K Number
K130942
Device Name
LEGACY MEDICAL ECO-CHOICE DISPOSABLE BLOOD PRESSURE CUFF
Date Cleared
2013-10-17

(196 days)

Product Code
Regulation Number
870.1120
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The Legacy Medical Blood Pressure Cuff is an accessory used in conjunction with non-invasive blood pressure measuring devices to measure systolic and diastolic blood pressures and heart rate. It is non-sterile and may be used with neonatal, pediatric and adult patients. The cuff is not designed, sold or intended for use except as indicated: Prescription Use, Part 21 CFR 801 Subpart D
Device Description
Per CFR 870.1120, a blood pressure cuff is a device that has an inflatable bladder within, or integral to, an inelastic sleeve (cuff) with a mechanism for inflating and deflating the bladder. The cuff is used in conjunction with an appropriate measuring device to determine a subject's blood pressure. The Legacy Medical Blood Pressure Cuff comprises a soft inelastic sleeve with an integrated inflatable bladder that is wrapped around the patient's limb and
More Information

No
The device description and performance studies focus on the physical characteristics and basic function of a blood pressure cuff, with no mention of AI or ML technologies.

No.
The device is used to measure blood pressure, not to treat a condition or disease.

No

The device is an accessory used in conjunction with blood pressure measuring devices. It does not independently measure or diagnose.

No

The device description explicitly states it is a "blood pressure cuff" which is a physical device with an inflatable bladder and sleeve, not a software-only product.

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

Here's why:

  • Intended Use: The intended use clearly states that the device is an accessory used in conjunction with non-invasive blood pressure measuring devices to measure systolic and diastolic blood pressures and heart rate. This is a physiological measurement taken directly from the patient's body.
  • Device Description: The description aligns with a physical device used externally on a patient's limb to restrict blood flow for blood pressure measurement.
  • Lack of IVD Characteristics: There is no mention of analyzing samples (blood, urine, tissue, etc.) in vitro (outside the body) to provide diagnostic information.

IVD devices are specifically designed to examine specimens derived from the human body to provide information for the diagnosis, treatment, or prevention of disease. This blood pressure cuff does not perform such a function.

N/A

Intended Use / Indications for Use

The Legacy Medical Blood Pressure Cuff is an accessory used in conjunction with non-invasive blood pressure measuring devices to measure systolic and diastolic blood pressures and heart rate. It is non-sterile and may be used with neonatal, pediatric and adult patients. The cuff is not designed, sold or intended for use except as indicated:

Prescription Use, Part 21 CFR 801 Subpart D

The Legacy Medical Eco Choice Blood Pressure cuff is an accessory used in conjunction with non-invasive blood pressure measuring devices to measure systolic and diastolic blood pressures and heart rate. It is non-sterile and may be used with neonatal, pediatric and adult patients. The cuff is not designed, sold or intended for use except as indicated.

Prescription Use X (Part 21 CFR 801 Subpart D) AND/OR Over-The-Counter Use (21 CFR 807 Subpart C)

Product codes

DXQ, DXO

Device Description

Per CFR 870.1120, a blood pressure cuff is a device that has an inflatable bladder within, or integral to, an inelastic sleeve (cuff) with a mechanism for inflating and deflating the bladder. The cuff is used in conjunction with an appropriate measuring device to determine a subject's blood pressure.

The Legacy Medical Blood Pressure Cuff comprises a soft inelastic sleeve with an integrated inflatable bladder that is wrapped around the patient's limb and

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

neonatal, pediatric and adult 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)

Non-clinical tests - comparative bench testing was utilized to assess and prove similarity of function between the Legacy Medical Blood Pressure Cuff and the predicate devices. Tests showed that the functional and operational performance characteristics including compression, pressure control, leakage and both safety and operational parameters used when connected to inflation and measurement equipment were substantially equivalent.

Test conclusion - Non-clinical test results of the Legacy Medical Blood Pressure Cuff indicated substantial equivalence in the measured characteristics to the predicate devices.

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

Not Found

Predicate Device(s)

K974080, K790810, K883977, K911213, K940214, K942259

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 870.1120 Blood pressure cuff.

(a)
Identification. A blood pressure cuff is a device that has an inflatable bladder in an inelastic sleeve (cuff) with a mechanism for inflating and deflating the bladder. The cuff is used in conjunction with another device to determine a subject's blood pressure.(b)
Classification. Class II (performance standards).

0

Image /page/0/Picture/1 description: The image shows the logo for Legacy Medical, Inc. The logo features a stylized figure within a circular design, with the text "Legacy Medical, Inc." to the right of the figure. The figure appears to be reaching upwards, and the overall design is simple and professional.

Legacy Medical, Inc. 9039 Horizon Drive, Shakopee, MN 55379 Tel: 952-322-7240 Fax: 866-498-5854 Web www.legacy-medical.com

IV. 510(k) Summary

Submitter:Legacy Medical, Inc. 9039 Horizon Drive Shakopee, MN 55379
------------------------------------------------------------------------

OCT 17 2013

Date: March 27, 2013

Contact Person: Debra Robertson, President Tel: 952-322-7240

Name of Device:

Classification Name:Cuff, Blood Pressure CFR 870.1120
Common Name:Non-invasive blood Pressure Cuff
Review Panel:Cardiovascular
Classification:Class II
Product Code:DXQ
Proprietary Name:Legacy Medical Blood Pressure Cuff

Predicate Devices:

DeviceManufacturer510(k)
Critikon Soft-Cuf Blood Pressure CuffGE HealthcareK974080
Disposa-Cuff Blood Pressure CuffCrest Medical
EquipmentK790810
Surgi-CuffEthox CorporationK883977
Cuff-Able Blood Pressure CuffVital Signs, IncK911213
Statcorp Disposable Blood Pressure
CuffStatcorp, IncK940214
TechnicuffTechnicuff Corp.K942259

Device Description:

Per CFR 870.1120, a blood pressure cuff is a device that has an inflatable bladder within, or integral to, an inelastic sleeve (cuff) with a mechanism for inflating and deflating the bladder. The cuff is used in conjunction with an appropriate measuring device to determine a subject's blood pressure.

The Legacy Medical Blood Pressure Cuff comprises a soft inelastic sleeve with an integrated inflatable bladder that is wrapped around the patient's limb and

1

Image /page/1/Picture/1 description: The image shows a logo for Legacy Medical, Inc. The logo features a stylized image of a person with their arms raised, surrounded by a circle and two leaves. The text "Legacy Medical, Inc." is written in a simple, sans-serif font to the right of the image.

Legacy Medical, Inc. 9039 Horizon Drive, Shakopee, MN 55379 Tel: 952-322-7240 Fax: 866-498-5854 Web www.legacy-medical.com

III. Statement of Indications for Use

Indications for use: 510(k) number: Pending Device name: Legacy Medical Blood Pressure Cuff Indications for use:

The Legacy Medical Blood Pressure Cuff is an accessory used in conjunction with non-invasive blood pressure measuring devices to measure systolic and diastolic blood pressures and heart rate. It is non-sterile and may be used with neonatal, pediatric and adult patients. The cuff is not designed, sold or intended for use except as indicated:

Prescription Use, Part 21 CFR 801 Subpart D

2

Image /page/2/Picture/1 description: The image shows the logo for Legacy Medical, Inc. The logo features a stylized human figure with arms raised inside a circular shape. The text "Legacy Medical, Inc." is written in a simple, sans-serif font to the right of the figure.

Legacy Medical, Inc. 9039 Horizon Drive, Shakopee, MN 55379 Tel: 952-322-7240 Fax: 866-498-5854 Web www.legacy-medical.com

Performance Summary:

The Legacy Medical blood pressure cuff has been tested according to the following standards:

  • ANSI/AAMI SP10. Manual. . electronic or automated
    sphygmomanometers, 2002+A1:2003+A2:2006+(R)2008

  • ISO 10993-5, Biological evaluation of medical devices, Part 5: .
    Tests for In Vitro cytotoxicity, 1999

  • ISO 10993-12, Biological Evaluation of Medical Devices, Part 12: .
    Sample Preparation and Reference Materials

Performance Data:

Non-clinical tests - comparative bench testing was utilized to assess and prove similarity of function between the Legacy Medical Blood Pressure Cuff and the predicate devices. Tests showed that the functional and operational performance characteristics including compression, pressure control, leakage and both safety and operational parameters used when connected to inflation and measurement equipment were substantially equivalent.

Test conclusion - Non-clinical test results of the Legacy Medical Blood Pressure Cuff indicated substantial equivalence in the measured characteristics to the predicate devices.

Statement of Substantial Equivalence:

The Legacy Medical Blood Pressure Cuff is substantially equivalent in technology, function, operating parameters, and intended use to the blood pressure cuffs that are currently commercially available and in distribution.

3

DEPARTMENT OF HEALTH & HUMAN SERVICES

Public Health Service

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-002

Image /page/3/Picture/3 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo features a stylized caduceus, a symbol often associated with medicine and healthcare. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged around the caduceus in a circular fashion. The logo is black and white.

October 17, 2013

Legacy Medical, Inc. C/O Deb Robertson 9039 Horizon Dr Shakopee, MN 55379 US

K130942 Re:

Trade/Device Name: Legacy Medical Eco-Choice Disposable Blood Pressure Cuff Regulation Number: 21 CFR 870.1120 Regulation Name: Non-Invasive Blood Pressure Cuff Regulatory Class: Class II Product Code: DXO Dated: August 30, 2013 Received: September 16, 2013

Dear Deb Robertson:

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.

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 labeling (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.

4

Page 2 - Deb Robertson

1f 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 toll-free 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" (21 CFR 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/Resourcesfor You/Industry/default.htm.

Sincerely yours,

Owen P. Faris -S

for Bram D. Zuckerman, Ph.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

5

K130942

Image /page/5/Picture/1 description: The image shows the logo for Legacy Medical, Inc. The logo features a stick figure with its arms raised inside of a circle. Above the stick figure are two dome-shaped objects that are connected to the circle. To the right of the circle is the text "Legacy Medical, Inc."

Legacy Medical, Inc. 9039 Horizon Drive, Shakopee, MN 55379 Tel: 952-322-7240 Fax: 866-498-5854 Web www.legacy-medical.com

Indications for Use

510(k) Number (if known): K130942 Device Name: Eco Choice Blood Pressure cuff Indications For Use:

The Legacy Medical Eco Choice Blood Pressure cuff is an accessory used in conjunction with non-invasive blood pressure measuring devices to measure systolic and diastolic blood pressures and heart rate. It is non-sterile and may be used with neonatal, pediatric and adult patients. The cuff is not designed, sold or intended for use except as indicated.

Prescription Use AND/OR Over-The-Counter Use X (Part 21 CFR 801 Subpart D) (21 CFR 807 Subpart C)

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

Concurrence of Center for Devices and Radiological Health (CDRH) Page 1 of

Digitally signed by
Owen P. Faris -S
Date: 2013.10.17
15:34:29 -04'00'