(27 days)
The Spectros T-Stat™ 2.0 Microvascular Tissue Oximeter is intended for use as an adjunct monitor of the localized hemoglobin oxygen saturation of blood in the microvascular tissue spaces (StO2%) in infants, children, or adults at risk for reduced-flow and no-flow ischemic states.
The prospective clinical value of measurements made with the T-Stat™ Oximeter has not been demonstrated in disease states. The T-Stat™ Oximeter should not be used as the sole basis for diagnosis or therapy.
The Spectros T-Stat™ 2.0 Microvascular Tissue Oximeter is a broadband, multiwavelength, Visible Light Spectroscopy (VLS) monitoring system for measuring the saturation of hemoglobin with oxygen in the microvascular tissue spaces (StO2%).
The complete system consists of a disposable sensor probe connected to a software-driven electronic monitor. Data collection, analysis, and display functions are provided by the monitor. Illumination of the tissue is provided by a visible light source in the sensor probe placed near, on, or into the target tissue to be studied. Reflected light is captured and returned to the monitor via a detachable connection at the monitor end of the patient probe. StO2% is estimated using differential optical diffuse reflectance spectroscopy and fitting for background scattering over a range of reflected visible wavelengths.
The provided text does not contain detailed information about specific acceptance criteria or a comprehensive study report for the T-Stat 2.0 Microvascular Tissue Oximeter. Instead, it focuses on the device's substantial equivalence to a predicate device (T-Stat 303™ Microvascular Tissue Oximeter) based on design modifications and re-verification of existing standards.
Therefore, I cannot provide a detailed answer to all parts of your request. However, I can extract what is available regarding testing and validation:
1. A table of acceptance criteria and the reported device performance
The document does not explicitly present a table of acceptance criteria with corresponding performance metrics for the T-Stat 2.0. The test summary mentions compliance verification with international standards and re-verification of functional requirements.
| Acceptance Criteria (Inferred from testing) | Reported Device Performance |
|---|---|
| Compliance with IEC60601-1-2 (Electromagnetic Compatibility) | Re-verified for the redesigned monitor |
| Compliance with IEC 60601-1 (Electrical Safety) | Re-verified for the redesigned monitor |
| Compliance with IEC 62304 (Software Life Cycle Processes) | Implemented and validated using in-house procedures, automated testing, and code reviews |
| Functional continuity with predicate device hardware and software | Confirmed through re-verification of predicate device protocols |
2. Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)
The document does not specify a "test set" in the context of patient data or clinical samples. The testing described is primarily engineering and software validation. Therefore, information about sample size for a clinical test set and data provenance is not available.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
This information is not provided as the document does not describe a clinical study where ground truth would be established by experts.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This information is not provided as the document does not describe a clinical study.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
This information is not provided. The T-Stat 2.0 is a tissue oximeter, not an AI-assisted diagnostic imaging device for human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
The T-Stat 2.0 provides StO2% measurements. The "functional continuity" re-verification suggests standalone performance relative to the predicate device's established functionality. However, detailed performance metrics for just the algorithm are not provided.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
The document focuses on engineering and software validation against established standards and the functional requirements of the predicate device. It does not mention a "ground truth" in the clinical sense (e.g., pathology, outcomes data) for the T-Stat 2.0's performance validation. The predicate device's existing clearance would have relied on such ground truth for its initial establishment of effectiveness.
8. The sample size for the training set
The document does not mention a "training set" as it describes re-verification of a modified device, not the development of a new algorithm requiring a training set.
9. How the ground truth for the training set was established
This information is not provided as there is no mention of a training set.
{0}------------------------------------------------
Image /page/0/Picture/0 description: The image shows the logos of the Department of Health & Human Services and the U.S. Food & Drug Administration. The Department of Health & Human Services logo is on the left, and the FDA logo is on the right. The FDA logo is a blue square with the letters "FDA" in white, followed by the words "U.S. Food & Drug Administration" in blue.
September 23, 2019
Spectros Corporation Bill Curnan Manager QA/RA 274 E Hamilton Ave Suite H Campbell, CA 95008
Re: K192322
Trade/Device Name: T-Stat 2.0 Microvascular Tissue Oximeter Regulation Number: 21 CFR 870.2700 Regulation Name: Oximeter Regulatory Class: Class II Product Code: MUD Dated: August 23, 2019 Received: August 27, 2019
Dear Bill Curnan:
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 statutes and regulations administered by other Federal agencies. You must comply with all the Act's
{1}------------------------------------------------
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/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (OS) 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Purva Pandva Acting Assistant Director DHT4A: Division of General Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
{2}------------------------------------------------
Indications for Use
510(k) Number (if known) K192322
Device Name
T-Stat™ 2.0 Microvascular Tissue Oxometer
Indications for Use (Describe)
The Spectros T-Stat™ 2.0 Microvascular Tissue Oximeter is intended for use as an adjunct monitor of the localized hemoglobin oxygen saturation of blood in the microvascular tissue spaces (StO2%) in infants, children, or adults at risk for reduced-flow and no-flow ischemic states.
The prospective clinical value of measurements made with the T-Stat™ Oximeter has not been demonstrated in disease states. The T-Stat™ Oximeter should not be used as the sole basis for diagnosis or therapy.
| 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}------------------------------------------------
K192322
510(k) Summary
l. Applicant Information
| A. Applicant: | Spectros Medical Devices Inc.274 E Hamilton Ave #HCampbell, CA 95008 |
|---|---|
| --------------- | ------------------------------------------------------------------------------ |
- B. Official Contact: Bill Curnan Manager of Quality/Regulatory Spectros Medical Devices Inc. 274 E Hamilton Ave #H Campbell, CA 95008 bcurnan@spectros.com
- C. Date of Summary: 9/21/19
ll. Device Information
- A. Proprietary Name : T-Stat™ 2.0 Microvascular Tissue Oximeter
- B. Common Names: Tissue Oximeter, Somatic/Cranial Oximeter
- C. Classification Name: Oximeter, Tissue (870.2700)
- D. Product Code: MUD
- E. Regulatory Class: ll
- F. Panel: Cardiovascular
lll. Predicate Device
The device in this 510(k) represents a modification to the T-Stat 303™ Microvascular Tissue Oximeter approved in 510(k) K081233 which is the predicate device.
{4}------------------------------------------------
IV. General Description
The Spectros T-Stat™ 2.0 Microvascular Tissue Oximeter is a broadband, multiwavelength, Visible Light Spectroscopy (VLS) monitoring system for measuring the saturation of hemoglobin with oxygen in the microvascular tissue spaces (StO2%).
The complete system consists of a disposable sensor probe connected to a software-driven electronic monitor. Data collection, analysis, and display functions are provided by the monitor. Illumination of the tissue is provided by a visible light source in the sensor probe placed near, on, or into the target tissue to be studied. Reflected light is captured and returned to the monitor via a detachable connection at the monitor end of the patient probe. StO2% is estimated using differential optical diffuse reflectance spectroscopy and fitting for background scattering over a range of reflected visible wavelengths.
V. Indications
The Spectros T-Stat™ 2.0 Microvascular Tissue Oximeter is intended for use as an adjunct monitor of the localized hemoglobin oxygen saturation of blood in the microvascular tissue spaces (StO2%) in infants, children, or adults at risk for reduced-flow and no-flow ischemic states.
The prospective clinical value of measurements made with the T-Stat™ Oximeter has not been demonstrated in disease states. The T-Stat™ Oximeter should not be used as the sole basis for diagnosis or therapy.
VI. Comparison to Predicate
The system in this 510(k) represents a modification to the T-Stat303™ Oximeter System described in the predicate 510(k), K081233. These modifications consist of
-
- Monitor housing changed from molded plastic to all metal.
-
- Obsolete display, motherboard, and power supply replaced.
-
- Internal circuit boards consolidated.
-
- Addition of battery backup and Wi-Fi data download features.
- Updated software to work on windows 10 Pro and added 5. modules for indication of battery status and Wi-Fi data download capability.
{5}------------------------------------------------
VII. Test Summary
Validation testing was determined based upon an ISO14971 risk analysis.
- A. Monitor tests on the re designed monitor consist of re-verification of compliance with IEC60601-1-2 and IEC 60601-1.
- B. Software updates were implemented in compliance with IEC 62304 and validated using an in house validation procedure as well as automated testing and code reviews.
- C. Functional continuity was confirmed through reverification of the predicate device hardware and software functional requirements using the predicate device protocols.
VIII. Conclusions
Based upon the above test results the modified T-Stat 303™ Oximeter System represents an improvement over the predicate providing additional features, equivalent safety performance.
§ 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).