K Number
K200946
Device Name
Clever Forehead Thermometer / Clever Medical Forehead Thermometer (Model TD-1241)
Date Cleared
2022-04-05

(727 days)

Product Code
Regulation Number
880.2910
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Clever Forehead Thermometer/Clever Medical Forehead Thermometer (TD-1241) is an infrared thermometer intended for the non-contact measurement of human body temperature in people of all ages and may be used by medical professionals or by consumers in a home environment.
Device Description
The Clever Forehead Thermometer/Clever Medical Forehead Thermometer (TD-1241) is a handheld, battery powered, infrared forehead thermometer with a non-contact body temperature measuring function. It detects infrared energy emitted from forehead within 1.2 - 5 cm and converts to a body temperature. This device can be used on people of all ages by medical professionals and consumers in a home environment. The final measured temperature will be displayed on the LCD screen of the device. The users can transmit temperature results from the Clever Forehead Thermometer/Clever Medical Forehead Thermometer to Healthy Check on their mobile devices and Health care management system on pc via Bluetooth. The Healthy check and Health care management system provide an overview of users record with historical data and trend graph.
More Information

Not Found

No
The document describes a standard infrared thermometer that measures temperature and transmits data. There is no mention of AI/ML algorithms for data processing, interpretation, or decision-making.

No
The device is described as an infrared thermometer intended for "non-contact measurement of human body temperature," which is a diagnostic function, not a therapeutic one.

Yes
The device is described as an "infrared thermometer intended for the non-contact measurement of human body temperature," which is a diagnostic function because it measures a physiological parameter to assist in health assessment.

No

The device description clearly states it is a "handheld, battery powered, infrared forehead thermometer" with an LCD screen, indicating it is a physical hardware device that measures temperature. While it can transmit data to software, the core medical device is the thermometer itself.

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 Clever Forehead Thermometer/Clever Medical Forehead Thermometer measures body temperature by detecting infrared energy emitted from the forehead. This is a non-invasive measurement taken directly from the body, not from a sample taken from the body.
  • Intended Use: The intended use is for "non-contact measurement of human body temperature," which is a physiological measurement, not a diagnostic test performed on a sample.

Therefore, the device falls under the category of a medical device used for physiological monitoring, not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

The Clever Forehead Thermometer/Clever Medical Forehead Thermometer (TD-1241) is an infrared thermometer intended for the non-contact measurement of human body temperature in people of all ages and may be used by medical professionals or by consumers in a home environment.

Product codes

FLL

Device Description

The Clever Forehead Thermometer/Clever Medical Forehead Thermometer (TD-1241) is a handheld, battery powered, infrared forehead thermometer with a non-contact body temperature measuring function. It detects infrared energy emitted from forehead within 1.2 - 5 cm and converts to a body temperature. This device can be used on people of all ages by medical professionals and consumers in a home environment. The final measured temperature will be displayed on the LCD screen of the device. The users can transmit temperature results from the Clever Forehead Thermometer/Clever Medical Forehead Thermometer to Healthy Check on their mobile devices and Health care management system on pc via Bluetooth. The Healthy check and Health care management system provide an overview of users record with historical data and trend graph.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Forehead

Indicated Patient Age Range

all ages

Intended User / Care Setting

medical professionals or by consumers in a home 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

A clinical accuracy testing evaluated 250 subjects which were performed on the following three age groups: infants (newborn to one vear), children (greater than one to five years), and adults (greater than five years old) in accordance with ASTM standard (E1965-98) to compare the Clever Forehead Thermometer/Clever Medical Forehead Thermometer with the comparator method (WelchAllyn SureTemp PLUS model 690 Thermometer). This clinical accuracy study demonstrated that the temperatures obtained with the Clever Forehead Thermometer/Clever Medical Forehead Thermometer were highly related when compared to the comparator method. The clinical bias with stated uncertainty and clinical repeatability as defined in the ASTM standard (E1965-98) were within clinical acceptability.

Key Metrics

Not Found

Predicate Device(s)

K131771

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 880.2910 Clinical electronic thermometer.

(a)
Identification. A clinical electronic thermometer is a device used to measure the body temperature of a patient by means of a transducer coupled with an electronic signal amplification, conditioning, and display unit. The transducer may be in a detachable probe with or without a disposable cover.(b)
Classification. Class II (performance standards). The device is exempt from the premarket notification procedures in part 807, subpart E of this chapter, subject to the limitations in § 880.9 and the following conditions for exemption:(1) Device is not a clinical thermometer with telethermographic functions;
(2) Device is not a clinical thermometer with continuous temperature measurement functions; and
(3) Appropriate analysis and testing (such as that outlined in the currently FDA-recognized editions, as appropriate, of ISO 80601-2-56, “Medical electrical equipment—Part 2-56: Particular requirements for basic safety and essential performance of clinical thermometers for body temperature measurement,” or ASTM E1965, “Standard Specification for Infrared Thermometers for Intermittent Determination of Patient Temperature,” or ASTM E1112, “Standard Specification for Electronic Thermometer for Intermittent Determination of Patient Temperature,” or ASTM E1104, “Standard Specification for Clinical Thermometer Probe Covers and Sheaths”) must validate specifications and performance of the device.

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Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

TaiDoc Technology Corporation Jacky Chou Regulatory Affairs Director 6F, No.127, Wugong 2nd Rd., Wugu District New Taipei City, 24888 TWN

April 5, 2022

Re: K200946

Trade/Device Name: Clever Forehead Thermometer / Clever Medical Forehead Thermometer (TD-1241) Regulation Number: 21 CFR 880.2910 Regulation Name: Clinical Electronic Thermometer Regulatory Class: Class II Product Code: FLL Dated: March 4, 2022 Received: March 7, 2022

Dear Jacky Chou:

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,

Payal Patel Assistant Director DHT3C: Division of Drug Delivery and General Hospital Devices, and Human Factors OHT3: Office of GastroRenal, ObGyn, General Hospital and Urology Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K200946

Device Name

Clever Forehead Thermometer/Clever Medical Forehead Thermometer (TD-1241)

Indications for Use (Describe)

The Clever Forehead Thermometer/Clever Medical Forehead Thermometer (TD-1241) is an infrared thermometer intended for the non-contact measurement of human body temperature in people of all ages and may be used by medical professionals or by consumers in a home environment.

Type of Use (Select one or both, as applicable)
---------------------------------------------------

Prescription Use (Part 21 CFR 801 Subpart D)

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

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510(k) Summary

K200946

ManufacturerTaiDoc Technology Corporation
Address6F, No. 127, Wugong 2nd Rd. Wugu Dist.
New Taipei City, Taiwan 24888
Establishment Registration No.3004145393
Date PreparedMarch 23, 2022
CorrespondentTaiDoc Technology Corporation
Correspondent ContactJacky Chou
TitleRegulatory Affairs Director
Phone+886-2-6625-8188

Submitter information

Proposed Device Information

| Proprietary name | Clever Forehead Thermometer/Clever Medical Forehead
Thermometer (TD-1241) |
|----------------------|------------------------------------------------------------------------------|
| Common name | Clinical Electronic Thermometer |
| Product code | FLL |
| Classification panel | General Hospital |
| Classification | II |
| Regulation Number | 21 CFR §880.2910 |

Predicate Device Information

ManufacturerTaiDoc Technology Corporation
Proprietary NameCaregiver Professional Clinical Thermometer, PRO-TF series
(Model PRO-TF300)
Common NameClinical Electronic Thermometer
510(k) NumberK131771

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Indications for use

The Clever Forehead Thermometer/Clever Medical Forehead Thermometer (TD-1241) is an infrared thermometer intended for the non-contact measurement of human body temperature in people of all ages and may be used by medical professionals or by consumers in a home environment.

Device Description

The Clever Forehead Thermometer/Clever Medical Forehead Thermometer (TD-1241) is a handheld, battery powered, infrared forehead thermometer with a non-contact body temperature measuring function. It detects infrared energy emitted from forehead within 1.2 - 5 cm and converts to a body temperature. This device can be used on people of all ages by medical professionals and consumers in a home environment. The final measured temperature will be displayed on the LCD screen of the device. The users can transmit temperature results from the Clever Forehead Thermometer/Clever Medical Forehead Thermometer to Healthy Check on their mobile devices and Health care management system on pc via Bluetooth. The Healthy check and Health care management system provide an overview of users record with historical data and trend graph.

Principle of Operation

The thermometer measures temperature by reading infrared radiation emitting from the forehead and converts it into a temperature value.

Comparison to the Predicate

The similarities and differences between the predicate and proposed devices are summarized in Table 1 below.

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CharacteristicPredicate device:Proposed device:Comparison
Indications for useCaregiver Professional
Clinical Thermometer,
PRO-TF series (Model
PRO-TF300) (K131771)Clever Forehead
Thermometer/Clever
Medical Forehead
Thermometer (K200946)Similar
Caregiver Professional
Clinical Thermometer is an
infrared thermometer
intended for the
measurement of human
body temperature in people
of all ages without contact
to the body and may be
used by medical
professionals or by
consumers in a home
environment.The Clever Forehead
Thermometer/Clever
Medical Forehead
Thermometer (TD-1241) is
an infrared thermometer
intended for the non-contact
measurement of human
body temperature in people
of all ages and may be used
by medical professionals or
by consumers in a home
environment.
ComponentsPower button, temperature
measurement button,
scanner, 4 side buttons,
protective cap,
microcontroller, and LCDPower button, temperature
measurement button,
scanner, 4 side buttons,
protective cap,
microcontroller, LCD, and
Bluetooth moduleDifferent
FeaturesTemperatrue measurement

Memory feature (10 sets)

3 Measurement modes | | Temperatrue measurement

Memory feature (30 sets)

3 Measurement modes

Bluetooth

Apps for data transfer | Different |
| | Characteristic | Predicate device: | | Proposed device: | Comparison |
| | | Caregiver Professional
Clinical Thermometer,
PRO-TF series (Model
PRO-TF300) (K131771) | | Clever Forehead
Thermometer/Clever
Medical Forehead
Thermometer (K200946) | |
| Principles of
operation | Temperatures of a subject
and environment are sensed
by the thermopile and
thermistor respectively, then
temperature is transduced
into electrical signal and
feed to analog signal
amplification circuit. The
micro-controler consists of
ADC (analog to digital
signal converter) to process
the signals from the
amplification circuit, Then,
through mathematical
process, and the LCD
displays the temperature
reading on a screen. | Temperatures of a subject
and environment are sensed
by the thermopile and
thermistor respectively, then
temperature is transduced
into electrical signal and
feed to analog signal
amplification circuit. The
micro-controler consists of
ADC (analog to digital
signal converter) to process
the signals from the
amplification circuit, Then,
through mathematical
process, and the LCD
displays the temperature
reading on a screen. | Identical | | |
| MCU | The MSP430FG42x0 is a
microcontroller
configuration with a 16-bit
timer, a high-performance
16-bit sigma-delta A/D
converter, 12-bit D/A
converter, two configurable
operational amplifiers, 32
I/O pins, and a liquid crystal
display driver. | The MSP430FG42x0 is a
microcontroller
configuration with a 16-bit
timer, a high-performance
16-bit sigma-delta A/D
converter, 12-bit D/A
converter, two configurable
operational amplifiers, 32
I/O pins, and a liquid crystal
display driver. | Identical | | |
| Characteristic | Predicate device: | Proposed device: | Comparison | | |
| Materials | Caregiver Professional
Clinical Thermometer,
PRO-TF series (Model
PRO-TF300) (K131771) | Clever Forehead
Thermometer/Clever
Medical Forehead
Thermometer (K200946) | Identical | | |
| | User contacting materials
include ABS (device
housing, power button,
swithes), PC(lens &
protective head cap). | User contacting materials
include ABS (device
housing, power button,
swithes), PC(lens,
protective head cap). | | | |
| | | | | | |
| | | | | | |
| | | | | | |
| Performance | Meets ASTM E 1965:2016 | Meets ASTM E 1965 | Identical | | |
| Electrical Safety | Meets EN 60601-1:2014 | Meets IEC 60601-1 | Identical | | |
| EMC | Meets IEC 60601-1-2:2014 | Meets IEC 60601-1-2 | Identical | | |
| Measurement time | 1 second | 1 second | Identical | | |
| Measurement distance | 1.2 cm – 5 cm | 1.2 cm – 5 cm | Identical | | |
| Reference body site | Rectal for 3 years old | Oral for > 3 years old | | | |
| Mode of operation | Adjusted mode | Adjusted mode | Identical | | |
| | | | | | |
| Weight | 83 g | 83 g | Identical | | |
| Memory/storage | 32kb +256b flash memory | 32kb +256b flash memory | Identical | | |
| | 256b ram | 256b ram | | | |
| Biocompatibility | ISO 10993-1 | ISO 10993-1 | Identical surface material | | |
| Probe cover | Yes | Yes | Identical | | |
| Sensor | IR Thermopile sensor | IR Thermopile sensor | Identical | | |
| Dimension (mm) | 150 (L) x 48.48 (W) x
55.16 (H) | 150 (L) x 48.48 (W) x
55.16 (H) | Identical | | |
| | | | | | |
| Characteristic | Predicate device:
Caregiver Professional
Clinical Thermometer,
PRO-TF series (Model
PRO-TF300) (K131771) | Proposed device:
Clever Forehead
Thermometer/Clever
Medical Forehead
Thermometer (K200946) | Comparison | | |
| Display
Resolution | 0.1 °F /0.1°C | 0.1 °F /0.1°C | Identical | | |
| Measurement
unit | °F or °C | °F or °C | Identical | | |
| Ambient
operation
condition | 50°F to 104°F (10°C to
40°C) | 50°F to 104°F (10°C to
40°C) | Identical | | |
| Meter storage/
transportation
condition | -4°F to 140°F (-20°C to
60°C) | -4°F to 140°F (-20°C to
60°C) | Identical | | |
| Measurement
range | Forehead:
94°F to 108°F (34.4°C to
42.2°C) | Forehead:
71.6°F to 111.2°F (22°C to
44°C) | Different | | |
| | Ambient:
50°F to 104°F (10°C to 40
°C) | Ambient:
50°F to 104°F (10°C to 40
°C) | Identical | | |
| HI/LO Indicator | Forehead:
• ≤94°F (34.4°C) LCD
Display LO
• ≥108°F(42.2°C) LCD
Display HI
Surface: | Forehead:
• ≤94°F (34.4°C) LCD
Display LO
• ≥108°F(42.2°C) LCD
Display HI
Surface: | Identical | | |
| | • 140°F (60°C) LCD
Display HI | • 140°F (60°C) LCD
Display HI | Identical | | |
| Characteristic | Predicate device:
Caregiver Professional
Clinical Thermometer,
PRO-TF series (Model
PRO-TF300) (K131771) | Proposed device:
Clever Forehead
Thermometer/Clever
Medical Forehead
Thermometer (K200946) | Comparison | | |
| Accuracy
(Forehead) | $±0.4°F (±0.2°C) from96.8°F to 102.2°F (36°C to39°C)$ $±0.5°F (±0.3°C) for therange of71.6°F to 96.7°F (22°C to35.9°C) or 102.3°F to108.5°F (39.1°C to 42.5°C)$ | $±0.4°F (±0.2°C) from96.8°F to 102.2°F (36°C to39°C)$ $±0.5°F (±0.3°C) for therange ofless than 36 °C (96.8°F) or greater than 39 °C(102.2 °F)$ | Similar | | |
| Power source | 2 x 1.5V AA batteries | 2 x 1.5V AA batteries | Identical | | |
| Time to Power
saving | 30 Seconds | 30 Seconds | Identical | | |
| Signal output
and display | LCD, Buzzer | LCD, Buzzer, Bluetooth | Different | | |

Table 1: Comparison between the Predicate and Proposed Device

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Substantial Equivalent Discussion

. Indications for use

Indications for use of the Clever Forehead Thermometer/Clever Medical Forehead Thermometer (TD-1241) is similar to its predicate device. The without contact is rephrased to non-contact for more precise wording. No new safety and effectiveness questions were raised.

. Components

The modified device has an added Bluetooth module. ES and EMC testing as well as function validation has been implemented to ensure the safety or effectiveness of the device is unaffected. The difference does not raise new safety or effectiveness questions.

. Features

The Clever Forehead Thermometer/Clever Medical Forehead Thermometer (TD-1241) increases the memory storage limit to 30 temperature readings and added a Bluetooth transfer function. The Clever Forehead Thermometer/Clever Medical Forehead Thermometer (TD-1241) uses the identical memory component, 32kb +256b flash memory 256b ram, as its predicate device. Both the Bluetooth and the memory features have been validated and tested in ES and EMC to ensure the safety or effectiveness of the device.

An additional application feature is added for Bluetooth data transfer. The application has been verified and validated to ensure the safety or effectiveness of the device is unaffected.

. Measurement range and Accuracy

The measurement range and accuracy comply with the ASTM E1965-98 (2016) standards. Laboratory test was conducted, and the test results met the requirements. The difference does not raise new safety and effectiveness questions.

. Signal output and display

Bluetooth signal output is added to the Clever Forehead Thermometer/Clever Medical Forehead Thermometer (TD-1241). The device has been validated and tested in ES and EMC to ensure the Bluetooth signal output does not raised safety or effectiveness issue for the device.

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Non-clinical and performance testing

The entire Hazard Analysis for the Clever Forehead Thermometer/Clever Medical Forehead Thermometer was evaluated to identify all the risks / hazards that could be affected by the modifications to the Clever Forehead Thermometer/Clever Medical Forehead Thermometer. These risks were mitigated using planned measures that included testing to recognized FDA consensus standards. Changes in software were verified and validated using the software development process. The following table, which includes a summary of non-clinical testing data conducted according to FDA recognized consensus standards, is provided in support of the substantial equivalence determination:

Test reportPerformance Standard
Electromagnetic
compatibility (EMC)• IEC 60601-1-2:2014, Medical electrical equipment -- Part 1-2: General
requirements for basic safety and essential performance -- Collateral
Standard: Electromagnetic disturbances -- Requirements and tests
Electrical Safety• IEC 60601-1:2014, Medical electrical equipment - Part 1: General
requirements for basic safety and essential performance
• IEC 60601-1-11:2015, Medical electrical equipment - Part 1-11:
General requirements for basic safety and essential performance -
Collateral Standard: Requirements for medical electrical equipment and
medical electrical systems used in the home healthcare environment
Laboratory accuracy• ASTM E1965-98:2016, Standard Specification for Infrared
Thermometers for Intermittent Determination of Patient Temperature
Clinical accuracy• ASTM E1965-98:2016, Standard Specification for Infrared
Thermometers for Intermittent Determination of Patient Temperature
Storage stability• ASTM E1965-98:2016, Standard Specification for Infrared
Thermometers for Intermittent Determination of Patient Temperature
Shock test• ASTM E1965-98:2016, Standard Specification for Infrared
Thermometers for Intermittent Determination of Patient Temperature
Cleaning procedure• ASTM E1965-98:2016, Standard Specification for Infrared
Thermometers for Intermittent Determination of Patient Temperature
Risk management
report• ISO 14971, Medical devices - Applications of risk management to
medical devices

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BiocompatibilityISO 10993-1, Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process
Software and
CybersecurityIEC 62304, Medical device software - Software life cycle processes ISO/IEC 12207, Systems and software engineering Software life cycle processes Software verification and validation test according to the requirements of the FDA "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices (May 11, 2005)" Guidance for Industry and FDA Staff: Content of Premarket Submissions for Management of Cybersecurity in Medical Devices, October 2018.

Clinical Testing

A clinical accuracy testing evaluated 250 subjects which were performed on the following three age groups: infants (newborn to one vear), children (greater than one to five years), and adults (greater than five years old) in accordance with ASTM standard (E1965-98) to compare the Clever Forehead Thermometer/Clever Medical Forehead Thermometer with the comparator method (WelchAllyn SureTemp PLUS model 690 Thermometer). This clinical accuracy study demonstrated that the temperatures obtained with the Clever Forehead Thermometer/Clever Medical Forehead Thermometer were highly related when compared to the comparator method. The clinical bias with stated uncertainty and clinical repeatability as defined in the ASTM standard (E1965-98) were within clinical acceptability.

Conclusion

The intended use of the subject device, the Clever Forehead Thermometer/Clever Medical Forehead Thermometer, is identical to that of the predicate device, the Caregiver Professional Clinical Thermometer, PRO-TF series (Model PRO-TF300), and a risk analysis was performed to identify risks associated with the device modifications. Verification tests have been performed to demonstrate that the identified risks have been mitigated. The testing and analysis demonstrate that the subject device is substantially equivalent to the predicate device