K Number
K143108
Device Name
HealthGuard-15
Manufacturer
Date Cleared
2015-03-27

(149 days)

Product Code
Regulation Number
870.1130
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The HealthGuard-15 is a non-invasive screening device intended for use in corporate wellness facilities and in health/fitness clubs. It is not for use in medical facilities such as hospitals or doctor's offices. This device measures systolic and diastolic blood pressure, heart rate, percent body fat and weight. It is operated by the client supplied PC computer. The device is intended for users eighteen years and older.
Device Description
The HealthGuard-15 is a portable health kiosk that provides a means for measuring and tracking an individual's systolic and diastolic blood pressure, heart rate, percent body fat and weight. The HG-15 integrates two FDA market cleared devices ---- the Omron HEM-7200-Z [BP742] (K121932) for measurement of blood pressure and heart rate, and the FUTREX-6100/XL (K963271) for the estimation of the percent body fat --into a health kiosk with similar performance as the Health Check Kiosk (K063008). The HG-15 kiosk can typically be installed in corporate offices, lunch rooms or other community places so that employees can be measured as part of a corporate wellness program to track changes over time. It is not for use in hospitals or in other health care facilities. The HG-15 is delivered without the necessary PC computer. The client supplies the computer and Futrex supplies not only the HealthGuard-15 "kiosk" but also supplies the software that will be driven by the client's computer. In addition to making the measurements, the HealthGuard-15 also provides the recognized norms for systolic and diastolic blood pressure and weight. It provides a direct comparison of the user's measurements to these established norms, thereby providing education and motivation to the user. The computer/s monitor also warns the user not to start any exercise or diet program without first discussing it with their healthcare professional.
More Information

Health Check Kiosk (K063008), Omron HEM-7200-Z (BP742) (K121932), FUTREX-6100/XL (K963271)

Not Found

No
The description focuses on integrating existing, cleared devices and providing basic comparisons to norms. There is no mention of AI/ML algorithms for data analysis, prediction, or interpretation beyond simple comparisons.

No.
The device is described as a "non-invasive screening device" that measures health metrics and provides education and motivation. It integrates other FDA-cleared devices for measurement, but its intended use and description do not mention treating, mitigating, or curing any condition.

No

The device is described as a "non-invasive screening device" and a "portable health kiosk" intended for corporate wellness facilities and health/fitness clubs. Its primary function is to measure and track health metrics (blood pressure, heart rate, body fat, weight) and provide education and motivation by comparing measurements to established norms. It explicitly states, "It is not for use in medical facilities such as hospitals or doctor's offices." While it measures health parameters, its intended use and setting are for screening and tracking in non-medical environments, not for diagnosing disease or medical conditions.

No

The device description explicitly states that the HealthGuard-15 is a "portable health kiosk" that integrates two FDA-cleared hardware devices (Omron HEM-7200-Z and FUTREX-6100/XL) for measurements. While it includes software, it is not solely software.

Based on the provided information, the HealthGuard-15 is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • IVD Definition: In Vitro Diagnostic devices are used to examine specimens taken from the human body, such as blood, urine, or tissue, to provide information about a person's health.
  • HealthGuard-15 Function: The HealthGuard-15 measures physiological parameters directly from the user's body (blood pressure, heart rate, body fat, weight). It does not analyze specimens taken from the body.
  • Intended Use/Setting: The intended use is for non-medical settings like corporate wellness facilities and health/fitness clubs, and it is explicitly stated as not for use in medical facilities. This aligns with a device that provides general health screening information rather than diagnostic information derived from laboratory analysis.

Therefore, the HealthGuard-15 falls under the category of a medical device, but not specifically an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

The HealthGuard-15 is a non-invasive screening device intended for use in corporate wellness facilities and in health/fitness clubs. It is not for use in medical facilities such as hospitals or doctors' offices. This device measures systolic and diastolic blood pressure, heart rate, percent body fat and weight. It is operated by the client supplied PC computer. The device is intended for users eighteen years and older.

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

DXN, MNW

Device Description

The HealthGuard-15 is a portable health kiosk that provides a means for measuring and tracking an individual's systolic and diastolic blood pressure, heart rate, percent body fat and weight. The HG-15 integrates two FDA market cleared devices ---- the Omron HEM-7200-Z [BP742] (K121932) for measurement of blood pressure and heart rate, and the FUTREX-6100/XL (K963271) for the estimation of the percent body fat --into a health kiosk with similar performance as the Health Check Kiosk (K063008).

The HG-15 kiosk can typically be installed in corporate offices, lunch rooms or other community places so that employees can be measured as part of a corporate wellness program to track changes over time. It is not for use in hospitals or in other health care facilities.

The HG-15 is delivered without the necessary PC computer. The client supplies the computer and Futrex supplies not only the HealthGuard-15 "kiosk" but also supplies the software that will be driven by the client's computer.

In addition to making the measurements, the HealthGuard-15 also provides the recognized norms for systolic and diastolic blood pressure and weight. It provides a direct comparison of the user's measurements to these established norms, thereby providing education and motivation to the user. The computer/s monitor also warns the user not to start any exercise or diet program without first discussing it with their healthcare professional.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Upper arm (for blood pressure measurement). Triceps area of the left arm (for percent body fat measurement).

Indicated Patient Age Range

Eighteen years and older.

Intended User / Care Setting

Intended for use in corporate wellness facilities and in health/fitness clubs. Not for use in medical facilities such as hospitals or doctors' offices.

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)

The HealthGuard-15 has been subjected to bench testing to ascertain measurement precision and accuracy compared to its predicate devices. This bench performance testing demonstrated that the HealthGuard-15 measurements are substantially equivalent to the predicate devices.
Moreover, testing by an independent laboratory has shown that the HealthGuard-15 also satisfies the EMC requirements for medical electrical equipment. Similarly, the HealthGuard-15 satisfied the safety requirements for electrical medical equipment.
Comprehensive bench performance tests were performed that proved that minor changes made to the built-in Omron BP742 device (plastic exterior covers removed, pushbutton replaced by computer command, inflation bladder's cloth cover replaced) did not affect the accuracy or precision of the systolic and diastolic blood pressure measurements and the heart rate measurement.
Comprehensive bench performance tests were performed that proved minor changes made to the built-in FUTREX-6100/XL device (measurement site on triceps at fixed distance from elbow instead of biceps, measurement always on left arm instead of dominant arm, pushbutton replaced by computer command) did not affect the accuracy or precision of the percent body fat measurements.

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.

Health Check Kiosk (K063008), Omron HEM-7200-Z (BP742) (K121932), FUTREX-6100/XL (K963271)

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

§ 870.1130 Noninvasive blood pressure measurement system.

(a)
Identification. A noninvasive blood pressure measurement system is a device that provides a signal from which systolic, diastolic, mean, or any combination of the three pressures can be derived through the use of tranducers placed on the surface of the body.(b)
Classification. Class II (performance standards).

0

Image /page/0/Picture/1 description: The image is a black and white logo for the U.S. Department of Health & Human Services. The logo features a stylized caduceus, which is a symbol often associated with medicine and healthcare. The caduceus is formed by three human profiles facing to the right. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular pattern around the caduceus.

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

March 27, 2015

Futrex, Inc. Ms. Carole Rosenthal, President 130 Western Maryland Parkway Hagerstown. MD 21740

Re: K143108

Trade/Device Name: HealthGuard-15 Regulatory Number: 21 CFR 870.1130 Regulation Name: Noninvasive Blood Pressure Measurement System Regulatory Class: Class II (Two) Product Code: DXN, MNW Dated: February 11, 2015 Received: February 18, 2015

Dear Ms. Rosenthal:

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. Isting 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

1

Page 2 - Ms. Carole Rosenthal

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,

theory, years,

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

Enclosure

2

Indications for Use

K143108 510(k) Number (if known):

Device Name: HealthGuard-15

Indications For Use:

The HealthGuard-15 is a non-invasive screening device intended for use in corporate wellness facilities and in health/fitness clubs. It is not for use in medical facilities such as hospitals or doctor's offices. This device measures systolic and diastolic blood pressure, heart rate, percent body fat and weight. It is operated by the client supplied PC computer. The device is intended for users eighteen years and older.

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

Over-The-Counter Use _________________________________________________________________________________________________________________________________________________________ (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)

Page 1 of 1

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510(k) Summarv

(Per 21 CFR 807.92)

I. Applicant

Futrex, Inc. 130 Western Maryland Parkway Hagerstown, Maryland 21740 USA

Contact: Carole Rosenthal, President Tel: 240-242-3980 Fax: 240-242-4038 E-mail: info@futrex.com or: carolerosenthal(@aol.com

II. Date Preparation

This 510(k) Summary was prepared on October 27, 2014

III. Medical Device

Trade Name: HealthGuard-15 Common Name: Non-invasive Blood Pressure and Body Composition Measurement System Classification Number: 21 CFR 870.1130 Classification: Class II Panel: Circulatory System Device Panel Product Code: DXN (for Blood Pressure) MNW (for Body Composition Analysis)

IV. Predicate Devices

  • (1) Health Check Kiosk -- (K063008)
  • (2) Omron HEM-7200-Z (BP742) -- (K121932)
  • (3) FUTREX-6100/XL -- (K963271)

V. Intended Use of the Device

The HealthGuard-15 ("HG-15") is a non-invasive screening device intended for use in corporate wellness facilities and in health/fitness clubs.

4

It is not for use in medical facilities such as hospitals or doctors' offices. This device measures systolic and diastolic blood pressure, heart rate, percent body fat and weight. It is operated by the client supplied PC computer. The device is intended for users eighteen years and older.

VI. Description of the Device

The HealthGuard-15 is a portable health kiosk that provides a means for measuring and tracking an individual's systolic and diastolic blood pressure, heart rate, percent body fat and weight. The HG-15 integrates two FDA market cleared devices ---- the Omron HEM-7200-Z [BP742] (K121932) for measurement of blood pressure and heart rate, and the FUTREX-6100/XL (K963271) for the estimation of the percent body fat --into a health kiosk with similar performance as the Health Check Kiosk (K063008).

The HG-15 kiosk can typically be installed in corporate offices, lunch rooms or other community places so that employees can be measured as part of a corporate wellness program to track changes over time. It is not for use in hospitals or in other health care facilities.

The HG-15 is delivered without the necessary PC computer. The client supplies the computer and Futrex supplies not only the HealthGuard-15 "kiosk" but also supplies the software that will be driven by the client's computer.

In addition to making the measurements, the HealthGuard-15 also provides the recognized norms for systolic and diastolic blood pressure and weight. It provides a direct comparison of the user's measurements to these established norms, thereby providing education and motivation to the user. The computer/s monitor also warns the user not to start any exercise or diet program without first discussing it with their healthcare professional.

VII. Technical Considerations

The HealthGuard-15 measures systolic and diastolic blood pressure using the standard oscillometric measurement method. The device includes a unique patented cuff mechanism suitable upper arm measurements of arm circumferences 9" to 13". When the arm is inserted in the cuff, the cuff automatically wraps around the arm similar to the way it is done in a doctor's office. The cuff is then inflated before it is gradually deflated through a series of controlled deflation steps in accordance with specification. The blood pressure measurement is controlled by the client's

5

computer using the Futrex supplied software. The only exception to this software control is the hardware "ABORT" red pushbutton that has override authority.

VIII. Substantial Equivalence

The HealthGuard-15 is substantially equivalent to these predicate devices:

  • As a multi-measurement kiosk: The Health Check Kiosk . (K063008)
  • For blood pressure measurements: The Omron HEM-7200-Z . (BP742) (K121932)
  • . For body fat measurements: the FUTREX-6100/XL (K963271)

Tables comparing various aspects of the HealthGuard-15 to its predicate devices start on the next page:

6

Predicate DeviceHealthGuard Device
Xperex, Inc. Health Check
Kiosk (K063008)Model-15Comment
Indications for UseThe Health Check is intended
to be used by the general
public so that a user can
measure health parameters
such as weight, body fat ,
blood pressure and pulse rate
in public places and/or
corporate environments. It is
not for diagnostic use.The HealthGuard-15 is a
non-invasive screening
device intended for use in
corporate wellness
facilities and in
health/fitness clubs. It is
not for use in medical
facilities such as hospitals
or doctors' offices. This
device measures systolic
and diastolic blood
pressure, heart rate,
percent body fat and
weight. It is operated by
the client supplied PC
computer. The device is
intended for users
eighteen years and older.Similar
Intended PopulationGeneral PublicHealth/Fitness ClubsSimilar
Hardware DesignXperex Health Check Kiosk
uses a built-in computer to
control blood pressure, pulse
rate and percent body fat
measurements. A STOP
pushbutton cancels the blood
pressure measurement.HealthGuard uses the PC
computer to control the
device. A STOP push
button cancels the blood
pressure measurement.Similar
Software DesignXperex Health Check Kiosk
uses software as an automated
system for measuring blood
pressure and pulse rate. It is
completely automatic, and
measures blood pressure by
the oscillometric method. The
user is guided by a series of
interactive screens and voice
instructions.The HealthGuard-15
software controls all
measurements that the
device makes. It is
completely automatic and
measures blood pressure
using the oscillometric
method. The user is
guided by a series of
interactive screens.Similar
MaterialsLatex free polyester thread for
cuff. (The rest of their
materials are unknown.)Metal housing, ABS
plastic, Nylon material
used in cuff cover, and
latex free thread in cuff
cover.Similar
Cleaning MaterialsNon-sterile; cleaning and
disinfecting instructions are
provided.Non-sterile; cleaning and
disinfecting instructions
are provided.Identical
Electromagnetic
CompatibilityUnknownMeets IEC 60601-1-2-
ComponentsBlood Pressure, Body Fat, Pulse Rate and WeightBlood Pressure, Body Fat, Pulse Rate and WeightIdentical
Blood PressureOscillometric method. The user is guided by a series of interactive screens and voice instructions.Oscillometric method. The user is guided by a series of interactive screens.Similar
Body Fat TechnologyNear-IRNear-IRIdentical
User InteractionInteractive screens and voice instructionsInteractive screensSimilar
Omron Hem-7200-ZHealthGuard-15Comment
[BP742]
(K121932)
Indications for UseThe device is a digital monitor
intended for use in measuring
blood pressure and pulse rate
in adult patient population.
The device detects the
appearance of irregular
heartbeats during
measurement and gives a
warning signal with readings.The HealthGuard-15 is a
non-invasive screening
device intended for use in
corporate wellness
facilities and in
health/fitness clubs. It is
not for use in medical
facilities such as hospitals
or doctors' offices. This
device measures systolic
and diastolic blood
pressure, heart rate,
percent body fat and
weight. It is operated by
the client supplied PC
computer. The device is
intended for users
eighteen years and older.Similar
Patient PopulationAdultAdultIdentical
Environment of UseHomeHealth & fitness centersSimilar
PrescriptiveOTCOTCIdentical
Patient ConnectionYes via cuffYes via cuffIdentical
TechnologyOscillometricOscillometricIdentical
Measurement rangePressure: 0-299 mmHg
Pulse rate: 40 to 180 bpmPressure: 0-299 mmHg
Pulse rate: 40 to 180 bpmIdentical
Accuracy or pressure
indicator+/-3 mmHg or 2% of reading+/-3 mmHg or 2% of
readingIdentical
Accuracy Pulse Rate+/-5%+/-5%Identical
Inflation MethodDC rolling pumpDC rolling pumpIdentical
Deflation MethodDynamic linear deflationDynamic linear deflationIdentical
Display TypeGraphicalGraphicalSimilar
AuscultatoryNoNoIdentical
Power SourceAA battery or AC adapterRechargeable BatterySimilar
Operating ConditionsTemperature: 10° to 40° C
Humidity: 15 to 90% RHTemperature: 10° to 40°
C
Humidity: 15 to 90% RHIdentical
Storage ConditionsTemperature: -20° to 60° C
Humidity 10 to 95% RHTemperature: -20° to 60°
C
Humidity 10 to 95% RHIdentical

Table 5.1 - Comparing the HealthGuard Device to the Predicate Kiosk Device

7

Table 5.1 (Continued)

Measurement of Blood Pressure – The predicate blood pressure measurement device is the Omron HEM-7200-Z [BP742] (K121932) - - - hereinafter called the "Omron BP742." The HealthGuard-15's blood pressure measurement is accomplished by building the Omron BP742 into the HG-15. The only modifications made to the built-in BP742 are:

  • The plastic exterior covers are removed.
  • The pushbutton that starts the measurement has been replaced by a computer command signal.
  • . The inflation bladder's cloth cover was replaced with a more durable Nylon cloth cover.

Comprehensive bench performance tests were performed that proved that these minor changes did not affect the accuracy or precision of the systolic and diastolic blood pressure measurements and the heart rate measurement.

Table 5.2 compares the specifications of the predicate Omron BP742 with the device as installed in the HealthGuard-15.

8

9

Measurement of Percent Body Fat – The predicate body fat measurement device is the FUTREX-6100/XL (K963271). The HealthGuard-15's percent body fat measurement is accomplished by building the FUTREX-6100/XL into the HG-15. The only modifications made to the FUTREX-6100/XL are:

  • . The measurement site is on the triceps area at a fixed distance from the elbow instead of at the center of the biceps.
  • . Measurement is always on the left arm instead of always being done on the dominant arm.
  • . The pushbutton that starts the measurement has been replaced by a computer command signal.

Comprehensive bench performance tests were performed that proved these changes did not affect the accuracy or precision of the percent body fat measurements.

Table 5.3 compares the specifications of the unmodified predicate FUTREX-6100/XL with the device as installed in the HealthGuard-15.

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| | Predicate Device
FUTREX-6100/XL
(K9632710 | HealthGuard-15 | Comment |
|------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------|
| Indications for Use | The FUTREX-6100/XL is to
be used to estimate the
percent body fat in adult
humans between the ages of
18-85. It has not been
validated for subjects using
diuretics or estrogen
replacement therapy. | The HealthGuard-15 is a
non-invasive screening
device intended for use in
corporate wellness facilities
and in health/fitness clubs.
It is not for use in medical
facilities such as hospitals
or doctors' offices. This
device measures systolic
and diastolic blood
pressure, heart rate, percent
body fat and weight. It is
operated by the client
supplied PC computer. The
device is intended for users
eighteen years and older. | Similar. |
| Product Code | MNW | MNW | Identical |
| Patient Population | Adults | Adults | Identical |
| Environment for Use | Not for diagnostic use | Not for diagnostic use | Identical |
| Prescriptive | OTC | OTC | Identical |
| Patient Connection | Yes via Cuff | Yes via Cuff | Identical |
| Technology | Near-IR | Near-IR | Identical |
| Prime Wavelength | 940 nm | 940 nm | Identical |
| Measurement Site | On biceps of dominant arm | On triceps of left arm | Similar (see
Note 2) |
| Measurement Time | 2 seconds approximately | 2 seconds approximately | Identical |
| Limitations | Measurement site must not
be covered with clothing | Measurement site must not
be covered with clothing | Identical |
| Data Provided to the
User | % body fat, BMI, BMR,
% lean, % water. | % body fat, BMI, BMR,
% lean, % water. | Identical |
| Measurement Range | 2 - 45% | 2 - 45% | Identical |
| Accuracy | Equal to official method of
hydrostatic weighing | Equal to official method of
hydrostatic weighing | Identical |
| Precision | 0.3% | 0.3% | Identical |
| Power Source | Batteries or an AC Adapter | 12 V Rechargeable Battery | Similar |
| Operating Conditions | Temperature: 10° to 40° C
Humidity: 15 to 90% RH | Temperature: 10° to 40° C
Humidity: 15 to 90% RH | Identical |
| Storage Conditions | Temperature: -20° to 60° C
Humidity 10 to 95% RH | Temperature: -20° to 60° C
Humidity 10 to 95% RH | Identical |

Table 5-3 – Percent Body Fat Device Measurement Comparison

NOTE 2 – Performance bench testing has been performed to demonstrate that this difference does not affect the accuracy of measurement.

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IX. Testing

The HealthGuard-15 has been subjected to bench testing to ascertain measurement precision and accuracy compared to its predicate devices. This bench performance testing demonstrated that the HealthGuard-15 measurements are substantially equivalent to the predicate devices.

Moreover, testing by an independent laboratory has shown that the HealthGuard-15 also satisfies the EMC requirements for medical electrical equipment. Similarly, the HealthGuard-15 satisfied the safety requirements for electrical medical equipment.

X. Contraindications

There are no known contraindications.

XI. Differences Between Other Legally Marketed Predicate Devices

The HG-15, as shown in the previous three tables, has only minor differences to its predicate devices. Bench testing has been performed that proved that these minor differences do not diminish the HG-15's safety or effectiveness.

XII. Indications

The indications for use are identical

  • XIII. Design and Technology - The HG-15 has equivalent design and features as its predicate devices, and uses essentially the identical technology as its predicate devices.
  • Performance and Specifications The HG-15 has equivalent specifications XIV. of performance as its predicate devices.
  • Compliance with standards The HG-15 are in compliance with the XV. following Standards:
    • -ISO 14971
    • ANSI/AAMI SP10 -
    • BS/EN 60601-1 ।

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XVI. Materials

The patient contact material of the HG-15 (the cuffs) has been FDA market cleared in other 510(k) submissions as described in Section 15 -Biocompatibility. Materials are detailed in Section 15 as well.

XVII. Environment of Use

The HG-15 is intended for use in business locations

XVIII. Patient Population

The HG-15 and its predicate devices are for populations 18 years and older.

XIX. Performance Testing

We have performed bench tests and found that the HG-15 met all requirements, specifications and standards requirements and were found to be equivalent in comparison to the predicate. Testing includes the following:

  • -Testing for compliance to IEC 60601-1
  • Testing for compliance o IEC 60601-2 -
  • Testing for compliance to AAMI SP10 -
  • Comparative Testing to the Predicate -

XX. Conclusion

Futrex maintains that the HealthGuard-15 is substantially equivalent to the predicate devices (listed in Item IV above) in indications for use, patient population, environment for use, technology characterizes, specifications/performance and compliance with international standards.