(33 days)
The Braun ThermoScan® 3 High Speed Compact Ear Thermometer is intented for the intermittent measurement and monitoring of human body temperature by consumers in the home.
The Braun ThermoScan® 3 High Speed Compact Ear Thermometer is a hand held instrument that measures human body temperature through the opening of the auditory canal. It is a single mode ear thermometer that measures the natural thermal infrared radiation emitted from the tympanic membrane and adjacent surfaces. The Braun ThermoScan® 3 High Speed Compact Ear Thermometer is meant for intermittent measurement and monitoring of human body temperature by consumers of all ages in a home use environment.
Here's an analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text:
Device: Braun ThermoScan® 3 High Speed Compact Ear Thermometer
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria (Standard) | Reported Device Performance |
|---|---|
| Accuracy (ASTM E1965 & ISO 80601-2-56): | Measurement Accuracy: |
| - ±0.2°C/0.4°F for 35.5°C | - Achieved ±0.2°C/0.4°F for 35.5°C |
| - ±0.3°C/0.5°F for 34.0°C | - Achieved ±0.3°C/0.5°F for 34.0°C |
| - ±0.3°C/0.5°F for 42.1°C | - Achieved ±0.3°C/0.5°F for 42.1°C |
| Functional testing of software error handling (ASTM E1965 and ISO 80601-2-56) | Completed, implying it met requirements. |
| Functional testing of all functions after accelerated aging (ASTM F 1980-07 and ASTM D3045) | Completed, implying it met requirements. |
| Labeling verification (ASTM E1965, ISO 80601-2-56, and IEC 60601-1) | Completed, implying it met requirements. |
| Laboratory accuracy test (ISO 80601-2-56 Clause 201.101.2 and ASTM E1965 Clause 5.3.1) | Passed requirements. |
| Clinical accuracy validation test (ASTM E1965 Clause 5.5) | Passed requirements. |
| ME equipment identification, marking and documents (ISO 80601-2-56 Clause 201.7) | Passed requirements. |
| Accuracy of controls and instruments and protection against hazardous outputs (ISO 80601-2-56 Clause 201.12) | Passed requirements. |
| Displayed Temperature Range (ASTM E1965 Clause 5.2) | Passed requirements (reportedly 34.0°C |
| Maximum Permissible Laboratory Error (ASTM E1965 Clause 5.3) | Passed requirements. |
| Special Requirements (ASTM E1965 Clause 5.5) | Passed requirements. |
| Ambient Conditions (ASTM E1965 Clause 5.6) | Passed requirements. |
| Low Power Supply Operation (ASTM E1965 Clause 5.7) | Passed requirements. |
| Display and Human Interface (ASTM E1965 Clause 5.8) | Passed requirements. |
| Construction (ASTM E1965 Clause 5.9) | Passed requirements. |
| Labeling and Marking (ASTM E1965 Clause 5.10) | Passed requirements. |
| Test Method (ASTM E1965 Clause 6) | Passed requirements. |
| Documentation (ASTM E1965 Clause 7) | Passed requirements. |
| Biocompatibility (ISO-10993-1, 10993-5, 10993-10 and FDA Bluebook Memo G95-1) | Completed, implying it met requirements. |
| Usability (IEC 62366 and FDA Guidance Document on Human Factors) | Completed, implying it met requirements. |
| Electrical Safety (IEC 60601-1:2005) | Completed, implying it met requirements. |
| Electromagnetic Compatibility (EMC) (IEC 60601-1-2: 2007) | Completed, implying it met requirements. |
2. Sample Size Used for the Test Set and Data Provenance
The document does not explicitly state the specific sample sizes for the clinical accuracy validation test (ASTM E1965 Clause 5.5) or other non-clinical tests. It only states that the tests were completed and passed the requirements of the respective standards.
Given that this is a 510(k) submission for substantial equivalence, clinical data often relies on existing predicate device performance or standards-based testing rather than extensive new clinical trials with large patient cohorts. The "clinical accuracy validation test" passed requirements per ASTM E1965 Clause 5.5, which likely specifies the minimum number of subjects and measurements for clinical accuracy determination of ear thermometers.
The data provenance is not explicitly stated in terms of country of origin or whether it was retrospective or prospective. However, tests like those conforming to ASTM E1965 and ISO 80601-2-56 usually involve prospective testing to generate the required performance data.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This information is not provided in the document. For a thermometer, the "ground truth" for temperature measurements is typically established using highly accurate reference thermometers and controlled laboratory conditions, not through expert human assessment in the same way as, for example, image interpretation. The ASTM and ISO standards would dictate the methodology for establishing this reference.
4. Adjudication Method for the Test Set
This is not applicable in the context of this device and testing. Adjudication methods like 2+1 or 3+1 are used for subjective interpretations (e.g., medical image reading) where an expert consensus is needed. For thermometer accuracy, the "truth" is objectively measured against a reference standard.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was Done
No, an MRMC comparative effectiveness study was not done. This type of study assesses how human performance improves with or without AI assistance, which is irrelevant for a standalone electronic thermometer.
6. If a Standalone (i.e. algorithm only without human-in-the loop performance) was Done
The device itself is a standalone algorithm (or rather, an electronic device) that provides temperature readings. The "non-clinical testing" and "clinical accuracy validation test" outlined directly evaluate the performance of this device in its intended standalone function, without human-in-the-loop comparison. It performs the measurement and displays the result directly.
7. The Type of Ground Truth Used
The ground truth used for assessing the device's accuracy is based on objective measurements from reference standards/equipment in laboratory and clinical settings as defined by:
- Laboratory accuracy test: Passed requirements per ISO 80601-2-56 Clause 201.101.2 and ASTM E1965 Clause 5.3.1. This involves comparing the device's readings against highly precise reference temperature sensors under controlled conditions.
- Clinical accuracy validation test: Passed requirements per ASTM E1965 Clause 5.5. This involves comparing the device's readings against established core body temperature reference methods in actual human subjects.
8. The Sample Size for the Training Set
This document describes a medical device (thermometer), not an AI/ML algorithm that requires a "training set" in the conventional sense. The device operates based on fixed physical principles and pre-programmed algorithms. Therefore, the concept of a "training set" for an AI model is not applicable.
9. How the Ground Truth for the Training Set Was Established
As established in point 8, there is no "training set" for this device. The physical and software parameters of the thermometer are designed and verified against established engineering and medical standards, not "trained" on data.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
August 16, 2016
Kaz USA, Inc., A Helen of Troy Company Ms. Amy Liu Associate Director, Clinical and Regulatory Affairs 400 Donald Lynch Blvd., Suite 300 Marlborough, Massachusetts 01752
Re: K161933
Trade/Device Name: Braun ThermoScan® 3 High Speed Compact Ear Thermometer Regulation Number: 21 CFR 880.2910 Regulation Name: Clinical Electronic Thermometer Regulatory Class: Class II Product Code: FLL Dated: July 11, 2016 Received: July 18, 2016
Dear Ms. Liu:
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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Page 2 - Ms. Amy Liu
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,
Tina Kiang -S
Tina Kiang, Ph.D. Acting 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) K161933
Device Name
Braun ThermoScan® 3 High Speed Compact Ear Thermometer
Indications for Use (Describe)
The Braun ThermoScan® 3 High Speed Compact Ear Thermometer is intented for the intermittent measurement and monitoring of human body temperature by consumers in the home.
Type of Use (Select one or both, as applicable)Prescription Use (Part 21 CFR 801 Subpart D)
|X | Over-The-Counter Use (21 CFR 801 Subpart C)
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510(k) Summary - K161933
1. Company Name and Address
Kaz USA, Inc. A Helen of Troy Company 400 Donald Lynch Blvd., Suite 300 Marlborough, MA 01752
2. Establishment Registration Number
3006169981
3. Manufacturing Sites
Famidoc Technology Co., Ltd.
No.212 Yilong Road Hexi Industrial Zone Jinxia ,Changan Town Dongguan,Guangdong Province,China.
4. Device Name
Braun ThermoScan® 3 High Speed Compact Ear Thermometer
5. Device
Classification name: Thermometer, Clinical, Electronic Classification number - 21CFR 880.2910 Product code: FLL Requlatory Class: II
6. Predicate Device Information
Predicate device: Famidoc FDIR-V1 - 510(k)#: K052849
7. Performance Standards
-
ASTM E1965-98:2003 Standard Specification for Infrared Thermometers for Intermittent Determination of Patient Temperature.
-
IEC 60601-1 31d edition:2005: Medical electrical equipment - Part 1: General requirements for basic safety and essential performance.
-
BS EN ISO 15223-1: 2012: Medical devices. Symbols to be used with medical device labels, labelling and information to be supplied. General requirements.
-
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.
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- IEC 62366-1: 2015 Medical devices - Part 1: Application of usability engineering to medical devices. 6) ISO 14971:2007: Medical devices - Application of risk management to medical devices. 7) ISO 10993-1 / ISO 10993-5 / ISO 10993-10: Biological Evaluation of Medical Devices.
8. Indications for Use
The Braun ThermoScan® 3 High Speed Compact Ear Thermometer is intended for the intermittent measurement and monitoring of human body temperature by consumers in the home.
9. Device Description and Product Change Description
The Braun ThermoScan® 3 High Speed Compact Ear Thermometer is a hand held instrument that measures human body temperature through the opening of the auditory canal. It is a single mode ear thermometer that measures the natural thermal infrared radiation emitted from the tympanic membrane and adjacent surfaces. The Braun ThermoScan® 3 High Speed Compact Ear Thermometer is meant for intermittent measurement and monitoring of human body temperature by consumers of all ages in a home use environment.
10. Technological Characteristics
The Braun ThermoScan® 3 High Speed Compact Ear Thermometer is identical to the predicated thermometer, FDIR-V1, with exception to the following changes:
- -Addition of lens filter as a sanitary barrier between the infrared thermometer and the ear canal.
- -Change in outer casing and associate industrial design to meet internal requirements.
- -Update the brand name of the device.
11. Substantial Equivalence
Based on the comparison chart above, we believe that the Braun ThermoScan® 3 High Speed Compact Ear Thermometer is substantially equivalent to its predicate device cited above and does not raise any new safety and/or effectiveness issues.
| Elements ofComparison | Subject Device | Predicate Device(Famidoc FDIR-V1) | Comparison |
|---|---|---|---|
| Device Name | Infrared EarThermometer | Infrared Thermometer | Similar |
| Models | The Braun ThermoScan®3 High Speed CompactEar Thermometer | FDIR-V1 | Similar |
| 510(k) Number | Pending | K052849 | Similar |
| Manufacturer(legal) | Kaz USA, Inc., a Helen ofTroy Company | Famidoc TechnologyCo., Ltd. | Similar |
| Contract Manufacturer | Famidoc Technology Co., | Famidoc Technology | Same |
| Ltd. | Co., Ltd. | ||
| Intended for use | The Braun ThermoScan®3 High Speed CompactEar Thermometer isintended for theintermittent measurementand monitoring of humanbody temperature byconsumers in the home. | The device is intendedfor the intermittentmeasurement andmonitoring of humanbody temperature, byconsumers in the home | Similar |
| Sensor | Infrared sensor | Infrared sensor | Similar |
| Microcontroller Unit | XWIC00834.0°C | XWIC00832.0°C~42.9°C (89.6°F~109.2°F) | SimilarSimilar (Themeasurement rangewas selected based onthe range specified inASTM E1965. Thisrange was thenincluded in the PRDand communicated toFamidoc (supplier) forinclusion in theengineeringspecification. Since thiscurrent range is asubset of the predicatedevice range it does notraise new questionsregarding theperformance andsafety. All of theverification testing wascompleted for theselected range fromASTM E1965) |
| Accuracy for bodytemperaturemeasurement | ±0.2°C/0.4°F35.5°C | ±0.2°C/0.4°F 35.5°C | Similar |
| Resolution of display | 0.1°C/0.1°F | 0.1°C/0.1°F | Similar |
| Signal output anddisplay | LCD, Buzzer | LCD, Buzzer | Similar |
| Power supply | One 3V CR2032 buttonLi-MnO2 battery | One 3V CR2032 buttonLi-MnO2 battery | Similar |
| FundamentalTechnology&Operating Principle | Uses Infrared Sensor andsignal acquisition,conditioning, processingwith embeddedmicroprocessor and | Uses Infrared Sensorand signal acquisition,conditioning, processingwith embeddedmicroprocessor and | Similar |
| software | software. | ||
| Lens filter | Yes, used | No | Demonstrated to notraise questions ofsafety andeffectiveness throughrequirements withinstandard ASTM E1965,ISO80601-2-56, ISO10993 |
| Performance | Meets ASTM E 1965, EN12470-5 and ISO80601-2-56 | Meets ASTM E 1965,EN 12470-5 andISO80601-2-56 | Similar |
| Biocompatibility | Meets ISO 10993 andFDA Bluebook memoG95-1 | Meets ISO 10993 andFDA Bluebook memoG95-1 | Similar |
| Electrical Safety | Meets IEC 60601-1 | Meets IEC 60601-1 | Similar |
| EMC | Meets IEC 60601-1-2 | Meets IEC 60601-1-2 | Similar |
Braun ThermoScan® 3 High Speed Compact Ear Thermometer
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12. Non-clinical testinq
Non-clinical performance reports were provided to document verification and validation activities which are intended to demonstrate substantial equivalence of the subject device with the noted changes, to the predicate device:
- A. Design Qualification Testing is completed to ensure that the device meets the product requirements.
- a. Functional testing of software error handling per ASTM E1965 and ISO 80601-2-56
- b. Functional testing of all functions after accelerated aging per ASTM F 1980-07 and ASTM D3045.
- c. Labeling verification per requirements within ASTM E1965, ISO 80601-2-56, and IEC 60601-1
- B. Engineering testing is completed to ensure that the device meets the performance standard requirements of ASTM E1965 and ISO 80601-2-56.
- a. Measurement accuracy after preconditioning per standard requirements: Laboratory accuracy test: passed requirements per ISO 80601-2-56 ●
- Clause 201.101.2 and ASTM E1965 Clause 5.3.1
- Clinical accuracy validation test: passed requirements per ASTM E1965 ● Clause 5.5
- b. Tests for other requirements of ISO 80601-2-56and ASTM E1965
- · Passed requirements per ISO 80601-2-56
- Clause 201.7: ME equipment identification, marking and . documents
- Clause 201.12: Accuracy of controls and instruments and . protection against hazardous outputs
- Passed requirements per ASTM E1965 ●
- Clause 5.2: Displayed Temperature Range ●
- Clause 5.3 Maximum Permissible Laboratory Error .
- Clause 5.5 Special Requirements ●
- · Passed requirements per ISO 80601-2-56
- a. Measurement accuracy after preconditioning per standard requirements: Laboratory accuracy test: passed requirements per ISO 80601-2-56 ●
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- Clause 5.6 Ambient Conditions ●
- Clause 5.7 Low Power Supply Operation
- Clause 5.8 Display and Human Interface ●
- Clause 5.9 Construction
- Clause 5.10 Labeling and Marking ●
- Clause 6 Test Method
- Clause 7 Documentation ●
- C. Process Validation was completed to ensure that the installation qualification, operational qualification and performance qualification were successfully completed for validating the manufacturing process.
- a. Soldering iron.
- Electric screw driver. ﻘ
- Constant temperature water tank C.
- d. Pad printing machine
- Injection molding e.
- 25C and 37C validation f.
- D. Biocompatibility Testing was completed in accordance with ISO-10993-1, 10993-5, 10993-10 and FDA Bluebook Memo G95-1.
- ய Usability Testing was completed in accordance with IEC 62366 and FDA Guidance Document on Human Factors titled "Applying Human Factors and Usability Engineering to Medical devices" issued on February 3, 2016.
- ட Electrical Safety, and Electromagnetic Compatibility testing was completed in accordance with IEC 60601-1:2005 and IEC 60601-1-2: 2007
13. Clinical testing
There is no change to the technological characteristics, operating principle, or intended use, of the thermometer for Braun ThermoScan® 3 High Speed Compact Ear Thermometer in comparison to the predicate device, thus clinical testing was deemed unnecessary.
14. Conclusion
Based on the performance testing and compliance with acceptable voluntary standards, we believe that the Braun ThermoScan® 3 High Speed Compact Ear Thermometer is substantially equivalent to the predicate device cited above.
§ 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.