K Number
K130037
Device Name
BREATHE CPAP SYSTEM
Date Cleared
2013-05-17

(130 days)

Product Code
Regulation Number
868.5905
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The continuous positive airway pressure (CPAP) System is indicated for the treatment of obstructive sleep apnea (OSA) in patients > 661b (30 kg). The Breathe CPAP System is intended for single-patient re-use in the home environment.
Device Description
The Breathe Technologies™ CPAP system is an AC powered Continuous Positive Airway Pressure (CPAP) device that delivers a physician prescribed pressure during the inspiratory phase and expiratory phases to help maintain airway patency during sleep for patients with obstructive sleep apnea (OSA). The Breathe CPAP System consists of a programmable, microprocessor controlled, flow generator (i.e., blower) and a Nasal Pillows Mask. The flow generator generates CPAP from room air to the patient and transmits it via the attached Nasal Pillows Mask. The end of the patient circuit is a nasal pillows interface which is worn on the nose. The nasal interface is held in place with standard headgear.
More Information

No
The description mentions a "programmable, microprocessor controlled, flow generator" but does not include any language suggesting the use of AI or ML for decision-making, data analysis, or adaptive control beyond standard programming. The "Mentions AI, DNN, or ML" section is explicitly marked as "Not Found".

Yes

The device is indicated for the treatment of obstructive sleep apnea (OSA), which is a medical condition, making it a therapeutic device.

No

The device description clearly states it is a "Continuous Positive Airway Pressure (CPAP) device that delivers a physician prescribed pressure" for treatment, not diagnosis. Its purpose is to maintain airway patency, a therapeutic action.

No

The device description explicitly states it consists of a "programmable, microprocessor controlled, flow generator (i.e., blower) and a Nasal Pillows Mask," which are hardware components.

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

Here's why:

  • IVD Definition: In vitro diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections.
  • Device Function: The description clearly states that the Breathe CPAP System is a device that delivers continuous positive airway pressure to treat obstructive sleep apnea. It works by physically maintaining airway patency, not by analyzing biological samples.
  • Intended Use: The intended use is for the treatment of a condition (OSA) by delivering air pressure, not for diagnostic testing.
  • Device Description: The description focuses on the mechanical components (blower, mask, headgear) and how it delivers air, not on any components or processes related to analyzing biological samples.

Therefore, the Breathe CPAP System falls under the category of a therapeutic medical device, not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

The continuous positive airway pressure (CPAP) System is indicated for the treatment of obstructive sleep apnea (OSA) in patients > 661b (30 kg). The Breathe CPAP System is intended for single-patient re-use in the home environment.

Product codes

BZD

Device Description

The Breathe Technologies™ CPAP system is an AC powered Continuous Positive Airway Pressure (CPAP) device that delivers a physician prescribed pressure during the inspiratory phase and expiratory phases to help maintain airway patency during sleep for patients with obstructive sleep apnea (OSA).

The Breathe CPAP System consists of a programmable, microprocessor controlled, flow generator (i.e., blower) and a Nasal Pillows Mask. The flow generator generates CPAP from room air to the patient and transmits it via the attached Nasal Pillows Mask. The end of the patient circuit is a nasal pillows interface which is worn on the nose. The nasal interface is held in place with standard headgear.

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 (specified as > 66lb (30 kg) which implies an age range, but not explicitly stated)

Intended User / Care Setting

single-patient re-use in the home environment.

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)

Biocompatibility data demonstrates that the device is in compliance with ISO 10993-1 (2009) Biological evaluation of medical devices -- Part 1: Evaluation and testing

The Breathe CPAP System is compliant with the following Standards and Guidance:

  • FDA Draft Reviewer Guide for Ventilators (July 1995) .
  • ASTM F1246-91 (2005), Standard Specification for Electrically Powered Home . Care Ventilators
  • IEC 60601 1 (1988), Amendment 1 (1991-11), Amendment 2 (1995): Medical . electrical equipment - General Requirements for Safety.
  • ANSI/AAMI/IEC 60601-1-2 (2007), Medical electrical equipment Part 1-2: . General requirements for basic safety and essential performance - Collateral standard: Electromagnetic compatibility - Requirements and tests (Edition 3).

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

Not Found

Predicate Device(s)

K070609

Reference Device(s)

K050171

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

Image /page/0/Picture/2 description: The image shows the word "Breathe" in a simple, sans-serif font. A curved line is drawn beneath the word, resembling a wave or a breath of air. The text and line are black against a white background, creating a clean and minimalist design.

Section 5: 510(k) Summary

CategoryComments
Sponsor:Breathe Technologies
175 Technology Drive, Suite 100
Irvine, CA 92618
Tel: 949-988-7700
Correspondent ContactCraig Coombs
Information:President
Coombs Medical Device Consulting, Inc
1193 Sherman St.
Alameda, CA 94501
Office: 510.337.0140
Fax: 510.337.0416
Device Common Name:CPAP System
Device Classification21 CFR 868.5905
Regulation & Name:Ventilator, Non-Continuous (Respirator)
Device Classification &Class II,
Product Code:BZD
Device Proprietary Name:Breathe CPAP System

Predicate Device Information:

Predicate Device:XT1 CPAP Model 9S-005
Predicate Device Manufacturer:Apex Medical Corporation
Predicate Device Premarket Notification #K070609
Predicate Device Common Name:CPAP
Predicate Device Classification & Name:21 CFR 868.5905
Predicate Device Classification &Class II
Product Code:BZD

Reference Device Information:

Predicate Device:InnoMed IT Nasal Mask
Predicate Device Manufacturer:InnoMed Technologies
Predicate Device Premarket Notification #:K050171
Predicate Device Common Name:Ventilator, continuous non-life supporting
(accessory to)
Predicate Device Classification & Name:21 CFR 868.5905
Predicate Device Classification &
Product Code:Class II
BZD

·

b. Date Summary Prepared

4 January 2013

1

c. Description of Device

The Breathe Technologies™ CPAP system is an AC powered Continuous Positive Airway Pressure (CPAP) device that delivers a physician prescribed pressure during the inspiratory phase and expiratory phases to help maintain airway patency during sleep for patients with obstructive sleep apnea (OSA).

The Breathe CPAP System consists of a programmable, microprocessor controlled, flow generator (i.e., blower) and a Nasal Pillows Mask. The flow generator generates CPAP from room air to the patient and transmits it via the attached Nasal Pillows Mask. The end of the patient circuit is a nasal pillows interface which is worn on the nose. The nasal interface is held in place with standard headgear.

d. Intended Use

The continuous positive airway pressure (CPAP) System is indicated for the treatment of obstructive sleep apnea (OSA) in patients > 661b (30 kg). The Breathe CPAP System is intended for single-patient re-use in the home environment.

e. Comparison to Predicate Device

The Breathe Technologies CPAP is substantially equivalent in Intended Use, Indications for Use, technology, design, materials, physician or patient use, and energy source to the predicate Apex Medical XTI CPAP Model 9S-005 (K070609) with the InnoMed IT Nasal Mask (K050171).

  • The testing described below demonstrates that the differences in the devices do not raise any unresolved issues of safety or efficacy.
    Breathe Technologies concludes that the devices are substantially equivalent.

f. Summary of Supporting Data

Biocompatibility data demonstrates that the device is in compliance with ISO 10993-1 (2009) Biological evaluation of medical devices -- Part 1: Evaluation and testing

The Breathe CPAP System is compliant with the following Standards and Guidance:

  • FDA Draft Reviewer Guide for Ventilators (July 1995) .
  • ASTM F1246-91 (2005), Standard Specification for Electrically Powered Home . Care Ventilators
  • IEC 60601 1 (1988), Amendment 1 (1991-11), Amendment 2 (1995): Medical . electrical equipment - General Requirements for Safety.
  • ANSI/AAMI/IEC 60601-1-2 (2007), Medical electrical equipment Part 1-2: . General requirements for basic safety and essential performance - Collateral standard: Electromagnetic compatibility - Requirements and tests (Edition 3).

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Image /page/2/Picture/0 description: The image shows the seal of the Department of Health & Human Services - USA. The seal is circular, with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. In the center of the seal is a stylized symbol that resembles an abstract representation of a human figure or a caduceus. The symbol consists of three curved lines that converge at the bottom, creating a sense of movement or flow.

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

May 17, 2013

Breathe Technologies C/O Mr. Craig Coombs President Coombs Medical Devices Consulting, Incorporated 1193 Sherman Street ALAMEDA CA 94501

Re: K130037

Trade/Device Name: Breathe CPAP System Regulation Number: 21 CFR 868.5905 Regulation Name: Noncontinuous Ventilator (IPPB) Regulatory Class: II Product Code: BZD Dated: April 15, 2013 Received: April 18, 2013

Dear Mr. Coombs:

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. 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.

3

Page 2 - Mr. Coombs

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 devicerelated 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 contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address

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

Kwame O. Ulmer -S for

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

4

Breathe

Breathe CPAP System Traditional Premarket Notification

Section 4: Indications for Use Statement

510(k) Number (if known):

Device Name: Breathe CPAP System

Indications for Use:

The continuous positive airway pressure (CPAP) System is indicated for the treatment of obstructive sleep apnea (OSA) in patients > 661b (30 kg). The Breathe CPAP System is intended for single-patient re-use in the home environment.

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

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)

Page 1 of

Paul H. Shin = 2013.05:15 15:59:53 -04'00'

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

510(k) Number;