchial walls, increasing mobilization. The shift in pressure produces a high expiratory flow from the lungs, promoting the clearance of the mobilized secretions via coughing. The Philips Respironics SimplyClear device may be used either with a facemask or mouthpiece, or with an adapter to a patient's endotracheal or tracheostomy tube. It is for use on adult or pediatric patients having difficulty with secretion clearance and/or inability to cough. The SimplyClear device is for use in a hospital, institutional environment or in the home.
Device Description
The Philips Respironics SimplyClear device promotes airway clearance by loosening, mobilizing and clearing secretions. The loosening and mobilization occurs by gradually applying air pulse generated high frequency oscillatory vibrations on the positive and negative pressures applied to the chest wall via the airways. The high frequency oscillatory vibrations release mucus from the bronchial walls, increasing mobilization. The positive to negative shift in pressure produces a high expiratory flow from the lungs, promoting the clearance of the mobilized secretions via coughing. The SimplyClear device combines the loosening and mobilization functionality of the Vest Airway Clearance System (K024309) with the secretion clearance functionality of the CoughAssist device (K002598), Dima Italia Negavent DA-3 Plus Pegaso (K072292) and the CoughAssist T70 device (K121955).
More Information

Not Found

No
The description focuses on mechanical principles (air pulse, oscillations, pressure shifts) and software algorithms for control and performance, not AI/ML for decision-making or pattern recognition. The testing described is standard software and performance verification, not AI/ML model training or validation.

Yes
The device is intended to promote airway clearance for patients having difficulty with secretion clearance and/or inability to cough, which is a therapeutic function.

No
The device is used to promote airway clearance and secretion mobilization, which are therapeutic actions, not diagnostic ones.

No

The device description explicitly states it applies "air pulse generated high frequency oscillatory vibrations on the positive and negative pressures applied to the chest wall via the airways," which requires hardware components to generate and deliver these pressures and vibrations. The testing also mentions "sensor malfunctions" and "external suctioning accessory interface," further indicating hardware is involved.

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

Here's why:

  • IVD Definition: In vitro diagnostic devices are used to examine specimens taken from the human body (like blood, urine, or tissue) to provide information about a person's health.
  • SimplyClear Function: The SimplyClear device works by applying physical forces (air pulses, pressure, vibrations) to the patient's chest wall and airways to help clear secretions. It directly interacts with the patient's body.
  • Lack of Specimen Analysis: The description does not mention the device analyzing any biological specimens. Its function is entirely external and mechanical.

Therefore, the SimplyClear device falls under the category of a therapeutic or medical device, not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

The Philips Respironics SimplyClear device assists patients in loosening, mobilizing and clearing secretions by providing high frequency oscillatory vibrations while gradually applying a positive pressure to the airway, then rapidly shifting to a negative pressure. The oscillatory vibrations assist in loosening and mobilizing the secretions while the rapid shift in pressure produces a high expiratory flow rate from the lungs, which promotes the clearance of secretions.

The SimplyClear device may be used either with a facemask or mouthpiece, or with an adapter to a patient's endotracheal or tracheostomy tube. It is for use on adult or pediatric patients having difficulty with secretion clearance and/or inability to cough. The SimplyClear device is for use in a hospital. institutional environment or in the home.

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

BYI, NHJ

Device Description

The Philips Respironics SimplyClear device promotes airway clearance by loosening, mobilizing and clearing secretions. The loosening and mobilization occurs by gradually applying air pulse generated high frequency oscillatory vibrations on the positive and negative pressures applied to the chest wall via the airways. The high frequency oscillatory vibrations release mucus from the bronchial walls, increasing mobilization. The positive to negative shift in pressure produces a high expiratory flow from the lungs, promoting the clearance of the mobilized secretions via coughing.

The SimplyClear device combines the loosening and mobilization functionality of the Vest Airway Clearance System (K024309) with the secretion clearance functionality of the CoughAssist device (K002598), Dima Italia Negavent DA-3 Plus Pegaso (K072292) and the CoughAssist T70 device (K121955).

The key benefits of this device are:

  • Oscillations .
  • Simplicity of Use .
  • Common User Interface across product platforms
  • Triggering adjustments (Cough-Trak)
  • Data storage, transfer and reporting (DirectView and Encore)
  • Portability ●
  • Maintains patient lifestyle
  • Smaller size and decreased weight
  • Accessory Options ●
  • Oximetry Accessory ·
  • Remote Control Accessory (foot pedal)
  • External Suctioning Accessory Interface
  • Power Management Options
  • Detachable battery
  • External DC battery
  • Universal Battery pack

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

chest wall (via the airways), lung

Indicated Patient Age Range

Adult or pediatric patients

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)

Black-box performance testing was conducted for the SimplyClear device using side by side bench testing methodologies to demonstrate that the SimplyClear device performs to design input specifications and is equivalent to the predicate devices. This bench testing included both open and closed loop conditions from the defined patient test cases to verify that the SimplyClear software algorithms performed to specification. Bench testing conducted for the SimplyClear device characterized the types of worst case scenario inputs that would be experienced in the intended use environment such as extreme flow rates. Additional white-box testing verified proper operation under conditions of sensor malfunctions and inaccurate or complete sensor dropout. This combination of testing demonstrated that the SimplyClear devices' closed loop control algorithms function safely and effectively under worst case scenarios.

Verification activities have been performed to verify that the device features stated above did not affect the safety and effectiveness of the subject device. This included bench testing, software unit testing and code reviews. A control system analysis was completed and submitted as part of this 510(k) submission.

Testing Summary:

  • User Interface including displayed therapy parameters: Has been verified to meet product requirements defined for the SimplyClear UI. Bench testing, code reviews and software unit testing was performed to ensure that all display functions, user controls and informational messages performed as intended. The User Interface was verified to ensure that it displayed the proper data and expected therapy information.
  • Delivered Pressure and Flow Stability: Verification testing has verified that the SimplyClear device delivers accurate pressure for the intended duration of the insufflation, exsufflation and pause phases of therapy. The SimplyClear device has been verified to demonstrate pressure and flow stability across all patient test cases, including extreme flow rates and sensor malfunctions (i.e. sensor inaccuracies and / or complete sensor drop out).
  • CoughTrak: The CoughTrak feature of the SimplyClear device has been verified to meet product specifications with each defined patient case simulation. The availability, operation and triggering performance has been verified to operate across the range of patient cases.
  • Oscillations: The Oscillation feature of the SimplyClear device has been verified to meet product specifications. Bench testing at extreme therapy settings has been provided, which includes waveform testing conducted on maximum duration of therapy at extreme therapy settings. Oscillation waveforms were also compared against the predicate device waveforms with no oscillations.
  • Data Management: Data management of the SimplyClear device has been verified to meet product specifications for SD card data integrity. Software verification, including code reviews and software verification testing was conducted to verify the expected results with the SD card.
  • Oximetry Accessory: The Oximetry Accessory has been tested to verify the behavior of the pulse oximetry data and the proper display of data received by the oximetry accessory.
  • Wired Remote Control: Verification testing has been conducted to verify the availability and operation of the SimplyClear wired remote control device.
  • External Suctioning Accessory Interface: The SimplyClear device has been verified to demonstrate that the device provides power to a suctioning accessory as specified.
  • Power Management: The SimplyClear device has been verified to properly interface with the detachable battery, properly display the battery information, properly charge the battery and indicate a low battery charge. The SimplyClear device has also been verified to be compatible with an external DC power supply, to properly display the power supply information and to properly indicate a low external battery.

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.

Modified Vest Airway™ Clearance System - K024309, Emerson CoughAssist, Model CA-3000 - K002598, Dima Italia Negavent DA-3 Plus Pegaso - K072292, Philips Respironics CoughAssist T70 - K121955

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

§ 868.5665 Powered percussor.

(a)
Identification. A powered percussor is a device that is intended to transmit vibration through a patient's chest wall to aid in freeing mucus deposits in the lung in order to improve bronchial drainage and that may be powered by electricity or compressed gas.(b)
Classification. Class II (performance standards).

0

K 122111

Philips Respironics SimplyClear

Premarket Notification -- Abbreviated 510(k)

Section 5.0 510(k) Summary

DEC 3 1 2012

Administrative Information and Device Identification

Name and address of theManufacturer:
manufacturer and sponsor of the
510(k) submission:Respironics, Inc.
175 Chastain Meadows Court
Kennesaw, GA 30144-3714
Office: (770) 423-2322
Fax: (770) 423-2300
Sponsor:
Respironics
1740 Golden Mile Highway
Monroeville, PA 15146
Office: 724-387-7562
Fax: 724-387-7490
FDA registration number of theManufacturer: 1040777 (Establishment
manufacturer of the new device:registration number)
Sponsor: 2518422 (Establishment registration
number)
Official contact person for allColleen Witt, RAC
correspondence:Senior Regulatory Affairs Engineer
Philips Respironics
1740 Golden Mile Highway
Monroeville, PA 15146
Office: 724-387-4870
Fax: 724-387-7490
Email: colleen.witt(@)philips.com
Date Prepared:July 16, 2012
Device Name:Philips Respironics SimplyClear Device
Proprietary name of new device:Philips Respironics SimplyClear Device
Common or usual name of thePercussor, Powered-Electric
device:
Philips/Respironics model number:Philips Respironics SimplyClear Device
Classification of new device:Class II
Classification of the predicateClass II
device:
Classification Panel:Anesthesiology
Panel Code:BYI - powered percussor
NHJ - noncontinuous ventilator (IPPB)

1

CFR Regulation Number:21 CFR 868.5665
a) Identification. A powered percussor is a
device that is intended to transmit vibration
through a patient's chest wall to aid in freeing
mucus deposits in the lung in order to improve
bronchial drainage and that may be powered by
electricity or compressed gas
(b) Classification. Class II (performance
standards).
Predicate Device Name(s) and
510(k) numbers:Modified Vest Airway™ Clearance System -
K024309
Emerson CoughAssist, Model CA-3000 -
K002598
Dima Italia Negavent DA-3 Plus Pegaso -
K072292
Philips Respironics CoughAssist T70 - K121955
Reason for submission:New Device

Description of Device:

The Philips Respironics SimplyClear device promotes airway clearance by loosening, mobilizing and clearing secretions. The loosening and mobilization occurs by gradually applying air pulse generated high frequency oscillatory vibrations on the positive and negative pressures applied to the chest wall via the airways. The high frequency oscillatory vibrations release mucus from the bronchial walls, increasing mobilization. The positive to negative shift in pressure produces a high expiratory flow from the lungs, promoting the clearance of the mobilized secretions via coughing.

The SimplyClear device combines the loosening and mobilization functionality of the Vest Airway Clearance System (K024309) with the secretion clearance functionality of the CoughAssist device (K002598), Dima Italia Negavent DA-3 Plus Pegaso (K072292) and the CoughAssist T70 device (K121955).

The key benefits of this device are:

  • Oscillations .
  • Simplicity of Use .
    • Common User Interface across product platforms

2

Philips Respironics SimplyClear

  • Triggering adjustments (Cough-Trak)
  • Data storage, transfer and reporting (DirectView and Encore)

  • Portability ●
    • Maintains patient lifestyle

    • Smaller size and decreased weight

  • Accessory Options ●
    • Oximetry Accessory ·

    • Remote Control Accessory (foot pedal)

    • External Suctioning Accessory Interface

  • Power Management Options
    • Detachable battery

    • External DC battery

    • Universal Battery pack

Statement of Intended Use:

The Philips Respironics SimplyClear device assists patients in loosening, mobilizing and clearing secretions by providing high frequency oscillatory vibrations while gradually applying a positive pressure to the airway, then rapidly shifting to a negative pressure. The oscillatory vibrations assist in loosening and mobilizing the secretions while the rapid shift in pressure produces a high expiratory flow rate from the lungs, which promotes the clearance of secretions.

Indications for Use:

The SimplyClear device may be used either with a facemask or mouthpiece, or with an adapter to a patient's endotracheal or tracheostomy tube. It is for use on adult or pediatric patients having difficulty with secretion clearance and/or inability to cough. The SimplyClear device is for use in a hospital. institutional environment or in the home.

Comparison of Device Technological Characteristics to Predicate Device

Substantial Equivalence

The submitted SimplyClear device has the following similarities to the predicate devices listed in this submission which previously received 510(k) concurrence; the SimplyClear device:

  • Has the same intended use, .
  • . Uses the same operating principle,
  • Incorporates the same basic system requirements including, but not limited to: physical . interfaces; modes of operation; therapy controls; and
  • Incorporates similar materials ●
  • Is manufactured utilizing the same manufacturing processes .

3

The table below summarizes the key technical characteristics between the SimplyClear device to those of the predicate devices listed in the submission:

TechnologicalSimplyClearThe VestEmersonNegavent DA-3CoughAssist T70
CharacteristicAirwayCoughAssistPlus Pegaso
Clearance
System
PatientAdult orAdult andAdult orAdult orAdult or pediatric
Populationpediatricpediatricpediatric patientpediatric patientpatient unable to
patients havingpatients withwith anunable to coughcough or clear
difficulty withevidence orineffectiveor clearsecretions
secretionsuggestion ofcough due tosecretions effectivelyeffectively
clearanceretainedmusculareffectively
and/or inabilitysecretions,dystrophy,
to cough.evidence thatmyasthenia
the patient isgravis,
havingpoliomyelitis, or
difficulty with
secretionother neurologic
disorder with
clearance orsome paralysis
presence ofof the
atelectasisrespiratory
caused bymuscles, such as
mucusspinal cord
plugging.injury.
Delivery TypeNon InvasiveNon-Invasive,
Inflatable VestNon Invasive or
InvasiveNon Invasive or
InvasiveNon Invasive or
Invasive
Modes ofManual andAutoManual andManual and AutoManual and Auto
OperationAutoAuto
Inhalation0 to 70 cmH2OPressure
setting 1-100 to 60 cmH2O+5 to 70 cmH2O0 to 70 cmH2O
Pressure
Exhalation0 to -70Pressure
setting 1-100 to -60 cmH2O-5 to -70 cmH2O0 to -70 cmH2O
PressurecmH2O
Inhale FlowLow, Medium,
HighN/ALow and HighLow, Medium,
HighLow, Medium,
High
Pause Time0 to 5 secondsN/A0 to 5 seconds0.1 - 9.9 seconds0 to 5 seconds
Phases ofInsufflation,
Exsufflation,
PauseN/AInsufflation,
Exsufflation,
PauseInsufflation,
Exsufflation,
PauseInsufflation,
Exsufflation,
Pause
Therapy FeaturesCoughTrak,
OscillationsOscillationsN/AN/ACoughTrak
SoftwareDynamic
Stability
Analysis
Flow and
Pressure Based
Oscillation
Detection
Extreme Flow
Rate Control
and Response
Sensor
Malfunction
StabilityN/AN/AN/ADynamic
Stability Analysis
Flow and
Pressure Based
Oscillation
Detection
Extreme Flow
Rate Control and
Response
Sensor
Malfunction
Stability
Oscillations1 to 20 cmH2ON/AN/AN/AN/A
Amplitude
Oscillation
Frequency0 to 20 Hz5 to 20 cycles
per second
(Hz)N/AN/AN/A
Remote Data
AccessA secure
digital (SD)
card provides
means for data
accessN/AN/AA secure digital
(SD) card
provides means
for data access

Tab 5 Page 4 of 8

·

4

The table below provides a description of the features of the SimplyClear device that are the subject of this 510(k) submission:

Device FeatureDescription
User InterfaceA new graphical user interface with hierarchal menu system
Delivered PressureThe device Inhale pressure is 0 to 70 cmH2O and Exhale pressure is 0 to -70 cmH2O
CoughTrakA feature for patients who can provide a spontaneous breathing effort to trigger
the cough sequence, instead of using manual or auto modes of therapy. This
software feature monitors the device outlet pressure and initiates the Insufflation
phase of therapy delivery when the pressure decreases below a set threshold
indicative of patient effort.
OscillationsA feature that delivers an oscillation on the pressure signal based on frequency
and amplitude set points
Displayed Therapy
Parameters ·The device displays outlet pressure, measured peak cough flow and measured
inhaled tidal volume
Data ManagementTherapy data will be stored on an SD card, which will be compatible with both
DirectView and Encore
Oximetry AccessoryDevice shall interface with the Oximetry accessory to display current SpO2 and
heart rate data received from the oximeter
Wired Remote ControlA remote control accessory (foot pedal) is provided to initiate manual therapy by
means of a wired remote control interface
External Suctioning
Accessory InterfaceDevice shall provide a DC output intended to power an external suctioning
accessory
Power ManagementOptions include a Detachable battery, External DC battery and Universal Battery
pack

The software design and algorithm descriptions for each of these features of the SimplyClear device have been provided as part of this 510(k) submission.

Performance Data

Non-Clinical Testing

Black-box performance testing was conducted for the SimplyClear device using side by side bench testing methodologies to demonstrate that the SimplyClear device performs to design input specifications and is equivalent to the predicate devices. This bench testing included both open and closed loop conditions from the defined patient test cases to verify that the SimplyClear software algorithms performed to specification. Bench testing conducted for the SimplyClear device characterized the types of worst case scenario inputs that would be experienced in the intended use environment such as extreme flow rates. Additional white-box

5

testing verified proper operation under conditions of sensor malfunctions and inaccurate or complete sensor dropout. This combination of testing demonstrated that the SimplyClear devices' closed loop control algorithms function safely and effectively under worst case scenarios.

Device Testing Summary

Verification activities have been performed to verify that the device features stated above did not affect the safety and effectiveness of the subject device. This included bench testing, software unit testing and code reviews. A control system analysis was completed and submitted as part of this 510(k) submission.

The table below provides a summary of the testing that was conducted on the features of the Philips Respironics SimplyClear device that are the subject of this 510(k) submission:

Device FeatureTesting Summary
User Interface including
displayed therapy
parametersHas been verified to meet product requirements defined for the SimplyClear UI. Bench testing, code reviews and software unit testing was performed to ensure that all display functions, user controls and informational messages performed as intended. The User Interface was verified to ensure that it displayed the proper data and expected therapy information.
Delivered Pressure and
Flow StabilityVerification testing has verified that the SimplyClear device delivers accurate pressure for the intended duration of the insufflation, exsufflation and pause phases of therapy. The SimplyClear device has been verified to demonstrate pressure and flow stability across all patient test cases, including extreme flow rates and sensor malfunctions (i.e. sensor inaccuracies and / or complete sensor drop out).
CoughTrakThe CoughTrak feature of the SimplyClear device has been verified to meet product specifications with each defined patient case simulation. The availability, operation and triggering performance has been verified to operate across the range of patient cases.
OscillationsThe Oscillation feature of the SimplyClear device has been verified to meet product specifications. Bench testing at extreme therapy settings has been provided, which includes waveform testing conducted on maximum duration of therapy at extreme therapy settings. Oscillation waveforms were also compared against the predicate device waveforms with no oscillations.
Data ManagementData management of the SimplyClear device has been verified to meet product specifications for SD card data integrity. Software verification, including code reviews and software verification testing was conducted to verify the expected results with the SD card.
Oximetry AccessoryThe Oximetry Accessory has been tested to verify the behavior of the pulse oximetry data and the proper display of data received by the oximetry accessory.
Wired Remote ControlVerification testing has been conducted to verify the availability and operation of the SimplyClear wired remote control device.
External Suctioning
Accessory InterfaceThe SimplyClear device has been verified to demonstrate that the device provides power to a suctioning accessory as specified.
Power ManagementThe SimplyClear device has been verified to properly interface with the

6

detachable battery, properly display the battery information, properly
charge the battery and indicate a low battery charge. The SimplyClear
device has also been verified to be compatible with an external DC power
supply, to properly display the power supply information and to properly
indicate a low external battery.

Standards Evaluation

This device has been tested to appropriate ISO, ASTM, and IEC standards and other applicable requirements passing all test protocols. The Philips Respironics SimplyClear device was designed and tested according to:

  1. ISO 14971 Medical devices - Application of risk management to medical devices

  2. ISO 10993-1 Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process

  3. IEC 60601-1 Medical Electrical Equipment - Part 1: General Requirements of Safety

  4. IEC 60601-1-2 Medical Electrical Equipment -- Part 1-2: Electromagnetic Compatibility

    1. IEC 60601-1-6 Medical Electrical Equipment Part 1-6: Usability
  1. IEC 60068 Environmental Testing (Part 2-6, 2-27, 2-64): Mechanical Vibration and Shock Resistance testing

  2. IEC 62304 Medical device software - Software life cycle processes

The SimplyClear device complies with the applicable requirements referenced in the FDA guidance documents:

  • FDA's Draft Reviewer Guidance for Premarket Notification Submissions -. Anesthesiology and Respiratory Devices Branch: Division of Cardiovascular. Respiratory, and Neurological Devices (November 1993); and
  • FDA "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices" (May 11, 2005).

As suggested by FDA's November 1993 publication entitled "Reviewer Guidance for Premarket Notification Submissions - Anesthesiology and Respiratory Devices Branch: Division of Cardiovascular, Respiratory, and Neurological Devices" the Philips Respironics SimplyClear device was tested in accordance with the applicable voluntary standards. The Philips Respironics SimplyClear met the required performance criteria and functioned as intended.

Conclusion

The SimplyClear device that is the subject of this 510(k) submission has been validated using non-clinical tests and has been determined to be substantially equivalent to the predicate devices. In summary, bench testing (black-box and white-box) and software code reviews have

7

Philips Respironics SimplyClear

confirmed that the SimplyClear device performs equivalently to the cited predicate devices. The indications for use, technological characteristics, and principles of operation are similar to the predicate devices. The Philips Respironics SimplyClear device is substantially equivalent to the predicate devices listed in this summary and the new device does not raise any new issues of safety and effectiveness.

8

Image /page/8/Picture/0 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is a stylized symbol that resembles an abstract caduceus or a series of waving lines, representing health and human services.

DEPARTMENT OF HEALTH & HUMAN SERVICES

Public Health Service

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

December 31, 2012

Ms. Colleen Witt, RAC Senior Regulatory Affairs Engineer Respironics 1740 Golden Mile Highway MONROEVILLE PA 15146

Re: K122111

Trade/Device Name: Phillips Respironics SimplyClear Regulation Number: 21 CFR 868.5665 Regulation Name: Powered Percussor Regulatory Class: II Product Code: BYI, NHJ Dated: December 28, 2012 Received: December 31, 2012

Dear Ms. Witt:

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. Iisting 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.

9

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); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); 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.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to

http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

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) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours,

Kwame O. Ulmer

Anthony D. Watson, B.S., M.S., M.B.A. Director

Division of Anesthesiology, General Hospital, Respiratory, Infection Control and

. Dental Devices

Office of Device Evaluation

Center for Devices and Radiological Health

Enclosure

10

Philips Respironics SimplyClear

Section 4.0 Indications for Use

Indications for Use

510(k) Number (if known): | | | | | | | | | | | | | | | | |

Device Name: Philips Respironics SimplyClear

The Philips Respironics SimplyClear device promotes airway clearance by gradually applying air pulse generated high frequency oscillatory vibrations on the positive and negative pressures applied to the chest wall via the airways. The high frequency oscillatory vibrations release mucus from the bronchial walls, increasing mobilization. The shift in pressure produces a high expiratory flow from the lungs, promoting the clearance of the mobilized secretions via coughing.

The Philips Respironics SimplyClear device may be used either with a facemask or mouthpiece, or with an adapter to a patient's endotracheal or tracheostomy tube. It is for use on adult or pediatric patients having difficulty with secretion clearance and/or inability to cough.

The SimplyClear device is for use in a hospital, institutional environment or in the home.

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)
Paul H. Shin -SFor L.S.
2012.12.31 11:39:21
-05'00'Concurrence of CDRH, Office of Device Evaluation (ODE)
(Division Sign-Off)
Division of Anesthesiology, General Hospital
Infection Control, Dental DevicesPage 1 of 1

K122111 510(k) Number: