K Number
K171828
Device Name
ETCO2 Sensor
Manufacturer
Date Cleared
2018-05-31

(345 days)

Product Code
Regulation Number
868.1400
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The intended use of the ETCO2 sensor is to provide carbon dioxide monitoring to a host monitoring system during anesthesia / recovery, in the intensive care unit (ICU), and in Emergency Medicine/Transport or Respiratory care.
Device Description
The ETCO2 Sensor is comprised of three main components, a sensor with photo detector and light emitter, cable and connector, The CO2 Sensor incorporates an infrared light source, of specified wavelength, and an infrared detector. The photo detector and light emitter end of the CO2 sensor is connected to an airway adapter. The airway adapter is connected between the patient airway and the respirator. As the patient completes an expiratory breath the sensor measures the CO2 levels in the expiratory breath and sends that data to the compatible CO2 monitor. The monitor then reads the data and converts the data so it can be displayed on screen.
More Information

Not Found

No
The device description focuses on standard infrared sensing technology for CO2 measurement and data transmission, with no mention of AI or ML algorithms for data processing or interpretation. The "Mentions AI, DNN, or ML" section explicitly states "Not Found".

No
The device is a sensor used for monitoring carbon dioxide levels, which is a diagnostic function rather than a therapeutic one. It provides data to a host system but does not directly treat or alleviate a condition.

No

The device is described as a sensor that measures CO2 levels and sends data to a monitor for display. Its intended use is for monitoring carbon dioxide during anesthesia/recovery, in the ICU, and in emergency medicine/transport or respiratory care. While the data obtained from the device can be used to inform clinical decisions, the device itself is a measurement tool and does not provide a diagnosis. It simply quantifies a physiological parameter (CO2 levels).

No

The device description explicitly states it is comprised of hardware components: a sensor with photo detector and light emitter, cable, and connector.

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

Here's why:

  • Intended Use: The intended use is to monitor carbon dioxide levels in a patient's breath during various medical procedures and settings. This is a measurement taken directly from the patient's respiratory system, not from a sample of bodily fluid or tissue that is analyzed in vitro (outside the body).
  • Device Description: The device measures CO2 in the expired breath as it passes through an airway adapter connected to the patient's airway. This is a direct measurement of a physiological parameter.
  • Lack of IVD Characteristics: There is no mention of analyzing a sample of blood, urine, tissue, or any other bodily fluid. The measurement is taken in real-time from the patient's breath.

IVD devices are typically used to examine specimens obtained from the human body to provide information for diagnosis, monitoring, or screening. This device is a physiological monitoring device.

N/A

Intended Use / Indications for Use

The intended use of the ETCO2 sensor is to provide carbon dioxide monitoring to a host monitoring system during anesthesia / recovery, in the intensive care unit (ICU), and in Emergency Medicine/Transport or Respiratory care.

Product codes

CCK

Device Description

The ETCO2 Sensor is comprised of three main components, a sensor with photo detector and light emitter, cable and connector, The CO2 Sensor incorporates an infrared light source, of specified wavelength, and an infrared detector. The photo ETCO2 Sensor-510(k) Submission Page 1 of 4
detector and light emitter end of the CO2 sensor is connected to an airway adapter. The airway adapter is connected between the patient airway and the respirator. As the patient completes an expiratory breath the sensor measures the CO2 levels in the expiratory breath and sends that data to the compatible CO2 monitor. The monitor then reads the data and converts the data so it can be displayed on screen.

The ETCO2 sensor are described as follows:

ModelDescriptionCompatible Monitor
CTM-RP01Mainstream/ 3.0MGeneral Meditech INC. Patient Monitor model G3C

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Hospitals, clinics, and other healthcare environments

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Non-clinical test data:

  1. Industry Standards for Electrical Safety, EMC and Essential Performance Testing of the ECO2 Sensor has been completed to verify compliance with FDA recognized national and international standards for electrical safety and performance for medical devices, and particular requirements applicable to this device including:
    • IEC 60601-1:2012 Basic safety and essential performance
    • IEC 60601-1-2:2007 and 2014 EMC
    • ISO 80601-2-55:2011 Respiratory gas monitors
  2. Biocompatibility: The ETCO₂ Sensor does not contain any direct or indirect patient contacting components. Patient contacting accessories are previously cleared by FDA. Biocompatibility test is not applicable for subject device.
  3. Software Verification: Software verification and validation testing were conducted and documentation was provided as recommended by FDA Software Guidance.

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

CO2 measurement Range: 0 to 150 mmHg, 0 to 19.7%
CO2 Resolution: 0.1 mmHg 0 to 69 mmHg, 0.25 mmHg 70 to 150 mmHg
CO2 Accuracy:
0 - 40 mmHg ± 2 mmHg
41 - 70 mmHg ± 5% of reading
71 - 100 mmHg ± 8% of reading
101 - 150 mmHg ± 10% of reading
Above 80 breath per minute ± 12% of reading
Respiration Rate Range: 0 to 150 breaths per minute (bpm)
Respiration Rate Accuracy: ± 1 breaths per minute (bpm)

Predicate Device(s)

K042601

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 868.1400 Carbon dioxide gas analyzer.

(a)
Identification. A carbon dioxide gas analyzer is a device intended to measure the concentration of carbon dioxide in a gas mixture to aid in determining the patient's ventilatory, circulatory, and metabolic status. The device may use techniques such as chemical titration, absorption of infrared radiation, gas chromatography, or mass spectrometry.(b)
Classification. Class II (performance standards).

0

Image /page/0/Picture/0 description: The image shows the logos of the Department of Health & Human Services and the Food and Drug Administration (FDA). The Department of Health & Human Services logo is on the left, and the FDA logo is on the right. The FDA logo includes the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

May 31, 2018

Orantech Inc. % Mei Tan RA Consultant Chonconn Medical Device Consulting Co. LTD. 22A, Hai Jing Square, No.18 Taizi Road, Nanshan District, Shenzhen, 51800 China

Re: K171828

Trade/Device Name: ETCO2 Sensor, Model CTM-RP01 Regulation Number: 21 CFR 868.1400 Regulation Name: Carbon Dioxide Gas Analyzer Regulatory Class: Class II Product Code: CCK Dated: April 30, 2018 Received: April 30, 2018

Dear Mei Tan:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part

1

801); medical device reporting of medical 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.

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.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Geeta K. Pamidimukkala -S

for 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

2

Indications for Use

510(k) Number (if known)

K171828

Device Name EtCO2 Sensor, Model CTM-RP01

Indications for Use (Describe)

The intended use of the ETCO2 sensor is to provide carbon dioxide monitoring to a host monitoring system during anesthesia / recovery, in the intensive care unit (ICU), and in Emergency Medicine/Transport or Respiratory care.

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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3

510(K) Summary K171828

1. Prepared Date: 2018/5/30

2. Submitter Information

NameOrantech Inc.
AddressZone#A,4F,1st Bld,7th Industrial Zone,Yulv Community,
GongMing, Guangming New District, Shenzhen,China 518106
Contact personMr. Hsin Xiong
Tel0755-23699939
Fax0755-23243594
EmailYunxi.xiong@orantech.cn

3. Submission Correspondent

NameChonconn Medical Device Consulting Co.LTD.
Address22A,HaiJing Square,No.18 Taizi Road,Nanshan District,
Shenzhen,Guangdong,P.R.China,
Contact personMei(RA consultant)
E-mailFDA@chonconn.com/Xinmeitan@chonconn.com
Tel+86-755-33941160

4. Proposed Device Information

Trade NameETCO2 Sensor
ModelCTM-RP01
Common nameCarbon Dioxide (CO2) Analyzer
Regulatory classII
Production regulation21 CFR §868.1400
Product codeCCK
PanelAnesthesiology

5. Predicate Device Information

510(K)No.Trade Name/modelSubmitter
K042601Capnostat 5 CO2 sensorRespironics Novametrix, LLC

6. Device description

The ETCO2 Sensor is comprised of three main components, a sensor with photo detector and light emitter, cable and connector, The CO2 Sensor incorporates an infrared light source, of specified wavelength, and an infrared detector. The photo ETCO2 Sensor-510(k) Submission Page 1 of 4

4

detector and light emitter end of the CO2 sensor is connected to an airway adapter. The airway adapter is connected between the patient airway and the respirator. As the patient completes an expiratory breath the sensor measures the CO2 levels in the expiratory breath and sends that data to the compatible CO2 monitor. The monitor then reads the data and converts the data so it can be displayed on screen.

The ETCO2 sensor are described as follows:

ModelDescriptionCompatible Monitor
CTM-RP01Mainstream/ 3.0MGeneral Meditech INC. Patient Monitor model G3C

7. Intended use & Indications for Use

The intended use of the ETCO2 sensor is to provide carbon dioxide monitoring to a host monitoring system during anesthesia / recovery, in the intensive care unit (ICU), and in Emergency Medicine/Transport or Respiratory care.

8. Comparison to predicate device

The following is provided as a summary of how the technological characteristics of the device compare to the predicate device

| Comparison

itemSubject DevicePredicate DeviceComments
510(K) numberPending applicationK042601--
DeviceCTM-RP01Capnostat 5 CO2 sensor--
Intended use
&Indications for
UseThe intended use of the ETCO2
sensor is to provide carbon
dioxide monitoring to a host
monitoring system during
anesthesia / recovery, in the
intensive care unit (ICU), and
in Emergency
Medicine/Transport or
Respiratory care.The intended use of the
Capnostat 5 CO2 sensor is to
provide carbon dioxide
monitoring to a host monitoring
system during anesthesia /
recovery, in the intensive care
unit (ICU), and in Emergency
Medicine/Transport or
Respiratory careSame
Environment of
UseHospitals, clinics, and other
healthcare environmentsHospitals, clinics, and other
healthcare environmentsSame
Measurement
TechniqueNon-dispersive infrared (NDIR)
Infrared spectroscopyNon-dispersive infrared (NDIR)
Infrared spectroscopySame
CO2
measurement
Range0 to 150 mmHg, 0 to 19.7%0 to 150 mmHg, 0 to 19.7%Same
CO2 Resolution0.1 mmHg 0 to 69 mmHg
0.25 mmHg 70 to 150 mmHg0.1 mmHg 0 to 69 mmHg
0.25 mmHg 70 to 150 mmHgSame

Table1 Comparison between CTM-RP01 sensor and Capnostat 5 CO2 sensor

5

CO2 Accuracy0 - 40 mmHg ± 2 mmHg0 - 40 mmHg ± 2 mmHgSame
41 - 70 mmHg ± 5% of
reading41 - 70 mmHg ± 5% of reading
71 - 100 mmHg ± 8% of
reading71 - 100 mmHg ± 8% of reading
101 - 150 mmHg ± 10% of
reading101 - 150 mmHg ± 10% of reading
Above 80 breath per minute ±
12% of readingAbove 80 breath per minute ±
12% of reading
* NOTE: Gas temperature at
25°C* NOTE: Gas temperature at
25°C
Respiration
Rate Range0 to 150 breaths per minute
(bpm)0 to 150 breaths per minute
(bpm)Same
Respiration
Rate Accuracy± 1 breaths per minute (bpm)± 1 breaths per minute (bpm)Same
Voltage
Requirements5.0 VDC ±5%5.0 VDC ±5%Same
InterconnectionLemo Redel 8-pin plasticLemo Redel 8-pin plasticSame
Temperature
and HumidityOperating: 0 to 40°C, 15 to
85% RH, non-condensing
Storage: -10 to 40°C,