K Number
K180685
Device Name
AS-3XX Series Fingertip Pulse Oximeter
Date Cleared
2018-11-29

(259 days)

Product Code
Regulation Number
870.2700
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The AS-3XX Series Fingertip Pulse Oximeter (with models AS-301, AS-302, AS-301-L, AS-302-L, AS-303, AS-304, AS-304-L and AS-311) is a portable non-invasive device intended for spot-checking of oxygen saturation of arterial hemoglobin (SpO2) and pulse rate of adult in hospital-type facilities, and home environments.
Device Description
The AS-301/AS-302/AS-301-L/AS-302-L/AS-303/AS-304/AS-304-L/AS-311 Fingertip Pulse Oximeter manufactured by ACURIO provides noninvasive blood oxygen measurement by the dual-wavelength spectrophotometric technique, and shows the results by the OLED. The oximeter is easy to operate, small in volume, light in weight, convenient in carrying, low consumption in design and with strong resistance to ambient light interference. 2pcs of AAA batteries can be continuously used for 20 hours, and the battery voltage can be indicated. The fingertip pulse oximeter is a portable non-invasive device intended for spot-checking of oxygen saturation of arterial hemoglobin (SpO2) and pulse rate of adults in hospitals, hospital-type facilities, and home environments. The components of the oximeter include the body part and a hanging rope. Arterial oxygen saturation is measured by a method called pulse oximetry. It is a continuous, non-invasive method based on the different spectra absorption of hemoglobin and oxyhemoglobin. It measures how much light, sent from light sources on one side of the sensor, is transmitted through patient tissue (such as a finger), to a receiver on the other side. Two beams of different wavelength of lights (660nm red and 895nm near infrared light) can be focused onto a human nail tip through c 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.
More Information

Not Found

No
The description details a standard pulse oximetry technology based on spectrophotometry and a microprocessor for processing signals. There is no mention of AI, ML, or related concepts in the device description, performance studies, or key metrics.

No
The device is described as a "portable non-invasive device intended for spot-checking of oxygen saturation of arterial hemoglobin (SpO2) and pulse rate," which indicates a diagnostic or monitoring function rather than a therapeutic one.

Yes

The device is intended for spot-checking of oxygen saturation of arterial hemoglobin (SpO2) and pulse rate, which are measurements used to assess a patient's physiological state. Measuring and presenting physiological data for interpretation aligns with the definition of a diagnostic device.

No

The device description explicitly details hardware components such as light sources (660nm red and 895nm near infrared light), a photosensitive element, electronic circuits, a microprocessor, an OLED display, and requires AAA batteries. It is a physical fingertip pulse oximeter.

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 AS-3XX Series Fingertip Pulse Oximeter is a non-invasive device that measures oxygen saturation and pulse rate by shining light through the fingertip. It does not analyze samples taken from the body.
  • Intended Use: The intended use clearly states it's for "spot-checking of oxygen saturation of arterial hemoglobin (SpO2) and pulse rate". This is a physiological measurement, not a diagnostic test performed on a sample.
  • Device Description: The description details the non-invasive method using light transmission through tissue.

Therefore, while it's a medical device used for monitoring health parameters, it does not fit the definition of an In Vitro Diagnostic.

N/A

Intended Use / Indications for Use

The AS-3XX Series Fingertip Pulse Oximeter (with models AS-301, AS-302, AS-301-L, AS-302-L, AS-303, AS-304, AS-304-L and AS-311) is a portable non-invasive device intended for spot-checking of oxygen saturation of arterial hemoglobin (SpO2) and pulse rate of adult in hospital-type facilities, and home environments.

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

DOA

Device Description

The AS-301/AS-302/AS-301-L/AS-302-L/AS-303/AS-304/AS-304-L/AS-311 Fingertip Pulse Oximeter manufactured by ACURIO provides noninvasive blood oxygen measurement by the dual-wavelength spectrophotometric technique, and shows the results by the OLED. The oximeter is easy to operate, small in volume, light in weight, convenient in carrying, low consumption in design and with strong resistance to ambient light interference. 2pcs of AAA batteries can be continuously used for 20 hours, and the battery voltage can be indicated. The fingertip pulse oximeter is a portable non-invasive device intended for spot-checking of oxygen saturation of arterial hemoglobin (SpO2) and pulse rate of adults in hospitals, hospital-type facilities, and home environments.

The components of the oximeter include the body part and a hanging rope.

Arterial oxygen saturation is measured by a method called pulse oximetry. It is a continuous, non-invasive method based on the different spectra absorption of hemoglobin and oxyhemoglobin. It measures how much light, sent from light sources on one side of the sensor, is transmitted through patient tissue (such as a finger), to a receiver on the other side. Two beams of different wavelength of lights (660nm red and 895nm near infrared light) can be focused onto a human nail tip through c 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.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Fingertip

Indicated Patient Age Range

Adults only

Intended User / Care Setting

hospital-type facilities, and home 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)

Clinical hypoxia accuracy testing (controlled desaturation study) was conducted during induced hypoxia studies on 10 healthy, nonsmoking, light-to-dark-skinned subjects in an independent research laboratory. The measured arterial hemoglobin saturation value (SpO2) of the proposed device was compared with arterial hemoglobin oxygen (SaO2) value, determined from blood samples with a CO-oximeter. The accuracy of the device is in comparison with the CO-oximeter samples measured over the SpO2 range of 70-100%.

Accuracy data was calculated using the root-mean-squared (Arms value) for all subjects, per ISO 80601-2-61, the result showed that the error is far less than the scope specified in the STANDARD ; and the Agreement between Methods of Measurement with Multiple Observations per each subject was analyzed with the Bland and Altman statistics, the analysis demonstrated that the vast majority of data is within ±95% limit of agreement, the data points beyond or below this scope were regarded as outliers. By analyzing, these few outliers are occasional, which does not raise safety and performance concerns regarding the accuracy of the device.

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

Accuracy of SpO2 over the range of 70-100%.
AS-301/AS-302/AS-303/AS-304/AS-311: SpO2: ±3% (70% - 99%), ±3% (70% - 80%), ±2% (80% - 90%), ±2% (90% - 99%) less than 70% no definition. Pulse rate accuracy: ±2bpm.
AS-301-L/AS-302-L/AS-304-L: SpO2: ±3% (70% - 100%) ±3% (70% - 80%), ±2% (80% - 90%), ±2% (90%-99%) less than 70% no definition. Pulse rate accuracy: ±2bpm.

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.

K140582

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

§ 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 of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: a symbol on the left and the text "FDA U.S. FOOD & DRUG ADMINISTRATION" on the right. The symbol on the left is a stylized representation of a human figure, while the text on the right is written in blue and white. The logo is commonly used to identify the FDA and its role in regulating food and drugs in the United States.

Xiamen Acurio Instruments Co., Ltd Angel Liu General Manager Assistant 3rd-4th Floors, BI Park, No.2028 Wengjiao West Road, Haicang District Xiamen, 361026 Cn

Re: K180685

Trade/Device Name: AS-3XX Series Fingertip Pulse Oximeter (with models AS-301, AS-302, AS-301-L, AS-302-L, AS-303, AS-304, AS-304-L, AS-311) Regulation Number: 21 CFR 870.2700 Regulation Name: Oximeter Regulatory Class: Class II Product Code: DOA Dated: October 19, 2018 Received: October 25, 2018

Dear Angel Liu:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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

1

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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; 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 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,

Todd D. Courtney -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) K180685

Device Name

The AS-3XX Series Fingertip Pulse Oximeter (with models AS-301, AS-302-L, AS-302-L, AS-303, AS-304, AS-304-L and AS-311)

Indications for Use (Describe)

The AS-3XX Series Fingertip Pulse Oximeter (with models AS-301-L, AS-301-L, AS-302-L, AS-303, AS-304, AS-304-L and AS-311) is a portable non-invasive device intended for spot-checking of oxygen saturation of arterial hemoglobin (SpO2) and pulse rate of adult in hospital-type facilities, and home environments.

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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

3

510(K) SUMMARY AS-3XX Series Fingertip Pulse Oximeter 510(k) Number: K180685

This summary of 510(k) information is being submitted in accordance with the requirements of 21 CFR 807.87(h) and 21 CFR 807.92.

Submitter:

Xiamen Acurio Instruments Co., Ltd 3rd-4th Floors, Biomedical Industry Park, No.2028, Wengjiao West Road, Haicang District, Xiamen, Fujian, 361026, CHINA

● Contact Person:

Angel Liu General Manager Assistant Tel: 86-592-6312776 Fax: 86-592-6312776 Email: liushuzhen@acurio.cn

  • Date Prepared: ● November 28, 2018

Name of the Devices:

  • Device Common Name: Oximeter
  • Device Proprietary Name: AS-3XX Series Fingertip Pulse Oximeter (with models AS-301, AS-302, AS-301-L, AS-302-L, AS-303, AS-304, AS-304-L, AS-311)
  • Classification Name: Oximeter
  • Classification: Class II
  • Regulation Number: 21CFR 870.2700
  • Product Code: DQA

4

  • Review Panel: Anesthesiology

Legally Marketed Predicate Device(s):

K140582 Fingertip Pulse Oximeter, Model JPD-500

Indications for Use:

The AS-3XX Series Fingertip Pulse Oximeter (with models AS-301, AS-302, AS-301-L, AS-302-L, AS-303, AS-304, AS-304-L and AS-311) is a portable non-invasive device intended for spot-checking of oxygen saturation of arterial hemoglobin (SpO2) and pulse rate of adult in hospital-type facilities, and home environments.

Device Description:

The AS-301/AS-302/AS-301-L/AS-302-L/AS-303/AS-304/AS-304-L/AS-311 Fingertip Pulse Oximeter manufactured by ACURIO provides noninvasive blood oxygen measurement by the dual-wavelength spectrophotometric technique, and shows the results by the OLED. The oximeter is easy to operate, small in volume, light in weight, convenient in carrying, low consumption in design and with strong resistance to ambient light interference. 2pcs of AAA batteries can be continuously used for 20 hours, and the battery voltage can be indicated. The fingertip pulse oximeter is a portable non-invasive device intended for spot-checking of oxygen saturation of arterial hemoglobin (SpO2) and pulse rate of adults in hospitals, hospital-type facilities, and home environments.

The components of the oximeter include the body part and a hanging rope.

Arterial oxygen saturation is measured by a method called pulse oximetry. It is a continuous, non-invasive method based on the different spectra absorption of hemoglobin and oxyhemoglobin. It measures how much light, sent from light sources on one side of the sensor, is transmitted through patient tissue (such as a finger), to a receiver on the other side. Two beams of different wavelength of lights (660nm red and 895nm near infrared light) can be focused onto a human nail tip through c 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.

Comparison to Predicate Devices:

The Substantial Equivalence Comparison Chat is provided as follows:

Table 1: Substantial Equivalence Comparison Chart

5

Comparison itemsManufacturer (aCurio)Manufacturer (Jumper)Comparison results
NameFingertip pulse oximeterFingertip pulse oximeterIdentical
ModelAS-301/AS-302/AS-301-L/AS-
302-L/AS-303/AS-304/AS-304-
L/AS-311JPD-500A
510(K) numberK180685K140582
Regulatory ClassClass IIClass IIIdentical
Intended useThis product is used for spot-
checking of oxygen saturation of
arterial hemoglobin (SpO2) and
pulse rate for adults.This product is used for spot-
checking of oxygen saturation
of arterial hemoglobin (SpO2)
and pulse rate for adult and
pediatric users.Identical
Indications for useThe AS-3XX Series Fingertip
Pulse Oximeter (with models AS-
301, AS-302, AS-301-L, AS-302-
L, AS-303, AS-304, AS-304-L and
AS-311) is a portable non-
invasive device intended for spot-
checking of oxygen saturation of
arterial hemoglobin (SpO2) and
pulse rate of adult in hospitals,
hospital-type facilities, and home
environments.The JPD-500A Fingertip Pulse
Oximeter is non-invasive
device intended for spot-
checking of functional oxygen
saturation of arterial
hemoglobin (SpO2) and pulse
rate. The portable fingertip
device is indicated for adult
and pediatric patients in home
and hospital environments
(including clinical use in
internist/surgery, anesthesia,
intensive care, etc)Similar
Target populationAdults onlyAdult and pediatric usersSimilar
Anatomical sitesFingertipFingertipIdentical
Where usedhospitals, hospital-type facilities,
and home environments.Home and hospital (including
clinical use in
internist/surgery, Anesthesia,
intensive care etc.similar
Energy used and/or
deliveredD.C.3.0V (2xAAA alkaline
batteries)D.C. 3.0V (2×AAA alkaline
batteries)Identical
Human factors
DesignBody part and a lanyardBody part and a lanyardIdentical
PerformanceMeasuring
principleDual-wavelength
spectrophotometr
yDual-wavelength
spectrophotometryIdentical
AS-
301/AS302/AS30
3 AS-304/AS-
311:
SpO2: 36% ~
99%
Pulse rate:
30bpm ~ 250bpm
AS-301-
L/AS302-L:
SpO2: 36% ~
100%
Pulse rate:
30bpm ~ 250bpmSpO2: 35%~100%
Pulse Rate: 25bpm ~ 250bpm
Measurement
range
Measurement
accuracyAS-301/AS-
302/AS-303/AS-
304/AS-311:
SpO2: ±3% (70%
  • 99%), ±3%
    (70% - 80%),
    ±2% (80% -
    90%), ±2%
    (90% - 99%)
    less than 70% no
    definition
    Pulse rate
    accuracy: ±2bpm
    AS-301-L/AS-
    302-L/AS-304-L:
    SpO2: ±3% (70%
  • 100%) ±3%
    (70% - 80%),
    ±2% (80% -
    90%), ±2%
    (90%-99%)
    less than 70% no
    definition
    Pulse rate
    accuracy: ±2bpm | SpO2: ±2% (70% 100%), no
    definition (35%69%)
    Pulse rate: ±2bpm | Similar | |
    | | | | | |
    | Low
    perfusion | SpO2 and pulse
    rate can be | Measurement performance in
    low perfusion condition is | Similar | |
    | | | | | |
    | | error | shown correctly when pulse-filling ratio is 0.2% | 0.3%. | |
    | | Light sensor | RED wavelength 660nm
    IR wavelength 940nm | RED wavelength 660nm
    IR wavelength 940nm | Identical |
    | | | | | |
    | | Protection against electric shock | Internal power supply;
    Type BF | Internal power supply;
    Type BF | Identical |
    | | Operating environment | Operation temperature: 5-40°C
    Relative humidity: 15% - 95% (Non condensing) | Operation temperature: 5-40°C
    Relative humidity: 15% - 80 %( Non condensing) | Similar |
    | | | | | |
    | | Storage environment | Storage temperature: - 20
    55°C
    Relative humidity: 15% - 95% (Non condensing) | Storage temperature: - 10°C
    50°C
    Relative humidity: 10% - 95 %( Non condensing) | Similar |
    | | | | | |
    | | Weight | 50g (including batteries) | 57g (including batteries) | Similar |
    | | Size | AS-301, AS-301-L:
    56(L)×34(W)×32(H)mm
    AS-302, AS-302-L:
    58(L)×35(W)×32(H)mm
    AS-303:
    57(L)×35(W)×37(H)mm | 64(L)×35(W)×34(H) mm | Similar |
    | | | | | |
    | | | | | |
    | | | | | |
    | Standards met | ISO 80601-2-61: 2011
    IEC 60601-1: 2005
    IEC 60601-1-2: 2007/AC | | ISO 80601-2-61: 2011
    IEC 60601-1: 2005
    IEC 60601-1-2: 2007/AC | Identical |
    | | | | | |

6

7

8

510(K) Summary
------------------

| Materials | ISO 10993-5: 2009
ISO 10993-10: 2010
ISO 13485: 2003
ISO 15223-1: 2012
IEC 62304: 2006
IEC 62366: 2007
ISO 10993-1: 2009/AC: 2010
IEC 60601-1-11: 2010
IEC 60601-1-6: 2010
ABS+TPR | ISO 10993-5: 2009
ISO 10993-10: 2010
ISO 13485: 2003
ISO 15223-1: 2012
IEC 62304: 2006
IEC 62366: 2007
ISO 10993-1: 2009/AC: 2010
IEC 60601-1-11: 2010
IEC 60601-1-6: 2010
ABS+TPR | Conform to the
bio-compatibility
requirements. |
|------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------|
| Biocompatibility | Passed the detection of ISO10993-
5 and ISO10993-10. | Passed the detection of
ISO10993-5 and ISO10993-
10. | Conform to the
bio-compatibility
requirements. |
| Compatibility with
the environment and
other devices | The pulse oximeter can't be used
in an MRI or CT environment, in
situations where alarms are
required, or in an explosive
atmosphere. | The pulse oximeter can't be
used in an MRI or CT
environment, in situations
where alarms are required, or
in an explosive atmosphere. | Identical |
| Sterility | Non-sterile | Non-sterile | Identical |
| Electrical safety | Same | Same | Identical |

Discussion of Non-Clinical Tests Performed for Determination of Substantial Equivalence:

The Sponsor performed a risk assessment based on the changes made to their predicate device and determined that the following non-clinical testing was necessary to demonstrate that the changes did not introduce any new risks to the subject device.

Laboratory testing was conducted to validate and verify that the Pulse Oximeters continued to meet all requirements of related international standards, including electrical safety, EMC, software, bio-compatibility. Results of these tests demonstrated compliance to the requirements of the below consensus standards and FDA Guidance documents.

Electrical Safety and Performance:

  1. IEC 60601-1:2005+A1:2012;

  2. ISO 80601-2-61:2011.

Medical Electrical Equipment and medical Electrical Systems Used in the Home

9

Healthcare Environment:

  1. IEC 60601-1-11:2010+CORR.1:2011.

Electromagnetic Compatibility:

  1. IEC 60601-1-2:2007.

Biocompatibility:

    1. ISO 10993-5:2009
    1. ISO 10993-10:2010

Software:

    1. IEC 62304: 2006
    1. General Principles of Software Validation Final Guidance for Industry and FDA Staff.

Pulse Oimeters Guidance:

Pulse Oximeters - Premarket Notification Submissions [510(k)s]: Guidance for Industry and Food and Drug Administration Staff

Therefore, we conclude that the AS-3XX Series Fingertip Pulse Oximeter (with models AS-301, AS-302, AS-301-L, AS-302-L, AS-303, AS-304, AS-304-L, AS-311) is both safe and effective for its intended use.

Discussion of Clinical Tests Performed:

Clinical hypoxia accuracy testing (controlled desaturation study) was conducted during induced hypoxia studies on 10 healthy, nonsmoking, light-to-dark-skinned subjects in an independent research laboratory. The measured arterial hemoglobin saturation value (SpO2) of the proposed device was compared with arterial hemoglobin oxygen (SaO2) value, determined from blood samples with a CO-oximeter. The accuracy of the device is in comparison with the CO-oximeter samples measured over the SpO2 range of 70-100%.

Accuracy data was calculated using the root-mean-squared (Arms value) for all subjects, per ISO 80601-2-61, the result showed that the error is far less than the scope specified in the STANDARD ; and the Agreement between Methods of Measurement with Multiple Observations per each subject was analyzed with the Bland and Altman statistics, the analysis demonstrated that the vast majority of data is within ±95% limit of agreement, the data points beyond or below this scope were regarded as outliers. By analyzing, these few outliers are occasional, which does not raise safety and performance concerns regarding the accuracy of the device.

Conclusions:

The AS-3XX Series Fingertip Pulse Oximeter(with models AS-301. AS-302. AS-301-L, AS-302-L, AS-303, AS-304, AS-304-L, AS-311) has the same intended use and

10

similar characteristics as the predicate device. Moreover, bench testing contained in this submission demonstrates that any difference in their technological characteristics do not raise any different questions of safety or effectiveness. Thus, the AS-3XX Series Fingertip Pulse Oximeter (with models AS-301, AS-302, AS-301-L, AS-302-L, AS-303, AS-304, AS-304-L, AS-311) is substantially equivalent to the predicate devices.