K Number
K172986
Device Name
Zmachine Synergy
Date Cleared
2017-12-19

(83 days)

Product Code
Regulation Number
882.1400
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Zmachine Synergy is an EEG and respiratory signal recorder. The device is intended for use by adult patients in the home or clinical environment, under the direction of a qualified healthcare practitioner, to aid in the diagnosis of sleep disorders.
Device Description
The Zmachine Synergy system is a portable, battery operated, medical device housed within an ABS enclosure. The system combines the single-channel EEG recording capability of the Zmachine DT-100 (K101830) with the respiratory signal recording capability of the Resmed ApneaLink Air (K143272). The Zmachine Synergy is thereby capable of recording EEG, respiratory airflow, respiratory effort, blood oxygen saturation, pulse rate, and body position during sleep.
More Information

Not Found

No
The summary describes a device that records physiological signals and compares its performance to predicate devices using standard statistical methods. There is no mention of AI, ML, or related concepts.

No
The device aids in the diagnosis of sleep disorders by recording various physiological signals, but it does not treat or cure them, which is the definition of a therapeutic device.

Yes
The device is described as aiding "in the diagnosis of sleep disorders," which directly indicates a diagnostic purpose.

No

The device description explicitly states it is a "portable, battery operated, medical device housed within an ABS enclosure" and combines the capabilities of two predicate hardware devices, indicating it is a physical device with hardware components.

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

Here's why:

  • IVD Definition: In Vitro Diagnostics are medical devices used to perform tests on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections. These tests are performed outside of the living body (in vitro).
  • Zmachine Synergy's Function: The Zmachine Synergy records physiological signals directly from the patient's body (EEG, respiratory airflow, respiratory effort, blood oxygen saturation, pulse rate, and body position). It does not analyze samples taken from the body.
  • Intended Use: The intended use is to "aid in the diagnosis of sleep disorders" by recording these physiological signals. This is a diagnostic tool that gathers data in vivo (within the living body).

Therefore, the Zmachine Synergy falls under the category of a medical device used for physiological monitoring and recording, not an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

The Zmachine Synergy is an EEG and respiratory signal recorder. The device is intended for use by adult patients in the home or clinical environment, under the direction of a qualified healthcare practitioner, to aid in the diagnosis of sleep disorders.

Product codes (comma separated list FDA assigned to the subject device)

OLV, OMC, MNR

Device Description

The Zmachine Synergy system is a portable, battery operated, medical device housed within an ABS enclosure. The system combines the single-channel EEG recording capability of the Zmachine DT-100 (K101830) with the respiratory signal recording capability of the Resmed ApneaLink Air (K143272). The Zmachine Synergy is thereby capable of recording EEG, respiratory airflow, respiratory effort, blood oxygen saturation, pulse rate, and body position during sleep.

A healthcare provider will supply a Zmachine Synergy device to a patient. Prior to going to bed, the patient is instructed to clean each mastoid and the back of their neck with a supplied alcohol swab. After allowing a few seconds for the alcohol to dry, the patient then applies the supplied peel-and-stick, disposable, EEG sensor pads onto each mastoid (recording electrodes) and one onto the back of the neck (ground). The EEG cable, with three individual lead wires, is snapped onto the conductive studs of the three EEG sensor pads and the free end of the EEG cable is inserted into the corresponding socket of the Zmachine Synergy device. Respiratory effort is sensed using a thoracic belt which serves double duty in also holding the device onto the patient. The patient is instructed to click the belt onto each of the Zmachine Synergy device, position the device just under the armpits, adjust the tension for a snug but comfortable fit, and snap the belt cables onto the conductive studs of the belt. Respiratory nasal airflow is sensed using a nasal cannula. The patient is instructed to place the cannula in their nostrils, drape over their ears, remove slack with the slider, and screw the free end of the cannula onto the luer fitting of the Zmachine Synergy device. Blood oxygen saturation and pulse are sensed using a finger probe pulse oximeter. The patient is instructed to insert a finger from either hand into finger probe and clip the oximeter module to the effort belt. Body position is sensed by an accelerometer located within the body of the Zmachine Synergy device and no additional patient instructions are requires for this signal. The patient presses the center button of the Zmachine Synergy for approximately one second to start the test before going to sleep, and holding for approximately three seconds to end the test in the morning. LED indicators are used to indicate the status of all sensors.

Data from the overnight recording is streamed to a non-removable microSD memory card located inside the Zmachine Synergy device. When patient returns the Zmachine Synergy device to the healthcare provider, the healthcare provider can access the recorded data by connecting the Zmachine Synergy device to their PC using a supplied USB cable is also used to re-charge the Zmachine Synergy device when connected to a USB wall charger or PC. A fully charged Zmachine Synergy device can be used for approximately 30 hours of recording and can finish re-charging within approximately five hours.

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

Adults

Intended User / Care Setting

qualified healthcare practitioner, home or clinical environment

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)

Study Type: Bench comparison testing
Sample Size: Not specified (comparison of devices)
Key Results:

  • EEG: The EEG amplifier characteristics were found to be in high agreement with both the design limits and each other for all points of comparison. As such, the EEG recording capabilities were found to be substantially equivalent.
  • Respiratory Airflow: The correlation coefficient between the Zmachine Synergy and ApneaLink Air reveals a strong linear relationship in the Respiratory Airflow signal between the two systems. As such, the Respiratory Airflow characteristics were found to be substantially equivalent.
  • Respiratory Effort: The correlation coefficient between the Zmachine Synergy and ApneaLink Air reveals a strong linear relationship in the Respiratory Effort signal between the two systems. As such, the Respiratory Effort characteristics were found to be substantially equivalent.
  • Pulse Oximetry: The heart rate and oxygen saturation readings were found to be in high agreement with the specified calibrator output levels and having a low mean squared error when comparing the two systems together. As such, the Pulse Oximeter recording capabilities were found to be substantially equivalent.
  • Body Position: The angular readings and angular reference positions were found to be in very high agreement throughout 360 degrees of rotation. As such, the Body Position recording capabilities were found to be substantially equivalent.

All tests confirmed that the Zmachine Synergy device meets the predetermined acceptance criteria for both the external tests and side-by-side comparisons. General Sleep has determined that the Zmachine Synergy is Substantially Equivalent to the predicate devices.

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

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

Zmachine DT-100 (K101830), ApneaLink Air (K143272)

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 882.1400 Electroencephalograph.

(a)
Identification. An electroencephalograph is a device used to measure and record the electrical activity of the patient's brain obtained by placing two or more electrodes on the head.(b)
Classification. Class II (performance standards).

0

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December 19, 2017

Consolidated Research of Richmond, Inc. Richard Kaplan, PhD President 26250 Euclid Avenue. Suite 709 Cleveland, Ohio 44132

Re: K172986

Trade/Device Name: Zmachine Synergy Regulation Number: 21 CFR 882.1400 Regulation Name: Electroencephalograph Regulatory Class: Class II Product Code: OLV, OMC, MNR Dated: October 25, 2017 Received: October 26, 2017

Dear Dr. Kaplan:

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); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

1

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 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,

Michael J. Hoffmann -S

Carlos L. Peña, PhD, MS for Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K172986

Device Name Zmachine Synergy

Indications for Use (Describe)

The Zmachine Synergy is an EEG and respiratory signal recorder. The device is intended for use by adult patients in the home or clinical environment, under the direction of a qualified healthcare practitioner, to aid in the diagnosis of sleep disorders.

Type of Use ( Select one or both, as applicable )
----------------------------------------------------------
Exportation Use (Per 21 CFR 201.66, Outer Package)
On-Site Compounding (Per 21 CFR 201.66)

|X | Prescription Use (Part 21 CFR 801 Subpart D)

| | Over-The-Counter Use (21 CFR 801 Subpart C)

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3

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510(k) Summary

Zmachine® Synergy 510(k) Notification Consolidated Research of Richmond, Inc.

Date PreparedDecember 14, 2017
510(k) OwnerConsolidated Research of Richmond, Inc.
Contact
PersonRichard F. Kaplan, Ph.D., President
Phone: (216) 289-2331 Extension 1001
E-mail: kaplan@generalsleep.com
Address26250 Euclid Avenue, Suite 709
Euclid, Ohio 44132
Phone: (216) 289-2331
Fax: (216) 393-0079
Trade NameZmachine® Synergy
Common
NameSleep monitoring system
Classification
NameElectroencephalograph
Product
CodesOLV, OMC, and MNR
Indications
for UseThe Zmachine Synergy is an EEG and respiratory signal recorder. The
device is intended for use by adult patients in the home or clinical
environment, under the direction of a qualified healthcare practitioner, to aid
in the diagnosis of sleep disorders.
Predicate
DevicesZmachine DT-100 (K101830) – primary
ApneaLink Air (K143272)

4

Device Description

The Zmachine Synergy system is a portable, battery operated, medical device housed within an ABS enclosure. The system combines the single-channel EEG recording capability of the Zmachine DT-100 (K101830) with the respiratory signal recording capability of the Resmed ApneaLink Air (K143272). The Zmachine Synergy is thereby capable of recording EEG, respiratory airflow, respiratory effort, blood oxygen saturation, pulse rate, and body position during sleep.

A healthcare provider will supply a Zmachine Synergy device to a patient. Prior to going to bed, the patient is instructed to clean each mastoid and the back of their neck with a supplied alcohol swab. After allowing a few seconds for the alcohol to dry, the patient then applies the supplied peel-and-stick, disposable, EEG sensor pads onto each mastoid (recording electrodes) and one onto the back of the neck (ground). The EEG cable, with three individual lead wires, is snapped onto the conductive studs of the three EEG sensor pads and the free end of the EEG cable is inserted into the corresponding socket of the Zmachine Synergy device. Respiratory effort is sensed using a thoracic belt which serves double duty in also holding the device onto the patient. The patient is instructed to click the belt onto each of the Zmachine Synergy device, position the device just under the armpits, adjust the tension for a snug but comfortable fit, and snap the belt cables onto the conductive studs of the belt. Respiratory nasal airflow is sensed using a nasal cannula. The patient is instructed to place the cannula in their nostrils, drape over their ears, remove slack with the slider, and screw the free end of the cannula onto the luer fitting of the Zmachine Synergy device. Blood oxygen saturation and pulse are sensed using a finger probe pulse oximeter. The patient is instructed to insert a finger from either hand into finger probe and clip the oximeter module to the effort belt. Body position is sensed by an accelerometer located within the body of the Zmachine Synergy device and no additional patient instructions are requires for this signal. The patient presses the center button of the Zmachine Synergy for approximately one second to start the test before going to sleep, and holding for approximately three seconds to end the test in the morning. LED indicators are used to indicate the status of all sensors.

Data from the overnight recording is streamed to a non-removable microSD memory card located inside the Zmachine Synergy device. When patient returns the Zmachine Synergy device to the healthcare provider, the healthcare provider can access the recorded data by connecting the Zmachine Synergy device to their PC using a supplied USB cable is also used to re-charge the Zmachine Synergy device when connected to a USB wall charger or PC. A fully charged Zmachine Synergy device can be used for approximately 30 hours of recording and can finish re-charging within approximately five hours.

5

Technology Overview

Electroencephalograph (EEG)

Both the Zmachine Synergy and Zmachine DT-100 use the same EEG hardware (both technology and design) to acquire a single EEG channel.

Respiratory nasal airflow

Both the Zmachine Synergy and ApneaLink Air use the same pressure transducer to acquire the respiratory nasal airflow signals.

Blood oxygen saturation and pulse

Both the Zmachine Synergy and ApneaLink Air use the same pulse oximeter module to acquire the blood oxygen saturation and pulse signals. However, the Zmachine Synergy and ApneaLink Air operate the module using slightly different data output modes.

Respiratory effort

Both the Zmachine Synergy and ApneaLink Air use a thoracic effort belt to sense chest expansion and contraction during inhalation and exhalation (i.e. respiratory effort). However, the Zmachine Synergy records changes in belt stretch using respiratory inductance plethysmography (RIP), whereas the ApneaLink Air measures changes in belt stretch using an in-line air cell and pressure transducer.

Body position

Both the Zmachine Synergy and ApneaLink Air use solid-state accelerometers to acquire the body position signal.

Substantial Equivalence

The table, starting on the next page, summarizes the technological characteristics of the Zmachine Synergy in comparison to the predicate devices.

6

| | Zmachine Synergy
(New Device) | Zmachine DT-100
(Primary Predicate) | ApneaLink Air
(Predicate) |
|-----------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Manufacturer | Consolidated Research of Richmond, Inc. | Consolidated Research of Richmond, Inc. | ResMed Germany Inc. |
| 510(k) number | K172986 | K101830 | K143272 |
| Classification regulation | 21 CFR 868.2375 | 21 CFR 882.1400 | 21 CFR 868.2375 |
| Product code | MNR | OLV and OMC | MNR |
| Indications for use | The Zmachine Synergy is an EEG
and respiratory signal recorder. The
device is intended for use by adult
patients in the home or clinical
environment, under the direction of a
qualified healthcare practitioner, to
aid in the diagnosis of sleep
disorders. | The CRI Zmachine is a single-
channel, EEG acquisition and
analysis system, designed for use in
the home or clinical environments.
This device is intended to be used by
qualified healthcare practitioners to
monitor the wake and sleep states of
adult patients and as an adjunct to
their diagnosis of sleep disorders. | The ApneaLink™ Air device is
indicated for use by Health Care
Professionals (HCP), where it may
aid in the diagnosis of sleep
disordered breathing for adult
patients. ApneaLink Air records the
following data: patient respiratory
nasal airflow, snoring, blood oxygen
saturation, pulse, respiratory effort
and body position during sleep. The
device uses these recordings to
produce a report for the HCP that
may aid in the diagnosis of sleep
disordered breathing or for further
clinical investigation. The device is
intended for home and hospital use
under the direction of a HCP. |
| Intended
environment(s) | Home or clinical environment | Home or clinical environment | Home or hospital environment |
| Patient population | Adults | Adults | Adults |
| Acquired Channels | Airflow
Pulse Oximeter
Respiratory Effort
Body Position
EEG | n/a
n/a
n/a
n/a
EEG | Airflow
Pulse Oximeter
Respiratory Effort
Body Position
n/a |
| | Zmachine Synergy
(New Device) | Zmachine DT-100
(Primary Predicate) | ApneaLink Air
(Predicate) |
| Sensor technology | Airflow: Honeywell solid state
pressure transducer (±6 mbar range)
Pulse Oximetry: Nonin XPOD LP
module
Respiratory Effort: Thoracic effort
belt based on respiratory inductance
plethysmography (RIP)
Body position: Solid state
accelerometer
Zmachine DT-100 EEG technology | n/a | Airflow: Honeywell solid state
pressure transducer (±6 mbar range)
Pulse Oximetry: Nonin XPOD LP
module
Respiratory Effort: Thoracic effort
belt based on pneumatics
Body position: Solid state
accelerometer
n/a |
| Display type | LED indicators. A full-color LED
indicator is located beside each
connector (airflow, effort, oximeter,
and EEG) to indicate correct or
incorrect hookup/operation. Another
full-color LED is located under the
main power button to indicate system
status. | Zmachine DT-100 EEG technology
LCD display. A full color, 320x240
pixel, LCD display with an LED
backlight is used to present all
system information. | LED indicators. 3 LED indicators
are located beside each connector
(airflow, effort and oximeter) to
indicate correct or incorrect function.
Another LED is used to indicate the
"test complete" status based on
recording time. |
| Power source | Internally powered using li-ion
rechargeable battery | Internally powered using li-ion
rechargeable battery | Internally powered using 2xLR03
(AAA) primary or rechargeable |
| Internal memory / data
storage | Fixed microSD card | Removable microSD card | Fixed microSD card |
| Communication
interface | USB | USB card reader | USB |
| Access to recorded data | Recorded data is stored in the device.
When the device is connected to PC
via USB cable the device provides
access to its internal memory. | Recorded data is stored in the device.
The microSD card is removed and
connected to PC via USB card reader
to access internal memory. | Recorded data is stored in the device.
When the device is connected to PC
via USB cable the device provides
access to its internal memory. |
| Recorded data format | Each channel of recorded data is
stored in an individual file of the
GSC2 data format. | Each channel of recorded data is
stored in an individual file of the
binary data format. | All channels of recorded data are
stored in EDF+ data format. |
| | Zmachine Synergy
(New Device) | Zmachine DT-100
(Primary Predicate) | ApneaLink Air
(Predicate) |
| Device dimensions
LxWxH (mm) | 120 x 61 x 24 | 116 x 68 x 21 | 61 x 102 x 31 |

7

8

The table above shows that there are no significant differences between Zmachine devices that adversely affect product safety and effectiveness.

9

Testing Summary

Design and verification activities have been performed on the Zmachine Synergy as a result of the risk analysis and product requirements. External tests have been completed for electrical safety (IEC 60601-1:2012), EMC (IEC 60601-1-2:2007), and mechanical and environmental requirements (IEC 60601-1-11:2010). In addition, side-by-side bench comparison testing, summarized in the table below, was performed in which a Zmachine Synergy was compared against a Zmachine DT-100 (K10183) and an ApneaLink Air (K143272).

TestTest Method SummaryResults
EEGEEG is sensed by the Zmachine Synergy and the Zmachine DT-100 using the identical EEG amplifier and analog-to-digital conversion hardware. As such, the acquired signals from both systems are expected to be substantially equivalent.The acquired data from each system was analyzed in order to determine the EEG amplifier gain, highpass filter cutoff frequency, lowpass filter cutoff frequency, DC offset, and noise floor levels at various points across the frequency spectrum.
To test, a multi-channel EEG analog playback system was connected to the EEG input of a Zmachine Synergy and Zmachine DT-100 device. Broad spectrum shaped white noise and a zero-level output signal were generated and acquired by each system.The EEG amplifier characteristics were found to be in high agreement with both the design limits and each other for all points of comparison. As such, the EEG recording capabilities were found to be substantially equivalent.
Respiratory
AirflowRespiratory Airflow is sensed by the Zmachine Synergy and the ApneaLink Air using the identical pressure transducer hardware. As such, the acquired signals from both systems are expected to be substantially equivalent.The acquired data from each system was analyzed in order to compare the Respiratory Airflow readings.
To test, a variable pressure air pump was connected to the Respiratory Airflow input of a Zmachine Synergy and ApneaLink Air device. A stepped variable air pressure signal was generated, split, and delivered to both systems.Because the two systems record airflow using different units of measure, Pearson's correlation coefficient was used to compare the recorded signals.

The correlation coefficient between the Zmachine Synergy and ApneaLink Air reveals a strong linear relationship in the Respiratory Airflow signal between the two systems. As such, the Respiratory Airflow characteristics were found to be substantially equivalent |

10

TestTest Method SummaryResults
Respiratory
EffortRespiratory Effort is sensed by the
Zmachine Synergy and the ApneaLink
Air using a thoracic effort belt to
qualitatively record chest expansion
and contraction during inhalation and
exhalation (i.e. respiratory effort). The
Zmachine Synergy senses this
expansion and contraction by
monitoring changes in belt inductance
(RIP), whereas the ApneaLink Air
monitors changes in air pressure within
an in-line air cell. Although the two
systems utilize different techniques for
measuring respiratory effort, they are
both responsive to belt expansion and
contraction and are expected to produce
substantially equivalent output.

To test, the Zmachine Synergy and
ApneaLink Air were subjected to
simulated inhalation and exhalation by
controlled belt stretching and partial
relaxing against a linear scale. | The acquired data from each system
was analyzed in order to compare the
Respiratory Effort readings.

Because the two systems record airflow
using different units of measure,
Pearson's correlation coefficient was
used to compare the recorded signals.

The correlation coefficient between the
Zmachine Synergy and ApneaLink Air
reveals a strong linear relationship in
the Respiratory Effort signal between
the two systems. As such, the
Respiratory Effort characteristics were
found to be substantially equivalent. |
| Pulse
Oximetry | Pulse Oximetry is sensed by the
Zmachine Synergy and the ApneaLink
Air using the identical pulse oximeter
hardware and similar data output
modes. As such, the acquired signals
from both systems are expected to be
substantially equivalent.

To test, a patient simulator was
connected in place of the finger probe
of a Zmachine Synergy and ApneaLink
Air device, one-at-a-time, under the
same conditions | The acquired data from each system
was analyzed in order to compare the
Pulse Oximeter readings.

The heart rate and oxygen saturation
readings were found to be in high
agreement with the specified calibrator
output levels and having a low mean
squared error when comparing the two
systems together. As such, the Pulse
Oximeter recording capabilities were
found to be substantially equivalent. |

11

TestTest Method SummaryResults
Body
PositionBody Position is sensed by the
Zmachine Synergy and the ApneaLink
Air using an accelerometer module.
Because each system is measuring the
angle of the system with regard to
gravity, and both systems are worn by
the patient in the same configuration,
the acquired signals from both systems
are expected to be substantially
equivalent if it can be demonstrated that
the Zmachine Synergy reports angle
with regard to gravity appropriately
against an angular reference.The acquired data from the Zmachine
Synergy was analyzed in order to
compare the Body Position angular
readings against the angular reference.

The angular readings and angular
reference positions were found to be in
very high agreement throughout 360
degrees of rotation. As such, the Body
Position recording capabilities were
found to be substantially equivalent. |
| | To test, the Zmachine Synergy is
rotated through 360 degrees against an
angular reference. | |

All tests confirmed that the Zmachine Synergy device meets the predetermined acceptance criteria for both the external tests and side-by-side comparisons. General Sleep has determined that the Zmachine Synergy is Substantially Equivalent to the predicate devices.

Conclusion

Based on the results of the performance testing for the Zmachine Synergy and the substantial equivalence comparison with the predicate devices, no new concerns about safety and effectiveness were raised. We believe that the presented information is sufficient to determine that the Zmachine Synergy is substantially equivalent to the predicate Zmachine DT-100, K101830, and ApneaLink Air, K143272, devices.