K Number
K172616
Device Name
Pulse Oximeter
Date Cleared
2018-07-27

(330 days)

Product Code
Regulation Number
870.2700
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
PULSE OXIMETER SHO-3002,SHO-3006 and SHO-3008 is a portable non-invasive, spot-check, oxygen saturation of arterial hemoglobin (SpO2) and pulse rate of adult at hospital (including clinical use internist/surgery, Anesthesia etc ).It is not for continuously monitoring.
Device Description
The devices consist of detector and emitter LED, CPU, display unit and power unit. The Pulse oximeter is a kind of innovated medical detection device with non-invasive and continuous features for arterial SPO2 and PR detection. The proposed device consists of photo detector and emitter, LED, CPU, data display unit and power unit. It is portable and easy to measure the SPO2 and PR value quickly and precisely. The series of pulse oximeter detect the body's oxygen saturation and pulse rate through the fingers. The device does not contain drug or biological products. The power sources of the proposed devices are 2 AAA alkaline batteries. All the proposed devices have low battery voltage indicator function, and all the proposed devices will automatically power off when there is no signal for longer than 5 seconds. The proposed devices are not for life-supporting or life-sustaining, not for implant. The devices or transducers are not sterile and the transducers are reusable and do not need sterilization. The devices are for prescription. The devices do not contain drug or biological products. The Pulse oximeter SHO-3002, SHO-3006 and SHO-3008 share the same measurement principle and oximeter sensor and oxygen saturation module and power supply. The indented target population and use environment of the Pulse oximeter SHO-3002, SHO-3006 and SHO-3008 are the same. The devices are software-driven and the software validation is provided in Section of Software.
More Information

Not Found

No
The description focuses on standard pulse oximetry technology (photo detector, emitter, CPU) and does not mention any AI/ML components or algorithms. The performance studies are based on standard clinical trial procedures for pulse oximeters, not AI/ML model validation.

Yes
The device is described as a "medical detection device" and is used in a "hospital" setting for "oxygen saturation of arterial hemoglobin (SpO2) and pulse rate" measurement, which are diagnostic indicators used in healthcare.

Yes

Explanation: The device measures oxygen saturation of arterial hemoglobin (SpO2) and pulse rate, which provides physiological data used to assess a patient's condition and help in the diagnosis of various medical issues.

No

The device description explicitly states it consists of hardware components such as a detector and emitter LED, CPU, display unit, and power unit, in addition to being software-driven.

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

Here's why:

  • IVD Definition: In vitro diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections.
  • Device Function: The description clearly states that the Pulse Oximeter SHO-3002, SHO-3006, and SHO-3008 are "portable non-invasive, spot-check, oxygen saturation of arterial hemoglobin (SpO2) and pulse rate of adult". It measures these parameters through the fingertip, which is a non-invasive method.
  • No Sample Analysis: The device does not analyze any samples taken from the body. It uses light to measure oxygen saturation and pulse rate directly through the skin.

Therefore, since the device does not perform tests on samples taken from the body, it does not fit the definition of an In Vitro Diagnostic.

N/A

Intended Use / Indications for Use

PULSE OXIMETER SHO-3002,SHO-3006 and SHO-3008 is a portable non-invasive, spot-check, oxygen saturation of arterial hemoglobin (SpO2) and pulse rate of adult at hospital (including clinical use internist/surgery, Anesthesia etc ).It is not for continuously monitoring.

Product codes

DQA

Device Description

The devices consist of detector and emitter LED, CPU, display unit and power unit.

The Pulse oximeter is a kind of innovated medical detection device with non-invasive and continuous features for arterial SPO2 and PR detection. The proposed device consists of photo detector and emitter, LED, CPU, data display unit and power unit. It is portable and easy to measure the SPO2 and PR value quickly and precisely.

The series of pulse oximeter detect the body's oxygen saturation and pulse rate through the fingers. The device does not contain drug or biological products.

The power sources of the proposed devices are 2 AAA alkaline batteries. All the proposed devices have low battery voltage indicator function, and all the proposed devices will automatically power off when there is no signal for longer than 5 seconds.

The proposed devices are not for life-supporting or life-sustaining, not for implant. The devices or transducers are not sterile and the transducers are reusable and do not need sterilization. The devices are for prescription. The devices do not contain drug or biological products.

The Pulse oximeter SHO-3002, SHO-3006 and SHO-3008 share the same measurement principle and oximeter sensor and oxygen saturation module and power supply. The indented target population and use environment of the Pulse oximeter SHO-3002, SHO-3006 and SHO-3008 are the same.

The devices are software-driven and the software validation is provided in Section of Software.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

nail tip, fingers

Indicated Patient Age Range

adult

Intended User / Care Setting

hospital (including clinical use internist/surgery, Anesthesia etc)

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 Tests Performed:
The following testing was performed on the Pulse Oximeter SHO-3002, SHO-3006 and SHO-3008 in accordance with the requirements of the design control regulations and established quality assurance procedures.
a. ES60601-1:2005(R) 2012, Medical electrical equipment-Part 1: General requirements for basic safety, and essential performance.
b. IEC60601-1-2:2014, Medical electrical equipment-Part 1-2: General requirements for basic safety and essential performance - Collateral standard: Electromagnetic compatibility-Requirements and tests.
c. ISO80601-2-61:2011, Medical electrical equipment-Part 2-6 1: Particular requirements for basic safety and essential performance of pulse oximeter equipment.
d. ISO10993-1:2009, Biological evaluation of medical devices -Part 1:Evaluation and testing within a risk management process
e. ISO 10993-5:2009, Biological evaluation of medical devices - PartS5: Tests for In Vitro cytotoxicity.
f. ISO10993-10:2010, Biological evaluation of medical devices-Part10: Tests for irritation and skin sensitization
g. Software Validation and Verification Test.
h. Use Life Test.
i. SpO2 Accuracy and Pulse Rate Accuracy Test (Test after the repeated clean & disinfection conditions).
j. SpO2 Accuracy and Pulse Rate Accuracy Test (Test under the normal conditions).
k. SpO2 Accuracy and Pulse Rate Accuracy Test (Test under the low perfusion conditions).

  1. Storage Condition Test

Summary of the biocompatibility tests performed on the device:
Direct contacting the skin components included Plastic Shell (ABS Novodur HD M203FC ) and color additives (BASF K7090, BASF L0080) , Silica gel pad (Medical grade silica gel HCRU4470) and color additives (SUNWELL SILICONES P801. Plastic Shell included ABS and color additives, Silica gel pad included medical grade silica gel and color additives were tested together. Because the material only contact with the user's intact skin within 24 hours, so according to ISO 10993-1:2009, the In Vitro Cytotoxicity Test, Skin Sensitization Test and Skin Irritation Test have been performed.

Clinical Trial Conclusion:
The Pulse Oximeter SHO-3002, SHO-3006 and SHO-3008 share the same pulse oximeter sensor, algorithm and oxygen saturation module. So, we considered a clinical test of one of the proposed devices could cover that of other devices. The clinical test of other proposed devices can be exempted. And we conducted clinical test for one of the proposed devices, and the model is SHO-3002.

The clinical trial was performed according to Annex EE.2 Procedure for invasive laboratory testing of ISO80601-2-61:2011, Medical electrical equipment-Part 2-6 1: Particular requirements for basic safety and essential performance of pulse oximeter equipment.

It can be determined from the result of the clinical study that the accuracy Arms of the proposed device is smaller than 2%.

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

Accuracy: SpO2 70%100%: ±2%, 069%:unspecified; PR ±2bpm (all models: SHO-3002, SHO-3006, SHO-3008).

Predicate Device(s)

K130947

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 870.2700 Oximeter.

(a)
Identification. An oximeter is a device used to transmit radiation at a known wavelength(s) through blood and to measure the blood oxygen saturation based on the amount of reflected or scattered radiation. It may be used alone or in conjunction with a fiberoptic oximeter catheter.(b)
Classification. Class II (performance standards).

0

Image /page/0/Picture/0 description: The image shows the logo for the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA text logo on the right. The FDA text logo is in blue and includes the acronym "FDA" followed by "U.S. FOOD & DRUG ADMINISTRATION" in a stacked format.

Beijing Safe Heart Technology Ltd. Xiaoming Yang Quality Manager Room 101, Unit 6, Building NO.6 No.88 Kechuang 6th Street Beijing Economic-Technological Development Area, 101111 Cn

Re: K172616

Trade/Device Name: Pulse Oximeter Regulation Number: 21 CFR 870.2700 Regulation Name: Oximeter Regulatory Class: Class II Product Code: DQA Dated: June 29, 2018 Received: June 29, 2018

Dear Xiaoming Yang:

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 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);

1

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 comprehensive regulatory information about medical devices and radiation-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. Todd D. Courtney -S

Tina Kiang, Ph.D. for 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) K172616

Device Name PULSE OXIMETER

Indications for Use (Describe)

PULSE OXIMETER SHO-3002,SHO-3006 and SHO-3008 is a portable non-invasive, spot-check, oxygen saturation of arterial hemoglobin (SpO2) and pulse rate of adult at hospital (including clinical use internist/surgery, Anesthesia etc ).It is not for continuously monitoring.

Type of Use (Select one or both, as applicable)
X Prescription Use (Part 21 CFR 801 Subpart D)Over-The-Counter Use (21 CFR 801 Subpart C)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

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Section 6 - 510(k) Summary

Date of Summary Preparation: 06/21/2018

1. Submitter's Identifications

Submitter's Name: Beijing Safe Heart Technology Ltd. Address: Room 101, Unit 6, Building NO.6, No.88 Kechuang 6th Street,Beijing Economic-Technological Development Area, 101111 Beijing, P. R. China Contact Person: Mr. Xiaoming Yang Contact Email Address: Email: QA@safeheart.com.cn Phone number: +86- 10-61253661 Fax number: +86- 10-61253660-897

2. Correspondent's Identifications

Submitter's Name: Beijing Safe Heart Technology Ltd. Address: Room 101, Unit 6, Building NO.6, No.88 Kechuang 6th Street, Beijing Economic-Technological Development Area, 101111 Beijing, P. R. China Contact Person: Mr. Xiaoming Yang Contact Email Address: Email: QA@safeheart.com.cn Phone number: +86-10-61253661 Fax number: +86-10-61253660-897 3. Name of the Device

Device Classification Name: Oximeter Product Name: Pulse Oximeter Trade Name: Pulse Oximeter Model :SHO-3002,SHO-3006,SHO-3008 Classification Panel: Cardiovascular Product Code: DQA Device Classification: Class II

4. The Predicate Devices

K130947 MD300C1.MD300C2 Fingertip pulse Oximeter 21 CFR 870.2700

5. Device Description

The devices consist of detector and emitter LED, CPU, display unit and power unit.

The Pulse oximeter is a kind of innovated medical detection device with non-invasive and continuous features for arterial SPO2 and PR detection. The proposed device consists of photo detector and emitter, LED, CPU, data display unit and power unit. It is portable and easy to measure the SPO2 and PR value quickly and precisely.

The series of pulse oximeter detect the body's oxygen saturation and pulse rate through the fingers. The device does not contain drug or biological products.

4

The power sources of the proposed devices are 2 AAA alkaline batteries. All the proposed devices have low battery voltage indicator function, and all the proposed devices will automatically power off when there is no signal for longer than 5 seconds.

The proposed devices are not for life-supporting or life-sustaining, not for implant. The devices or transducers are not sterile and the transducers are reusable and do not need sterilization. The devices are for prescription. The devices do not contain drug or biological products.

The Pulse oximeter SHO-3002, SHO-3006 and SHO-3008 share the same measurement principle and oximeter sensor and oxygen saturation module and power supply. The indented target population and use environment of the Pulse oximeter SHO-3002, SHO-3006 and SHO-3008 are the same.

The devices are software-driven and the software validation is provided in Section of Software.

6. Principle of operation and mechanism of action of the device

The device works by applying a sensor to a pulsating arteriolar vascular bed. The sensor contains a dual light source and photo detector. The wavelength of one light source is 660mm, which is red light; the other is 905nm, which is infrared light.

A mathematical formula is established making use of Lambert Beer Law according to Spectrum Absorption Characteristics of Reductive hemoglobin (RHb) and Oxyhemoglobin (HbO2) in glow and near-infrared zones.

Operation principle of the instrument: Photoelectric Oxyhemoglobin Inspection Technology is adopted in accordance with Capacity Pulse Scanning and Recording Technology, so that two beams of different wavelength of lights can be focused onto a human nail tip through a clamping finger-type sensor. A measured signal obtained by a photosensitive element, will be shown on the oximeter's display through process in electronic circuits and microprocessor.

7. Intended Use of Device

PULSE OXIMETER SHO-3002, SHO-3006 and SHO-3008 is a portable non-invasive, spot-check, oxygen saturation of arterial hemoglobin (SpO2) and pulse rate of adult at hospital (including clinical use internist/surgery, Anesthesia etc). It is not for continuously monitoring.

8. Summary of Substantial Equivalence

Table 1: The difference between SHO-3002, SHO-3006 and SHO-3008.

SHO-3002SHO-3006SHO-3008
DisplaySpo235%~100%35%~100%35%~100%
RangePR30bpm~250bpm30bpm~250bpm30bpm~250bpm
MeasurementSpo235%~100%35%~100%35%~100%
RangePR30bpm~250bpm30bpm~250bpm30bpm~250bpm
AccuracySpo270%~100%: ±2%,70%~100%: ±2%,70%~100%: ±2%,
0~69%:unspecified0~69%:unspecified0~69%:unspecified
PR±2bpm±2bpm±2bpm
ResolutionSpo21%1%1%
PR1 bpm1 bpm1 bpm

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Display ScreenOLEDOLEDOLED
Pulse waveform displayYYY
Four direction displayYYY
Dimension
( L x W x H )57mm x 31. 5mm x 30.
5mm57mm x 31. 5mm x
  1. 5mm | 57mm x 31. 5mm x 30.
    5mm |
    | Appearances and color | Different | Different | Different |
    | Structure and composition | The proposed device
    consists of photo
    detector and emitter
    LED, CPU, data
    display unit and power
    unit. | The proposed device
    consists of photo
    detector and emitter
    LED, CPU, data
    display unit and
    power unit. | The proposed device
    consists of photo
    detector and emitter
    LED, CPU, data display
    unit and power unit. |
    | Operating style | Fingertip | Fingertip | Fingertip |
    | Accessories | 1. One lanyard
  2. Two batteries
  3. One user's manual | 1. One lanyard
  4. Two batteries
  5. One user's manual | 1. One lanyard
  6. Two batteries
  7. One user's manual |
    | | | | |

Beijing Safe Heart Technology Ltd.

Table 2 : The difference between Proposed Device and Predicate Device

Comparison ElementsProposed DevicePredicate DeviceComparison
Device NamePulse oximeterFingertip pulse Oximeter (K130947)Similar
ModelSHO-3002,SHO-3006 and SHO-3008MD300C1,MD300C2-----
Regulation No.21 CFR 870.270021 CFR 870.2700Same
ClassificationIIIISame
Classification NameOximeterOximeterSame
Product CodeDQADQASame
Indications for UsePULSE OXIMETER
SHO-3002,SHO-3006 and
SHO-3008 is a portable
non-invasive, spot-check, oxygen
saturation of arterial hemoglobin
(SpO2) and pulse rate of adult at
hospital (including clinical use
internist/surgery, Anesthesia
etc). It is not for continuouslyThe Fingertip Pulse
Oximeter MD300C series,
are portable, non-invasive
devices intended for spot
checking of arterial
hemoglobin oxygen
saturation(SPO2) and pulse
rate of adult and pediatric
patient at hospital (includingSimilar
monitoring.clinical use in
internist/surgery, Anesthesia,
and intensive care units).
Comparison StatementThe proposed devices have the same indications for use and classification.
Detector and emitter LED,Similar
ComponentsThe applicant device consists ofsignal amplify unit, CPU, data display unit and power unit.
photo detector and emitter LED, CPU, data display unit and power unit.
Design PrincipleA mathematical formula is established making use of Lambert Beer Law according to Spectrum Absorption Characteristics of Reductive hemoglobin (RHb) and Oxyhemoglobin (HbO2) in glow and near-infrared zones. Operation principle of the instrument: Photoelectric Oxyhemoglobin Inspection Technology is adopted in accordance with Capacity Pulse Scanning and Recording Technology, so that two beams of different wavelength of lights can be focused onto a human nail tip through a clamping finger-type sensor. A measured signal obtained by a photosensitive element, will be shown on the Oximeter's display through process in electronic circuits and microprocessor shown on the Oximeter's display through electronic circuits and a microprocessor.Skin, bone, tissue, and venous vessels normally absorb a constant amount of light over time. The photo detector in finger sensor collects and converts the light into electronic signal which is proportional to the light intensity. The arteriolar bed normally pulsates and absorbs variable amount of light during systole and diastole, as blood volume increases and decreases. The ratio of light absorbed at systole and diastole is translated into an oxygen saturation measurement. This measurement is referred to as SPO2.Similar
MeasurementRed660nm660nmSame
WavelengthInfrared905nm940nmThe
wavelength of
IR led is
different.
SE Note 1
Comparision StatementThe proposed devices have the same design principle and similar components.
Display TypeOLEDLED:MD300C1Same
Working timeWork about 30 hours continuously.OLED:MD300C2Work for 30 hours continuouslySame
Power Supply2 * AAA2 * AAASame
Display DataSPO2, PRSPO2, PRSame
Spo2 Display Range35%~100%0~99%: MD300C1
0~100%: MD300C2Same
Spo2 Accuracy70%100%: ±2%, 069% is no definitionMD300C1: 7099% is ±2%, 069% is no definition
MD300C2: 70100% is ±2%, 069% is no definitionThe Spo2 Display Range is different.
SE Note 2
Spo2 resolution1%1%Same
PR display range30~250bpm0~254 bpmThe PR range of the predicate device is bigger.
SE Note 3
PR Accuracy±2bpm±2bpm(3099bpm) and 2%(100235bpm)Same
PR resolution1 bpm1 bpmSame
Operating temperature+5°~+40°C+5°~+40°CSame
Relative humidity15%~90% (Operating),
15%~93% (Storage)≤80%(Operating)
≤93%( storage)Similar
Atmosphere pressure860hPa~1060hPa (Operating)
500hPa-1060hPa (Storage )86~106 kPaSimilar
Pulse BeepNot AvailableNot AvailableSame
Comparison StatementThe applicant device has similar device specifications as the predicate device.
ContactingBattery coverABSABSSame
MaterialFingertip
CushionMedical Silica gelMedical Silica gelSame
EnclosureABSABSSame
Comparsion StatementThe contacting materials of applicant device are same as to the predicate device.
Performance
TestingBench TestThe bench test include SpO2
accuracy test, pulse rate test, FFC
bending test, drop test, function test
and test according to
ISO80601-2-61.All the bench test
results are provide in performance
Testing-BenchMeet the requirements of FDA Guidance.Similar

6

Beijing Safe Heart Technology Ltd.

7

Beijing Safe Heart Technology Ltd.

8

Beijing Safe Heart Technology Ltd.
Clinical TestConformed to ISO80601-2-61Conformed to ISO 9919Similar
Electromagnetic
Compatibility
SafetyElectrical
SafetyConformed to IEC60601-1.
The test results are provided in
Electromagnetic Compatibility and
Electrical Safety.Conformed to
IEC60601-1Same
Electromagnetic
CompatibilityConformed to IEC60601-1-2.
The test results are provided in
Electromagnetic Compatibility and
Electrical Safety.Conformed to
IEC60601-1-2Same
SoftwareModerate level of Concern

Compliance with FDA Guidance for
the content of Premarket Submissions
for Software Contained in Medical
Devices. | Moderate level of
Concern

Compliance with FDA
Guidance for the content
of Premarket
Submissions for Software
Contained in Medical
Devices. | Same | |
| Biocompatibility | Medical
Silica gel | In Vitro
Cytotoxicity | No cytotoxic
potential

In Vitro
Cytotoxici
ty | No
cytotoxic
potential | Same |
| | | Skin Irritation Test | No evidence of
causing
sensitization

Skin
Irritation
Test | No evidence
of causing
sensitization | Same |
| | | Skin Sensitization
Test | No evidence of
significant
irritation from
the test extract
to rabbits

Skin
Sensitizati
on Test | No evidence
of
significant
irritation
from the
test extract
to rabbits | Same |
| | Label and Labeling | Compliance with FDA guidance | Compliance with FDA
guidance | Similar | |

9. Substantial Equivalence:

SE Note 1:

The degree of light absorption and the degree of light scattering of blood are mainly related to the content of oxygenated hemoglobin, which is feasible in the infrared spectrum area (800nm ~ 1000nm). Although the "Measurement Wavelength" of the subject device is slightly different from the predicate device ,all devices comply with infrared spectrum area (800nm ~ 1000mm), ES 60601-1 and ISO80601-2-61 requirements. These differences do not raise different questions of safety and effectiveness. SE Note 2:

When the human blood oxygen saturation value less than 60%, the non-invasive blood oxygen error will be

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relatively large. So, non-invasive blood oxygen products will be specified in the Spo2 Accuracy measurement, 0 ~ 69% interval is not definition. Although the "Spo2 Display Range" of the subject device is slightly different from the predicate devices comply with clinical application, ES60601-1 and ISO80601-2-61 requirements. These differences do not raise different questions of safety and effectiveness.

SE Note 3:

Clinical experience show that range of the pulse rate interval 30bpm, has been able to meet the clinical application. Although the "PR Display Range" of the subject device is slightly different from the predicate device ,all devices comply with clinical application, ES60601-1 and ISO80601-2-61 requirements. These differences do not raise different questions of safety and effectiveness.

According to the non-clinical and clinical test results, the proposed devices are as safe, as effective and perform as well as the predicate device. So, the proposed devices are Substantially Equivalent (SE) to the predicate device which is US legally market device.

10. Non-Clinical Tests Performed:

The following testing was performed on the Pulse Oximeter SHO-3002, SHO-3006 and SHO-3008 in accordance with the requirements of the design control regulations and established quality assurance procedures.

a. ES60601-1:2005(R) 2012, Medical electrical equipment-Part 1: General requirements for basic safety, and essential performance.

b. IEC60601-1-2:2014, Medical electrical equipment-Part 1-2: General requirements for basic safety and essential performance - Collateral standard: Electromagnetic compatibility-Requirements and tests.

c. ISO80601-2-61:2011, Medical electrical equipment-Part 2-6 1: Particular requirements for basic safety and essential performance of pulse oximeter equipment.

d. ISO10993-1:2009, Biological evaluation of medical devices -Part 1:Evaluation and testing within a risk management process

e. ISO 10993-5:2009, Biological evaluation of medical devices - PartS5: Tests for In Vitro cytotoxicity.

f. ISO10993-10:2010, Biological evaluation of medical devices-Part10: Tests for irritation and skin sensitization

g. Software Validation and Verification Test.

h. Use Life Test.

i. SpO2 Accuracy and Pulse Rate Accuracy Test (Test after the repeated clean & disinfection conditions).

j. SpO2 Accuracy and Pulse Rate Accuracy Test (Test under the normal conditions).

k. SpO2 Accuracy and Pulse Rate Accuracy Test (Test under the low perfusion conditions).

  1. Storage Condition Test

11. Summary of the biocompatibility tests performed on the device.

Direct contacting the skin components included Plastic Shell (ABS Novodur HD M203FC ) and color additives (BASF K7090, BASF L0080) , Silica gel pad (Medical grade silica gel HCRU4470) and color additives (SUNWELL SILICONES P801. Plastic Shell included ABS and color additives, Silica gel pad included medical grade silica gel and color additives were tested together. Because the material only contact with the user's intact skin within 24 hours, so according to ISO 10993-1:2009, the In Vitro Cytotoxicity Test, Skin Sensitization Test and Skin Irritation Test have been performed.

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12. Clinical Trial Conclusion

The Pulse Oximeter SHO-3002, SHO-3006 and SHO-3008 share the same pulse oximeter sensor, algorithm and oxygen saturation module. So, we considered a clinical test of one of the proposed devices could cover that of other devices. The clinical test of other proposed devices can be exempted. And we conducted clinical test for one of the proposed devices, and the model is SHO-3002.

The clinical trial was performed according to Annex EE.2 Procedure for invasive laboratory testing of ISO80601-2-61:2011, Medical electrical equipment-Part 2-6 1: Particular requirements for basic safety and essential performance of pulse oximeter equipment.

It can be determined from the result of the clinical study that the accuracy Arms of the proposed device is smaller than 2%.

13. Substantially Equivalent Conclusion

The proposed device Pulse Oximeter SHO-3002, SHO-3008 are determined to be Substantially Equivalent (SE) to the predicate device, Fingertip Pulse Oximeter (K130947) MD300C1, MD300C2.