The ReDe Mask is indicated for use by healthcare facility procedural areas and recovery rooms as an adjunct to monitor breathing in adult patients who are sedated for a diagnostic or therapeutic procedure. The ReDe Mask measures the time period between the current and previous exhalation and illuminates a colored light during the exhalation that reflects the interval of time between breaths. If the interval is less than 7.5 seconds, the green light illuminates during exhalation; if the interval is greater than 7.5 seconds, the yellow light illuminates during exhalation; and if the interval between breaths is 20 seconds or longer, the red light flashes continuously. The ReDe Mask is only to be used when supplemental oxygen is provided by the facemask. The ReDe Mask is not a standalone device and is only to be used as an adjunct to pulse oximetry.

Device Description

The ReDe Mask is a breathing frequency monitor that provides a visual signal at each breath event (i.e., an inhalation followed by an exhalation). The proposed device consists of a temperature-sensing circuit attached externally to a standard face mask. This circuit continuously analyzes the temperature inside the face mask and determines when a breath event has occurred.

The ReDe Mask is designed to detect breathing events (cycles of inhalation followed by exhalation) by measuring temperature changes in the immediate vicinity of a patient's nose and/or mouth. Exhalations produce a temperature warming as expired air exits the mouth and nose, while inhalations result in a temperature cooling as ambient air and supplied oxygen enter the mask. The overall pattern is thus one of repeating periods of a warming and a cooling phase with every breath. The rate of warming and cooling, that is, the slope of the temperature change (degrees C per unit time) depends on the vigor with which the patient is breathing, which can range from very shallow breathing (small slope values) to vigorous breaths (large slope values). The ReDe Mask's breath detection algorithms are based on continuously measuring the warming and cooling slopes coupled with real-time analysis to determine the changeover point from negative slope (inhalation phase) to positive slope (exhalation phase). It is the detection of inflection points in the slope (negative to positive) that yield the elapsed time period between successive breaths. With each new breath the elapsed time between inflection points is used to determine which LED to illuminate.

AI/ML Overview

This document focuses on the ReDe Mask, a breathing frequency monitor. Here's a breakdown of the requested information based on the provided text:

1. A table of acceptance criteria and the reported device performance

The document does not explicitly state "acceptance criteria" in a tabular format with specific numerical targets. However, the various bench, biocompatibility, and clinical tests imply performance requirements. I will derive implied acceptance criteria and reported performance from the text.

Acceptance Criteria (Implied)	Reported Device Performance
Electrical Safety	Conforms to IEC 60601-1:2005 + CORR.1:2006 + CORR.2:2007 + A1:2012.
Electromagnetic Compatibility (EMC)	Conforms to IEC 60601-1-2: 2007. Classified as Group 1 Class B apparatus according to CISPR 11: 2010 clause 5.2.
Battery Discharge Sufficiency	Self-contained CR2032 coin battery provides an 8-hour life to enforce single use. (Reported as safe and effective as predicate which uses the same battery).
Ambient Temperature Operation	Operates properly in the range of 16°C to 31°C. (Reported as safe and effective, operating within the predicate's 5°C to 32°C range).
Operational Time Limits	Device properly indicates when it is about to expire to enforce single use. (Reported as safe and effective as the predicate, which lacks this feature).
Single Use Enforcement	Device properly expires to enforce single use. (Reported as safe and effective as the predicate, which lacks this feature).
Performance in Worst-Case Scenario (Breathing, TV, O2 Flow)	Operates as specified with breathing rate, tidal volume, and oxygen flow parameters, and beyond specifications. (Reported as safe and effective given predicate performance).
Aging (1 year)	Ambient aging up to 1 year does not produce loss of performance or physical integrity. (Reported as safe and effective as predicate, expecting performance beyond predicate's 3-month/1-year warranty).
Transit Conditions	Transit conditions do not produce loss of performance or physical integrity. (Reported as safe and effective by operating after transit conditions, as does predicate).
Breath Detection Accuracy	Operates as specified with breathing rate, tidal volume, and oxygen flow parameters and beyond the specifications. (Reported as safe and effective given predicate performance).
Breath Detection at BPM, TV, O2 Limits	Operates as specified with breathing rate, tidal volume, and oxygen flow parameters at the limits of the specifications. (Reported as safe and effective given predicate performance).
Light Indicator Accuracy	Operates as specified with breathing rate, tidal volume, and oxygen flow parameters and beyond the specifications, and light indicators perform as designed (green for <7.5s, yellow for 7.5s-20s, red for >=20s). (Reported as safe and effective given predicate performance).
Lifetime Consistency and Robustness (8 hours operation)	Operates as specified over the entire lifetime of 8 hours, detecting all breaths (consistency) and showing that large changes in breathing rate do not affect accuracy (robustness). (Reported as safe and effective given predicate performance).
Temperature Swings at Upper Operating Temperature (31°C)	Operates as specified at 31°C, with correct lights illuminating. Temperature swings from 0.17°C to 1.40°C over tidal volumes of 100-500ml and breathing rates of 2-45 BPM, reflecting precision and accuracy. (Reported as safe and effective given predicate performance).
Biocompatibility (Cytotoxicity, Sensitization, Intracutaneous, Systemic Toxicity)	No effects of the applied parts were noted for cytotoxicity, skin irritation or skin sensitization. (Reported as safe).
Human Factors/Usability (Ease of use, interpretation)	Instructions for use were easy to follow and the device was easy to use. All participants correctly interpreted green, yellow, and red illuminations and could see flashing LEDs from 20 feet. No observed participant use errors, close calls, or use problems. (Reported as safe and effective as predicate).
Accuracy of Exhalation/Low Respiratory Rate Detection	Equivalent in all respects to a capnograph (gold standard in monitoring breathing rate). No false positives or false negatives observed. Equivalent in performance to an ExSpiron and a capnograph, for normal, reduced, and cessation of patient breathing. (Reported as safe and without confusion).

2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

Human Factors and Usability Validation (Study 1): 30 anesthesia care providers. Provenance not explicitly stated (likely prospective, conducted for this submission).
Human Factors and Usability Validation (Study 2): Complete spectrum of healthcare providers who may use the device. Provenance not explicitly stated (likely prospective, conducted for this submission), "conducted inside the intended environment of use."
Comparison of Accuracy With Capnograph: 38 individuals (non-patient volunteers). Provenance not explicitly stated (likely prospective, conducted for this submission).
Comparison of Accuracy With ExSpiron and Capnograph: 50 individuals (non-patient volunteers). Provenance not explicitly stated (likely prospective, conducted for this submission).

The document does not specify the country of origin for these studies, but they were conducted in support of an FDA 510(k) submission, suggesting they align with US regulatory standards.

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)

The ground truth for the clinical accuracy comparisons was established using objective measurement devices:

Capnograph (end-tidal CO2 measurements): Described as the "gold standard in monitor the breathing rate of a patient."
ExSpiron (bioimpedance measurements): Used in conjunction with the capnograph.

The human factors and usability studies involved "anesthesia care providers" and "the complete spectrum of health care providers who may use the device." Their "correct interpretation" and "overwhelming positive feedback" served as an evaluation of usability, rather than ground truth generation for medical conditions.

No specific number or qualifications of "experts" (e.g., radiologists) were mentioned for establishing ground truth in the context of identifying medical conditions, as the device is a breathing monitor rather than a diagnostic tool.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

The document does not describe an adjudication method like "2+1" or "3+1" that would typically be used for expert consensus on diagnostic imaging. Instead, the accuracy studies compared the ReDe Mask's performance directly against established measurement devices (capnograph, ExSpiron). For human factors studies, a "study monitor observed and recorded any instances of subject difficulty, mishandling and/or misuse." This suggests direct observation and recording rather than a consensus-based adjudication process.

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

No, an MRMC comparative effectiveness study was not done. The ReDe Mask is a breathing frequency monitor, not an AI-assisted diagnostic tool that would typically involve "human readers" or "AI assistance" in the context of interpreting medical images or data. The studies focused on its standalone performance and usability compared to established medical monitoring devices and user interfaces.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

Yes, standalone performance was assessed in the "Comparison of Accuracy With Capnograph" and "Comparison of Accuracy With ExSpiron and Capnograph" studies. In these studies, the ReDe Mask's detection of exhalation and low respiratory rates was compared directly with the capnograph and ExSpiron, without human intervention in the ReDe Mask's core function of detecting breaths and illuminating lights. The human involvement was in observing these lights and verifying their accuracy against the reference devices.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

The ground truth used for the accuracy studies was based on objective measurements from:

Capnograph: Considered the "gold standard in monitor the breathing rate of a patient," measuring end-tidal CO2.
ExSpiron: A bioimpedance measurement device.

8. The sample size for the training set

The document does not provide information on a "training set" or "validation set" in the context of machine learning, as the ReDe Mask's breath detection relies on a temperature-sensing circuit and algorithms, rather than being explicitly described as an AI/ML device requiring significant training data. The "bench testing" and "clinical testing" described are for verification and validation of the device's performance against its specifications and predicate devices.

9. How the ground truth for the training set was established

As no specific "training set" is mentioned for an AI/ML model, the establishment of ground truth for such a set is not applicable based on the provided text. The device's breath detection algorithms are based on "continuously measuring the warming and cooling slopes coupled with real-time analysis to determine the changeover point from negative slope (inhalation phase) to positive slope (exhalation phase)." This suggests a rule-based or signal processing approach rather than data-driven machine learning that would require a distinct training set with ground truth labels.

Summary

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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

February 17, 2017

TereoPneuma, Inc. Warren Young President and COO 13223 Black Mountain Rd., Suite 1-224 San Diego, California 92129

Re: K161953

Trade/Device Name: ReDe Mask Regulation Number: 21 CFR 868.2375 Regulation Name: Breathing Frequency Monitor Regulatory Class: II Product Code: PRK Dated: January 3. 2017 Received: January 9, 2017

Dear Mr. Young:

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 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) K161953

Device Name ReDe Mask

Indications for Use (Describe)

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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510(k) Summary

Date summary prepared Jan 3, 2017

510(k) Submitter/Holder

TereoPneuma 13223 Black Mountain Rd. Ste 1-224 San Diego, CA 92129-4400

Contact

Warren G. Young, Ph.D. President and COO Telephone: 858-842-5036 Email: wyoung@tereopneuma.com

Name of Device

Trade Name	ReDe Mask
Common Name	Breathing Monitor
Classification Name	monitor, breathing frequency(21 CFR § 868.2375, class II, PRK)

Predicate Device

Trade Name:	Oral/Nasal Thermal Airflow Sensor
Device Common Name	Airflow Sensor
510(k) Number:	K080922 (cleared 7/2008)
Manufacturer:	Salter Labs

Reference Devices

Two reference devices are used in the clinical evaluations:

Trade Name:	MicroCap/NPB-75
Device Common Name	Combination Oximeter/ Carbon Dioxide Gas Analyzer
510(k) Number:	K964239
Manufacturer:	Spegas Industries Ltd.

Trade Name:	ExSpi
Device Common Name	Respi
510(k) Number:	K1200
Manufacturer:	Respi

iron ratory Monitor 087 ratory Motion, Inc.

Indications for Use

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The ReDe Mask is indicated for use by healthcare professionals in healthcare facility procedural areas and recovery rooms as an adjunct to monitor breathing in adult patients who are sedated for a diagnostic or therapeutic procedure. The ReDe Mask measures the time period between the current and previous exhalation and illuminates a colored light during the exhalation that reflects the interval of time between breaths. If the interval is less than 7.5 seconds, the green light illuminates during exhalation; if the interval is greater than 7.5 seconds but up to 20 seconds, the yellow light illuminates during exhalation; and if the interval between breaths is 20 seconds or longer, the red light flashes continuously. The ReDe Mask is only to be used when supplemental oxygen is provided by the facemask. The ReDe Mask is not a standalone device and is only to be used as an adjunct to pulse oximetry.

Intended Use

The ReDe Mask is to be used as a breathing frequency monitor by recording nasal and/or oral airflow while supplying oxygen. The ReDe Mask itself performs no diagnostic functions and only supports the recording of airflow for use as an adjunct with pulse oximetry. It is intended for adult prescription and single use only in healthcare facility procedural areas and recovery rooms.

Because sedation produces respiratory depression in every patient, healthcare providers must monitor ventilation by counting the respiratory rate during and after procedures in which sedatives are administered. Counting the respiratory rate may be inaccurate because it is difficult to gauge the rise and fall of a chest in a patient who is sedated, both because the size of the breaths are diminished by the sedatives and because the sedatives may cause airway obstruction. When the airway is obstructed, the chest continues to rise and fall as the diaphragm moves up and down, but no breath is going in and out of the patient due to the airway obstruction.

Device Description

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positive slope (exhalation phase). It is the detection of inflection points in the slope (negative to positive) that vield the elapsed time period between successive breaths. With each new breath the elapsed time between inflection points is used to determine which LED to illuminate.

Predicate Device Comparison

Similarities in the intended use and indications for use between the ReDe Mask and predicate are:

Both are to be used to record nasal and/or oral airflow while supplying oxygen.
. Both do not perform diagnostic functions and only support the recording of airflow for use as an adjunct with other clinical devices.
. Both are to be used as a breathing frequency monitor, with the proposed device conveying this information with colored indicator lights and the proposed predicate with a waveform display on a computer monitor.
Both are non-invasive medical devices. .

Differences in the intended use and indications for use between the ReDe Mask and predicate are:

. The ReDe Mask is intended to be used to measure the time period between the current and previous exhalation. The predicate averages the breathing rate over a period of time.
. The ReDe Mask uses colored light indicators to reflect the interval of time between breaths. The predicate uses waveforms on a computer monitor and digital readouts to reflect the averaged breathing rate.
. The ReDe Mask is indicated for use by healthcare professionals in healthcare facility procedural areas and recovery rooms as an adjunct to monitor breathing in adult patients who are sedated for a diagnostic or therapeutic procedure. The predicate is used in sleep laboratory settings to monitor a patient's breathing rate while sleeping.

These differences do not change the intended use for the ReDe Mask and do not raise different questions of safety and effectiveness per 807.92(a)(5).

Location of Use

The ReDe Mask is used in healthcare facility procedural areas and recovery rooms as an adjunct to monitor breathing in adult patients while the ThermiSense predicate is used in sleep laboratory settings. In both cases, the patients are not awake. The bench and clinical performance testing show that the device performs as specified within its operating ranges and effectively detects breathing in the patients in the healthcare facility procedural areas and recovery rooms. Both the ThermiSense and the ReDe Mask are designed to detect breathing rate by measuring breathing pattern waveforms. The waveforms in both devices are the electrical signals produced by each devices' thermistor circuitry in response to breathing-caused temperature changes. These waveform patterns are analyzed to determine a breathing rate. The ThermiSense transfers its waveform data to external

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equipment for analysis. The ReDe Mask retains its waveform data and performs the waveform analysis internal to the device itself. However, regardless of where the analyses take place, both devices are measuring and analyzing the same phenomenon: breathing pattern temperature waveforms. These waveforms are necessarily fundamental to the operation of both devices. Both devices measure temperature changes using thermistors, produce breathing waveforms corresponding to measured temperature patterns, and analyze those waveform patterns.

Based on these fundamental characteristics, which we view as equally inherent in both devices, we believe a claim of substantial equivalence is supported

Technological and Performance Characteristics

Technology Similarities

The ReDe Mask and the predicate were compared in the following areas and found to have similar technological characteristics and to be equivalent:

Characteristic	ReDe Mask	ThermiSense (K080922)
Similar power sourceusing a battery	Yes	Yes
Similar permanent, non-replaceable battery	Yes	Yes
Similar technology usinga thermistor	Yes	Yes
Similar electroniccomponents	Yes	Yes
Similar device function	Yes	Yes
Similar oxygen supplysystem	Yes	Yes
Similar sampling position	Yes	Yes

A. Both devices measure respiratory rate with the same technology:
- Both devices use a thermistor sensor to detect changes in temperature in the . nasal and/or oral airflow pathways reflecting exhalation and inhalation (i.e., a breath).
- . Both devices use a low-power 3V coin battery (CR2032) as the electrical power source.
- . Both devices use a battery that is permanent and non-replaceable.
B. Both devices have components that perform data analysis:
- . The ReDe Mask uses a thermistor connected to a microcontroller and other electronic components on a printed circuit board that is sealed in a small plastic housing mounted on the face mask.

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. The predicate uses a thermistor housed in a nasal cannula that is connected to other electronic components housed in a separate box that is located next to the patient,
. Both devices use firmware that performs algorithm analysis of temperature changes during exhalation and inhalation and correlates it to a breath.
C. Both devices include an oxygen supply system.
- . Uses a standard oxygen supply tube.
D. Both have similar sampling position under the nares and in the airflow path of the mouth.
- The ReDe Mask uses a face mask and elastic strap to hold in place on the face. .
- . The predicate uses a molded plastic nasal cannula.

Technology Differences

The ReDe Mask and the predicate were compared in the following areas and found to have different technological characteristics but do not impact safety or performance:

Characteristic	ReDe Mask	ThermiSense (K080922)
Requires additionalconnections	No	Yes
Data Reported	Breathing rate byway of coloredindicator lights	Airflow and breathing rate byreadout of waveform on computermonitor
Stored Data	Accumulated datastored internal tothe device.	Dependent upon recording deviceselected
Mounting Design	Face mask andelectronics housingis placed onpatient's face.	Nasal cannula and is placed onpatient's face and connected toexternal box of electronics.
Ambient OperatingTemperature	16° to 31° C	5° to 32° C
Weight	40 grams	30 grams
Dimensions (control unit)	43.43 mm H	17.2 mm H
	30.48 mm W	34.8 mm W
	14.99 mm D	57.5 mm D

A. Different methods are used to report the breathing rate:

The ReDe Mask reports the breathing rate by way of colored indicator lights. ●
. The predicate reports the breathing rate by way of a readout of a waveform on a computer monitor.

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The use of green, yellow and red lights to convey breathing rate information is simpler and easier than looking a waveform and counting the number of peaks on a moving signal on the computer monitor. This method of signaling the breathing rate does not impact safety and effectiveness of the ReDe Mask.

B. Different methods are used for the applied parts:
- The ReDe Mask uses a face mask, a housing and a thermistor as applied parts . to attach to the face of the patient.
- . The predicate uses nasal cannula as applied parts to attach to the face of the patient.

The use of a standard face mask is as safe and accepted as the use of a nasal cannula. The face mask applied part does not impact the safety and effectiveness of the ReDe Mask.

C. The ambient operating temperature of the ReDe Mask is specified in a range within the ambient operating temperature range of the predicate device.
Because the ambient operating temperature range of the ReDe Mask falls within the ambient operating temperature range of the predicate device, there is no impact on its safety and effectiveness.
D. The weight of the ReDe Mask is on 10 grams heavier than the proposed predicate.
The 10 grams heavier weight of the ReDe Mask does not impose any extra burden on the patient that would impact safety and effectiveness of the ReDe Mask.
E. The overall dimensions of the ReDe Mask is smaller than the predicate when comparing the volumes. The ReDe Mask is 19.843 cm³ while the predicate is 34.417 cm³.
The ReDe Mask is smaller and does not increase its impact on the safety and effectiveness.

Performance Data

The design of the ReDe Mask features the same operating principle, technology and manufacturing processes as the predicate device. The following performance tests were conducted to confirm the safety and effectiveness of the ReDe Mask.

Electromagnetic Compatibility Testing

The tests were performed according to following standard:

. 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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Remark: This device is ranged to the Group 1 Class B apparatus according to the standard of CISPR 11: 2010 clause 5.2.

Electrical Safety Testing

Electrical Safety Testing was conducted in accordance with the following standards:

IEC 60601-1:2005 + CORR.1:2006 + CORR.2:2007 + A1:2012 •

Bench Testing:

Test	ReDe Maskproposed device	ThermiSensepredicate device	Comment
Battery DischargeSufficiency	Self contained coinbattery (CR2032)with an 8 hour life toenforce single use.	Uses the sameCR2032 coin battery	Proposed device isas safe and effectiveas the predicate.
AmbientTemperatureSensor	Operates properly inrange from 16° - 31°C as specified.	Specified operatingrange is 5° to 32° C.	Proposed device isas safe and effectiveas the predicate byoperating well withinthe range specifiedby the predicate.
Operational TimeLimits	Properly indicatesthat device is aboutto expire to enforcesingle use.	Device has noenforceable single usemethod.	Proposed device isas safe and effectiveas the predicate.
Single UseEnforcement	Properly expires toenforce single use.	Device has noenforceable single usemethod.	Proposed device isas safe and effectiveas the predicate.
Worst-CaseScenario	Operates asspecified withbreathing rate, tidalvolume and oxygenflow parameters.	Parameters unknown.	Proposed device isas safe and effectiveas the predicategiven that thepredicate can performat least the sameparameters that arethe minimumphysiological/medicalrequirements.
Aging	Ambient aging up to1 year does notproduce loss ofperformance orphysical integrity.	Thermistor unit iswarranted for 3months and anoutboard interface boxis warranted for 1year.	Proposed device isas safe and effectiveas the predicate andwill not expire for atleast the maximumwarranty time periodoffered by thepredicate.
Transit	Transit conditions donot produce loss ofperformance orphysical integrity.	Unknown, butpresumably operatesafter transit todistributors and end-users.	Proposed device isas safe and effectiveas the predicate bycontinuing to performafter transitconditions, as doesthe predicate.
Breath Detection	Operates asspecified withbreathing rate, tidalvolume and oxygenflow parameters andbeyond thespecifications.	Parameters unknown.	Proposed device isas safe and effectiveas the predicategiven that thepredicate can performat least the sameparameters that arethe minimumphysiological/medicalrequirements.
Breath Detectionat BPM, TV andO² Limits	Operates asspecified withbreathing rate, tidalvolume and oxygenflow parameters atthe limits of thespecifications.	Parameters unknown.	Proposed device isas safe and effectiveas the proposedpredicate given thatthe proposedpredicate can performat least the sameparameters that arethe minimumphysiological/medicalrequirements.
Light IndicatorAccuracy	Operates asspecified withbreathing rate, tidalvolume and oxygenflow parameters andbeyond thespecifications andlight indicatorsperform as designed.	Parameters unknown.	Proposed device isas safe and effectiveas the predicategiven that thepredicate can performat least the sameparameters that arethe minimumphysiological/medicalrequirements.
LifetimeConsistency andRobustness	Operates asspecified over theentire lifetime of 8hours of operationdetecting all breaths(consistency) andshows that largechanges in breathingrate do not affect itsaccuracy(robustness).	Parameters unknown.	Proposed device isas safe and effectiveas the predicategiven that thepredicate can performat least the sameparameters that arethe minimumphysiological/medicalrequirements.
TemperatureSwings at UpperOperatingTemperature	Operates asspecified at theupper limits of theoperatingtemperature of 31° Cwhere all the correctlights illuminate asexpected in theirbreathing rateranges.Temperature swingsfrom a low of 0.17° Cto 1.40° C over atidal volume of 100and 500 ml andbreathing rates from2 to 45 BPM. Thevery low swingsreflect the precisionand accuracy of thedevice in detectingbreaths	Parameters unknown.	Proposed device isas safe and effectiveas the predicategiven that thepredicate can performat least the sameparameters that arethe minimumphysiological/medicalrequirements.

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Image /page/10/Picture/0 description: The image shows the logo for "TereoPneuma™". The logo consists of a stylized graphic on the left and the company name on the right. The graphic features three curved shapes in yellow, green, and red, stacked on top of each other. The company name is written in green, with the "™" symbol in a smaller font size.

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Image /page/11/Picture/0 description: The image is a logo for TereoPneuma. The logo consists of a stylized graphic on the left and the company name on the right. The graphic is a circular shape with three curved lines emanating from it in yellow, green, and red. The company name is written in green, with the letters "TereoPneuma" in a sans-serif font and the trademark symbol "TM" in superscript.

Conclusion from Bench Performance Tests

Overall, the bench performance tests shows that the ReDe Mask passes all expectations and requirements. The conclusions from bench performance test data after performing nonclinical performance and safety studies is that the data shows that the ReDe Mask is as safe, as effective, and performs as well as the predicate device.

Biocompatibility Testing:

Four biocompatibility tests were conducted by NAMSA:

. Cytotoxicity Study Using the ISO Elution Method (skin contact and external communication)
ISO Guinea Pig Maximization Sensitization Test (skin contact and external communication)
ISO Intracutaneous Study in Rabbits (skin contact and external communication)
. ISO Systemic Toxicity Study in Mice (external communication)

Conclusion from Biocompatibility Tests

No effects of the applied parts were noted for cytotoxicity, skin irritation or skin sensitization and is as safe

Clinical Testing:

ReDe Mask 510(K) Application

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Image /page/12/Picture/0 description: The image shows the logo for TereoPneuma. The logo consists of a stylized image of a green circle with a yellow arc above it and a red arc below it. To the right of the image is the company name, "TereoPneuma," in green font. The letters "TM" are in superscript to the right of the image and the company name.

The Human Factors and Usability testing of the proposed device is established by the evaluation of the user interface, user interactions and instructions accompanying the device in accordance with FDA quidance documents and established standards: Human Factors and Usability Testing per FDA Guidance Document "Applying Human Factors and Usability Engineering to Medical Devices" and ISO 14971:2012. See "Section 6 - Risk Analysis" for more information on risk and usability factor identification.

Human Factors and Usability Validation: The purpose of the HF/U validation was to determine if the instructions for use and overall device design facilitate safe and effective use for the intended users, uses and use environment. The test designs were comprised of participants running through the order of operations when operating the device, including unpacking the device, reading the IFU, using the device and disposing of the device, while a study monitor observed and recorded any instances of subject difficulty, mishandling and/or misuse. The first study utilized 30 anesthesia care providers. The participants reported that the instructions for use were easy to follow and the device was easy to use. The second study utilized the complete spectrum of health care providers who may use the device and was conducted inside the intended environment of use. In both studies, all participants were able to correctly interpret the green, yellow and red illuminations, and all were able to see the flashing LEDs from 20 feet away. The study monitor observed no observed participant use errors, close calls or use problems, and received overwhelming positive feedback that the device is easy to understand and use. These results and participant feedback support the conclusion that the ReDe mask is as safe and as effective for use as the predicate.

Comparison of Accuracy With Capnograph: The purpose of the study was to compare the detection of exhalation and low respiratory rates in non-patient volunteers using the ReDe mask device with simultaneous end-tidal CO2 (capnograph) measurements of exhalation. A total of 38 individuals participated in this study. The data show conclusively that the proposed device is equivalent in all respects to a capnograph, considered the gold standard in monitor the breathing rate of a patient. No false positives or false negatives occurred with the use of the proposed device, ensuring that it can be used safely and without confusion in the detection of breath events.

Comparison of Accuracy With ExSpiron and Capnograph: The purpose of the study was to compare the detection of exhalation and low respiratory rate in non-patient volunteers using the ReDe mask device with simultaneous bioimpedance (ExSpiron) and end-tidal CO₂ (capnograph) measurements of exhalation. A total of 50 individuals participated in this study. The study looked at normal patient breathing, reduced patient breathing and cessation of patient breathing. The study also looked at the occurrence of false negatives and false positives. The data show conclusively that the ReDe Mask is equivalent in performance to an ExSpiron and a capnograph,

Animal Testing:

Animal testing was not required to demonstrate that the proposed device met its design requirements and therefore there are no animal data associated with this device.

Conclusions from clinical performance data

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Image /page/13/Picture/0 description: The image shows the logo for TereoPneuma. The logo consists of a stylized graphic on the left and the company name on the right. The graphic is composed of three curved shapes in yellow, green, and red, with a green circle in the center. The company name "TereoPneuma" is written in green, with "TM" as a superscript.

Human factor and usability studies showed that the device use and interpretation of instructions were easy to follow. Clinical performance data shows that the proposed device performs similarly to the capnograph, and to the ExSpiron, another reference device used for monitoring breathing.

Conclusion

In establishing substantial equivalence of the ReDe Mask to the predicate device, TereoPneuma evaluated the intended use, indications for use, technological characteristics, reported adverse events and instrument risk profiles. The use of the ReDe Mask in patient monitoring environments does not raise any new types of questions of safety and effectiveness compared with the predicate device currently in use.

We believe that the ReDe Mask and the ThermiSense are substantially equivalent. Both the ThermiSense and the ReDe mask are designed to detect breathing by measuring breathing pattern waveforms. The waveforms in both devices are the electrical signals produced by each devices' thermistor circuitry in response to breathing-caused temperature changes. These waveform patterns are analyzed to determine a breathing event. The ThermiSense transfers its waveform data to external equipment for analysis. The ReDe mask retains its waveform data and performs the waveform analysis internal to the device itself. However, regardless of where the analyses take place, both devices are measuring and analyzing the same phenomenon: breathing pattern temperature waveforms. These waveforms are necessarily fundamental to the operation of both devices. Both devices measure temperature changes using thermistors, produce breathing waveforms corresponding to measured temperature patterns, and analyze those waveform patterns to arrive at a final output showing that the patient is breathing. Both devices use the same underlying technology, both devices measure and analyze waveform patterns to determine breathing. and both devices present their outputs, a display of breathing events, to clinicians in real time.

The design intent of both devices is the same; the underlying technology of both devices is the same: and the output information content of both devices is the same: breathing by the patient. Based on these fundamental characteristics, a claim of substantial equivalence is supported.

Based on the clinical and non-clinical testing performed, we believe that the ReDe mask is as safe and as effective as the predicate.

Regulation Number and Section

§ 868.2375 Breathing frequency monitor.

(a)
Identification. A breathing (ventilatory) frequency monitor is a device intended to measure or monitor a patient's respiratory rate. The device may provide an audible or visible alarm when the respiratory rate, averaged over time, is outside operator settable alarm limits. This device does not include the apnea monitor classified in § 868.2377.(b)
Classification. Class II (performance standards).