(231 days)
The TD-1035 Thermometer device is a thermometer intended for body temperature measurement at the axillary measurement site. The device is intended for measurement in patients 12 years and older in a home use environment.
The TD-1035 Thermometer is a wrist band with sensors, which are used to measure axillary temperature. The sensors are located on the inner edge of the wrist band, so when desired the band is removed from the wrist and held under the user's underarm with the sensors contacting the underarm skin directly.
The main function of TD-1035 Thermometer is to measurement the body temperature range easily and accurately. The TD-1035 Thermometer also has a wireless data transmission function which transmits the readings from the TD-1035 Thermometer to a personnel device, such as a smart phone, tablet PC, etc., via Bluetooth pairing.
The provided document is a 510(k) summary for the TaiDoc Technology Corporation's TD-1035 Thermometer. This document focuses on demonstrating substantial equivalence to a predicate device, rather than presenting a detailed clinical study for novel acceptance criteria.
Therefore, much of the requested information (such as sample size for test and training sets, data provenance, number and qualifications of experts, adjudication methods, MRMC studies, and standalone performance) would typically be found in detailed clinical trial reports or validation studies, not usually summarized in this level of detail within a 510(k) submission.
However, based on the information available in the provided text, here's what can be extracted and inferred regarding the acceptance criteria and the methods used to demonstrate them:
1. A table of acceptance criteria and the reported device performance
The primary acceptance criteria for performance relate to accuracy, measurement range, and resolution, as compared to the predicate device and relevant international standards.
| Acceptance Criterion | Predicate Device (Omron MC-246) Performance | Proposed Device (TD-1035 Thermometer) Performance | Comments on Equivalence/Acceptance |
|---|---|---|---|
| Accuracy | 89.6°F to 107.6°F: ±0.2°F(32.0℃ to 42.0℃: ±0.1℃) | 68.00°F to 94.99°F: ±0.18°F95.00°F to 100.40°F: ±0.09°F100.41°F to 113.00°F: ±0.18°F(20.00°C to 34.99°C: ±0.10°C35.00°C to 38.00°C: ±0.05°C38.01°C to 45.00°C: ±0.10°C) | Similar, claimed accuracy is within the predicate device's tolerance and verified per ISO 80601-2-56:2009 requirements. |
| Measurement Range | 89.6°F to 107.6°F(32.0°C to 42.0°C) | 68.00°F to 113.00°F(20.00°C to 45.00°C) | Similar, claimed measurement range includes predicate's range and is verified per ISO 80601-2-56:2009 requirements. |
| Resolution | 0.1°C / 0.1°F | 0.01°C / 0.01°F | Same (or better, as resolution is higher). |
| Safety (Electrical, EMC, Shock) | Conformance to EN 60601-1, IEC 60601-1-2 | Conformance to IEC/EN 60601-1, IEC/EN 60601-1-11, IEC/EN 60601-1-2 | Verified per recognized standards. |
| Biocompatibility | Conformance to ISO10993 | Conformance to ISO 10993 (Parts 5, 10, 12) | Verified. |
| Software Validation | - | Compliant with FDA Guidance for Content of Premarket Submissions for Software Contained in Medical Devices. | Verified. |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
The document states, "The accuracy study was performed to demonstrate the TD-1035 Thermometer meet the criteria of ISO 80601-2-56:2009."
- Sample Size: The document does not specify the sample size for the accuracy study. ISO 80601-2-56:2009 outlines methods for performance evaluation but doesn't prescribe a specific sample size for a 510(k) submission summary.
- Data Provenance: The document does not specify the country of origin of the data or whether it was retrospective or prospective. It is implied to be a prospective laboratory evaluation as per the standard.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
This is not applicable as the study described is a technical performance validation against an international standard (ISO 80601-2-56:2009), not a clinical study requiring expert ground truth in the context of diagnoses or interpretations. The "ground truth" for temperature measurements in this context would be reference thermometers traceable to national standards.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable for a technical performance validation study against an international standard.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
Not applicable. The TD-1035 Thermometer is a direct measurement device (clinical electronic thermometer), not an AI-assisted diagnostic tool.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
Yes, in essence, the "accuracy study" and other performance data described are standalone evaluations of the device's inherent capabilities. The device itself performs the temperature measurement and displays it. The wireless data transmission function merely transmits these readings to a personal device; the accuracy and resolution are intrinsic to the thermometer's design.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
The "ground truth" for temperature in the accuracy study would be established by a reference standard thermometer (or suite of thermometers) that has known traceability to national or international measurement standards. ISO 80601-2-56:2009 details the requirements for such reference standards and the testing methodology.
8. The sample size for the training set
Not applicable. The TD-1035 Thermometer is a conventional electronic thermometer based on thermistor technology, not a machine learning or AI-based device that would require "training data."
9. How the ground truth for the training set was established
Not applicable, as there is no training set for this type of device.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
May 6, 2016
TaiDoc Technology Corporation Ms. Sharon Peng Regulatory Affairs Specialist 6f. No. 127. Wugong 2nd Rd Wugu District New Taipei City, 24888 TAIWAN
Re: K152680
Trade/Device Name: TD-1035 Thermometer Regulation Number: 21 CFR 880.2910 Regulation Name: Clinical Electronic Thermometer Regulatory Class: II Product Code: FLL Dated: March 18, 2016 Received: March 24, 2016
Dear Ms. Peng:
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.
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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 (OS) 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 Industry and Consumer Education 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 Industry and Consumer Education 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,
Tina
Kiang -S
for Erin I. Keith, M.S. Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control, and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known) K152680
Device Name TD-1035 Thermometer
Indications for Use (Describe)
The TD-1035 Thermometer device is a thermometer intended for body temperature measurement at the axillary measurement site. The device is intended for measurement in patients 12 years and older in a home use environment.
Type of Use (Select one or both, as applicable)
_ Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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FOR FDA USE ONLY
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510(K) Summary
This is being submitted in accordance with the requirements of 21 CFR 807.92.
The Assigned 510(K) number is: K152680
1. Submitter Information
| Company Name: | TaiDoc Technology Corporation |
|---|---|
| Contact Person: | Sharon Peng |
| Title: | Regulatory Affairs Specialist |
| Address: | 6F, No. 127, Wugong 2nd Rd., Wugu District, New Taipei City,24888, Taiwan |
| Phone: | +886-2-6625-8188 # 1176 |
| Fax: | +886-2-6625-0288 |
| E-mail: | sharon_peng@taidoc.com.tw |
| Prepared Date: | May 05, 2016 |
2. Device name:
| Proprietary Name: | TD-1035 Thermometer | |
|---|---|---|
| Common Name: | Electronic Thermometer | |
| Product Code: | FLL | |
| Review Panel: | General Hospital | |
| Device Class: | Class II | |
| Regulation Number: | 21 CFR §880.2910 | |
3. Predicate Device:
| Proprietary Name: | Omron MC-246 |
|---|---|
| 510(K) Number: | K091676 |
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4. Intended Use:
The TD-1035 Thermometer device is a thermometer intended for body temperature measurement at axillary temperature measurement site. The device is intended for measurement in patients 12 years and older in a home use environment.
5. Device Description:
The TD-1035 Thermometer is a wrist band with sensors, which are used to measure axillary temperature. The sensors are located on the inner edge of the wrist band, so when desired the band is removed from the wrist and held under the user's underarm with the sensors contacting the underarm skin directly.
The main function of TD-1035 Thermometer is to measurement the body temperature range easily and accurately. The TD-1035 Thermometer also has a wireless data transmission function which transmits the readings from the TD-1035 Thermometer to a personnel device, such as a smart phone, tablet PC, etc., via Bluetooth pairing.
6. Test Principle:
The TD-1035 Thermometer detects the temperature by thermistor, which provides signals to the microcontroller where the signals are converted into a digital temperature value that is displayed on the LCD screen.
7. Substantial Equivalence Information:
The technological characteristics of the proposed device, TD-1035 Thermometer, are compared to the predicate device (K091676) and summarized in the following table.
| Item | Predicate device | Proposed device | Comments |
|---|---|---|---|
| Classification | Class II | Class II | Same |
| Product Code | FLL | FLL | Same |
| Item | Predicate device | Proposed device | Comments |
| Indications | The Omron electronic | The TD-1035 Thermometer | Similar, the subject |
| for use | thermometer Models MC-246 | device is a thermometer | device is confined to |
| is intended to measure the | intended for body temperature | home use, and axillary | |
| body temperature either oral, | measurement at axillary | contact which is within | |
| axillaries (under arm) and | temperature measurement site. | the intended use | |
| rectal and to be used by | The device is intended for | boundary set forth by | |
| medical professionals in | measurement in patients 12 | the predicate. Safety | |
| clinical and hospital | years and older in a home use | and effectiveness is not | |
| environments and consumers | environment. | affected because the | |
| in a home environment. It is | intended use is limited | ||
| intended for use on people of | to boundaries with no | ||
| all ages. | new potential hazards. | ||
| Environment | Home and professional use | Home use | Similar, the subject |
| device is confined to | |||
| home use which is | |||
| within the intended use | |||
| boundary by the | |||
| predicate. Safety and | |||
| effectiveness is not | |||
| affected because the | |||
| use environment is | |||
| limited to boundaries | |||
| with no new potential | |||
| hazards. | |||
| Thermometer | |||
| Detection | Temperature is detected by | Temperature is detected by | Same |
| method | thermistor and calculated. | thermistor and calculated. | |
| Accuracy | 89.6°F to 107.6°F: ±0.2°F | 68.00°F to 94.98°F: ±0.18°F | Similar, the claimed |
| (32.0℃ to 42.0℃: ±0.1℃) | 95.00°F to 100.40°F: ±0.09°F | accuracy is with the | |
| 100.42°F to 113.00°F: ±0.18°F | predicate device | ||
| (20.00°C to 34.99°C: ±0.10°C | accuracy tolerance, and | ||
| 35.00°C to 38.00°C: ±0.05°C | is verified per ISO | ||
| 38.01°C to 45.00°C: ±0.10°C) | 80601-2-56:2009 | ||
| requirements. | |||
| Item | Predicate device | Proposed device | Comments |
| Measurement range | 89.6°F to 107.6°F(32.0°C to 42.0°C) | 68.00°F to 113.00°F(20.00°C to 45.00°C) | Similar, the claimed measurement range includes the range specified by the predicate and is verified per ISO 80601-2-56:2009 requirements. |
| Resolution | 0.1°C / 0.1°F | 0.01°C / 0.01°F | Same |
| Measurement area | Oral, rectum, armpit | armpit | Similar, the measurement area is the same as one area measurable using the predicate device. |
| Measurement units | °C or °F | °C or °F | Same |
| General | |||
| Power source | one LR42 battery (DC 1.5V) | one 3V CR2032 lithium battery | Similar, electrical safety is verified per recognized standards noted below. |
| Battery life | Approx. 2 years(3 times measurements / day) | Approx. 25 days(1 time measurement / day) | Different |
| Beeper | Yes | None | Different, the absence of this function is validated as acceptable via human factors testing. |
| Operating condition | 50°F to 104°F (10°C to 40°C);30% to 85% R.H. | 41°F to 104°F (5°C to 40°C);15% to 93% R.H. | Similar, this function is verified per ISO 80601-2-56:2009 requirements |
| Item | Predicate device | Proposed device | Comments |
| Storagecondition | 4°F to 140°F (-20°C to 60°C);10% to 95% R.H. | -13°F to 158°F (-25°C to70°C);10% to 95% R.H. | Similar, this function isverified per ISO80601-2-56:2009requirements |
| Datatransmission | None | Bluetooth | Different, this functionis verified per IEC62304 requirements. |
| Appearance | |||
| Dimensions: | 132.5 mm (L) x 19.4mm (W)x 10mm (H) | 40.5mm (L) x 27.5mm (W) x11.7mm (H) | Different, the physicalfeatures of the deviceare validated per IEC60601-1:2012requirement. |
| Weight (g) | 11g | 18g | Different |
| Outer casing | On/off button, LCD display,protective case, probe cover | On/off button, LCD display,armband | Different |
| Appearance | Image: Thermometer | Image: Wristband | Different |
| ConformanceStandard | • Safety: EN 60601-1• EMC: IEC 60601-1-2• Biocompatibility: ISO10993• Performance: EN 12470-3 | • Safety: EN 60601-1• EMC: IEC 60601-1-2• Biocompatibility: ISO10993• Performance: ISO80601-2-56 | Similar, ISO80601-2-56 isrecognized by the FDA |
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CONFIDENTIAL
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A comparison table that described similarities and modifications is briefly provided and demonstrates that the modified TD-1035 Thermometer is substantially equivalent to the Omron MC-246 (K091676) and does not raise new questions of safety and effectiveness.
CONFIDENTIAL
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8. Performance Data:
The submission included the following performance data for the TD-1035 Thermometer device.
The accuracy study was performed to demonstrate the TD-1035 Thermometer meet the criteria of ISO 80601-2-56:2009. The evaluation study is in compliance with the international standard.
The laboratory testing of electrical safety, electromagnetic compatibility, and shock met the relevant requirements of the applicable recognized standard: IEC/EN 60601-1, IEC/EN 60601-1-11, IEC/EN 60601-1-2 and ISO 80601-2-56.
The software validation was performed to verify and validate the proposed device works functionally and is in compliance with FDA Guidance for the Content of the Premarket Submissions for Software Contained in Medical Devices.
Biocompatibility testing included cytotoxicity, sensitization and irritation studies completed in accordance with ISO 10993, Part 5: Tests for in vitro cytotoxicity, Part 10: Tests for skin irritation and skin sensitization, and Part 12: Sample preparation and reference materials.
9. Conclusion:
The proposed devise of TD-1035 Thermometer has the same classification information, same intended use, same test principle and similar product design and specifications with the predicate device. Based on the information provided in this submission, the TD-1035 Thermometer is substantially equivalent to the predicated Digital Thermometer, model Omron MC-246 (K091676).
§ 880.2910 Clinical electronic thermometer.
(a)
Identification. A clinical electronic thermometer is a device used to measure the body temperature of a patient by means of a transducer coupled with an electronic signal amplification, conditioning, and display unit. The transducer may be in a detachable probe with or without a disposable cover.(b)
Classification. Class II (performance standards). The device is exempt from the premarket notification procedures in part 807, subpart E of this chapter, subject to the limitations in § 880.9 and the following conditions for exemption:(1) Device is not a clinical thermometer with telethermographic functions;
(2) Device is not a clinical thermometer with continuous temperature measurement functions; and
(3) Appropriate analysis and testing (such as that outlined in the currently FDA-recognized editions, as appropriate, of ISO 80601-2-56, “Medical electrical equipment—Part 2-56: Particular requirements for basic safety and essential performance of clinical thermometers for body temperature measurement,” or ASTM E1965, “Standard Specification for Infrared Thermometers for Intermittent Determination of Patient Temperature,” or ASTM E1112, “Standard Specification for Electronic Thermometer for Intermittent Determination of Patient Temperature,” or ASTM E1104, “Standard Specification for Clinical Thermometer Probe Covers and Sheaths”) must validate specifications and performance of the device.