K Number
K201397
Device Name
Ultrasonic Mesh Nebulizer
Date Cleared
2021-06-14

(382 days)

Product Code
Regulation Number
868.5630
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The Ultrasonic Mesh Nebulizer designed to aerosolized liquid medications for inhalation by patient, the device may be used with pediatic (>4 years of age), defined by the prescribed medication, and adult patients in the home, hospital and sub-acute care settings. It is not intended for use with Pentamidine.
Device Description
The proposed devices are vibrating mesh nebulizers that use low frequency vibration to create aerosol and deliver aerosolized medication to the lower respiratory tract by using a vibrating mesh to create aerosol and provide fine particles to the patient's lungs. The mesh plate has holes to create low velocity aerosol. The proposed devices are portable size, curvaceous body design that is convenient to hold, Which are battery powered, 3.7V d.c. internally lithium battery. The medication container capacity is 8ml maximum. For devices, they are pushed by certain circuit frequency vibration to make piezoelectric ceramic vibrate harmony that caused high speed vibration of metal mesh. And the medicine liguid will be quickly popped through micro mesh hole of metal mesh plate to be countless micro atomizing particles. This will be further transferred by inhalation treatment using masks or mouthpieces to patients' respiratory system. There are 3 models included, MY-123/MY-125/ the three models have same intended use, mechanism of action, principle and specification. The difference between three models is appearance.
More Information

No reference devices were used in this submission.

No
The device description and performance studies focus on the mechanical and electrical aspects of nebulization, with no mention of AI or ML technologies.

Yes.
The device is designed to aerosolize liquid medications for inhalation, which is a therapeutic action aimed at treating the lower respiratory tract.

No

This device is an Ultrasonic Mesh Nebulizer, designed to deliver aerosolized liquid medications for inhalation. Its function is therapeutic (medication delivery), not diagnostic (identifying or characterizing a medical condition).

No

The device description clearly outlines hardware components such as a vibrating mesh, battery, and circuitry, and the performance studies include hardware-related testing like electrical safety and battery cycle life.

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

Here's why:

  • Intended Use: The intended use is to "aerosolized liquid medications for inhalation by patient". This describes a device used to deliver medication directly to a patient's respiratory system.
  • Device Description: The description details a "vibrating mesh nebulizer" that creates aerosolized medication for inhalation. This is a drug delivery device.
  • Mechanism of Action: The mechanism involves vibrating a mesh to create fine particles of liquid medication for inhalation. This is a physical process for drug delivery.
  • Lack of IVD Characteristics: There is no mention of the device being used to test samples (blood, urine, tissue, etc.) in vitro (outside the body) to diagnose, monitor, or screen for diseases or conditions.

IVD devices are used to perform tests on samples taken from the body to provide information about a person's health. This nebulizer is used to administer treatment to the body.

N/A

Intended Use / Indications for Use

The Ultrasonic Mesh Nebulizer designed to aerosolized liquid medications for inhalation by patient, the device may be used with pediatric (>4 years of age), defined by the prescribed medication, and adult patients in the home, hospital and sub-acute care settings.

Product codes

CAF

Device Description

The proposed devices are vibrating mesh nebulizers that use low frequency vibration to create aerosol and deliver aerosolized medication to the lower respiratory tract by using a vibrating mesh to create aerosol and provide fine particles to the patient's lungs. The mesh plate has holes to create low velocity aerosol.

The proposed devices are portable size, curvaceous body design that is convenient to hold, Which are battery powered, 3.7V d.c. internally lithium battery. The medication container capacity is 8ml maximum.

For devices, they are pushed by certain circuit frequency vibration to make piezoelectric ceramic vibrate harmony that caused high speed vibration of metal mesh. And the medicine liguid will be quickly popped through micro mesh hole of metal mesh plate to be countless micro atomizing particles. This will be further transferred by inhalation treatment using masks or mouthpieces to patients' respiratory system.

There are 3 models included, MY-123/MY-125/ the three models have same intended use, mechanism of action, principle and specification. The difference between three models is appearance.

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

pediatric (>4 years of age) and adult patients

Intended User / Care Setting

Home, hospital and sub-acute care settings.

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Non-clinical tests were performed including:

  • Biocompatibility testing: In Vitro Cytotoxicity Test, Skin Sensitization Test (polar and non polar), Intracutaneous Reactivity Test, Acute Systemic Toxicity Test (polar and non polar), Ames Test (polar and DMSO Extract), In Vitro Mammalian Chromosomal Aberration test, Mammalian Erythrocyte Micronucleus Test (polar and non polar), Subcutaneous Implantation Test, Test for emissions of VOCs and aldehydes, Test for emissions of particulate matter ozone CO2 and CO, Biocompatibility evaluation.
  • Electrical Safety and Electromagnetic Compatibility (EMC) testing.
  • Software Verification and Validation Testing.
  • Simulated shelf life testing, battery cycle life testing.
  • Cleaning and Disinfection Validation.
  • Human factors validation testing.
  • Particle size distribution testing using Salbutamol (Ventolin), Budesonide (Pulmicort), and Ipratropium bromide. Comparative particle test data (MMAD, GSD, Respirable fraction, Coarse particle fraction, Fine particle fraction, Ultra-fine particle fraction, residual (%), rate of recovery (%), Aerosol output and aerosol output rate, Dead volume, Respirable dose, Delivered dose) were provided for the subject device (with mouthpiece, small mask, big mask) and the predicate device (with big mask).

Key Results: The nonclinical tests performed demonstrated that the minor differences in specifications (dimensions, weight) do not affect the safety and effectiveness of the device. The device complies with biocompatibility, electrical safety, EMC, and software V&V requirements. Particle test results were presented for various parameters across different accessories and medications, showing comparability with the predicate device.

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

MMAD(µm), GSD, Respirable fraction 1 - 5 µm, Coarse particle fraction >5 µm, Fine particle fraction (FPF

§ 868.5630 Nebulizer.

(a)
Identification. A nebulizer is a device intended to spray liquids in aerosol form into gases that are delivered directly to the patient for breathing. Heated, ultrasonic, gas, venturi, and refillable nebulizers are included in this generic type of device.(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: the Department of Health and Human Services logo on the left and the FDA logo on the right. The FDA logo is in blue and includes the letters "FDA" in a square and the words "U.S. Food & Drug Administration".

Shenzhen Ivankaca Technology Co., Ltd % Long Yang Coo Shenzhen Hlongmed Biotech Co., Ltd. 1201, Haosheng Business Center, 4096 Dongbin Road, Nanshan, Shenzhen, P.R.C Shenzhen, 518054 Cn

Re: K201397

Trade/Device Name: Ultrasonic Mesh Nebulizer Regulation Number: 21 CFR 868.5630 Regulation Name: Nebulizer Regulatory Class: Class II Product Code: CAF Dated: June 14, 2021 Received: June 14, 2021

Dear Long Yang:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. 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 requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part

1

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 (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 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,

Brandon Blakely, PhD Acting Assistant Director DHT1C: Division of ENT. Sleep Disordered Breathing, Respiratory and Anesthesia Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K201397

Device Name Ultrasonic Mesh Nebulizer

Indications for Use (Describe)

The Ultrasonic Mesh Nebulizer designed to aerosolized liquid medications for inhalation by patient, the device may be used with pediatic (>4 years of age), defined by the prescribed medication, and adult patients in the home, hospital and sub-acute care settings.

It is not intended for use with Pentamidine.

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

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510(k) Summary

This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirement of SMDA 1990 and Title 21, CFR Section 807.92.

The assigned 510(K) number is: Date of Summary: 2021.6.2

1. Submitter information

Manufacturer Name: Shenzhen Ivankaca Technology Co.,Ltd

Address: 3/F, Building B, No.45 lixin road, NanWan, Longgang, Shenzhen, Guangdong, China

Contact Person and Title: Sam WONG/General manager

Tel: 0086- 755-28510161

Fax: 0086- 755-28510161

Email: 798401644@qq.com

Date Prepared: June 2, 2021

2. Contact person

2.1 Primary Contact Person

Long Yang (COO)

Shenzhen Hlongmed Biotech Co.,Ltd

1201, Haosheng Business Center, 4096 Dongbin Road, Nanshan, Shenzhen, P.R.C

Tel: 0086-755-86664986

Fax: 0086-755-86664933

E-mail: yanglong@hlongmed.com

2.2 Secondary Contact Person

Sam WONG/General manager Shenzhen Ivankaca Technology Co.,Ltd Tel: 0086- 755-28510161

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3. Proposed device

Type of 510(k) submissionTraditional
Trade Name nameUltrasonic Mesh Nebulizer
Common NameNebulizer
Model(s)MY-123, MY-125, MY-126
Classification NameNebulizer (Direct Patient Interface)
ClassificationII
Review PanelAnesthesiology
Product CodeCAF
Regulation ClassII
Regulation Number21 CFR 868.5630

4. Predicate device

510(k) Number:

K171549

Predicate Device Name:

Intelligent Mesh Nebulizer (model: NEB002)

Manufacturer:

Qingdao Future Medical Technology Co., Ltd

This predicate has not been subject to a design-related recall.

No reference devices were used in this submission.

5. Description of Proposed Device

The proposed devices are vibrating mesh nebulizers that use low frequency vibration to create aerosol and deliver aerosolized medication to the lower respiratory tract by using a vibrating mesh to create aerosol and provide fine particles to the patient's lungs. The mesh plate has holes to create low velocity aerosol.

The proposed devices are portable size, curvaceous body design that is convenient to hold, Which are battery powered, 3.7V d.c. internally lithium battery. The medication

5

container capacity is 8ml maximum.

For devices, they are pushed by certain circuit frequency vibration to make piezoelectric ceramic vibrate harmony that caused high speed vibration of metal mesh. And the medicine liguid will be quickly popped through micro mesh hole of metal mesh plate to be countless micro atomizing particles. This will be further transferred by inhalation treatment using masks or mouthpieces to patients' respiratory system.

There are 3 models included, MY-123/MY-125/ the three models have same intended use, mechanism of action, principle and specification. The difference between three models is appearance.

The proposed devices have the components shown as following illustration:

Image /page/5/Figure/4 description: The image shows two diagrams of a device labeled "MY-123" with various parts labeled. The diagrams show the main unit, atomizing cup, mesh plate, lock, indicator light, on/off button, USB charging port, and the back from the main unit. There is also a diagram of the bottom of the main unit.

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Image /page/6/Figure/0 description: The image shows the text 'MY-125' in a simple, sans-serif font. The text is arranged horizontally, with 'MY' followed by a hyphen and then the number '125'. The text is black against a white background, providing a clear contrast.

Image /page/6/Figure/1 description: The image shows a diagram of a device with several labeled parts. The parts include a mesh plate, main unit, on/off button, indicator light, lock, atomizing cup, back from main, USB charging port, and bottom from main unit. The diagram shows the device from different angles to highlight the different parts.

MY-126

Figure 1 Device Components illustration

The contents provided in the Table are description about the components.

Main UnitProvide electricity
Atomizing
Cupfilled with medicine liquid
Mesh PlateCreate low velocity aerosol
ON/OFF
buttonON/OFF the nebulizer
Press the ON/OFF button for 3s to turn on the power and press turn off
again;
The nebulizer will shut down automatically after 5min operation. Press
on /off for 3S to start the machine when it is still in use
Indicator
lightBlue light on when the nebulizer works regularly;
Automatic turn off after blue light flashes when the battery is running
out electricity;
Blue lights flicker on when charging regularly;
Green light on while finishing charging;
USB
interfaceConnect the nebulizer with the USB cable to 5Vd.c 1.0A min.
power supply to recharge .

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| Mask | Transport the aerosol to patient's respiratory
system. |
|------------|-----------------------------------------------------------|
| Mouthpiece | Transport the aerosol to patient's respiratory
system. |

Table 1 Main Components of Device introduction

The associated accessories include Mouthpiece, Adult Mask, Pediatric Mask, USB charging cable.

6. Intended Use/ Indications for Use

The Ultrasonic Mesh Nebulizer designed to aerosolized liquid medications for inhalation by patient, the device may be used with pediatric (>4 years of age), defined by the prescribed medication, and adult patients in the home, hospital and sub-acute care settings.

It is not intended for use with Pentamidine.

7. Technological Characteristics and Substantial Equivalence

ItemSubject DevicePredicate deviceRemark
General Comparison
K/K171549/
SponsorShenzhen Ivankaca Technology
Co.,LtdQingdao Future Medical Technology
Co., Ltd/
Trade/Device
NameUltrasonic Mesh NebulizerIntelligent Mesh Nebulizer/
Model(s)MY-123
MY-125
MY-126NEB002/
Regulation
Number21 CFR 868.563021 CFR 868.5630same
Regulation
NameNebulizerNebulizersame
Classification
NameNebulizer (Direct Patient Interface)Nebulizer (Direct Patient Interface)same
Regulatory
ClassClass IIClass IIsame
Product CodeCAFCAFsame
Review PanelAnesthesiologyAnesthesiologysame
Intended
Use/
Indications
for UseThe Ultrasonic Mesh Nebulizer designed to aerosolized liquid medications for inhalation by patient, the device may be used with pediatric (>4 years of age), defined by the prescribed medication, and adult patients in the home, hospital and sub-acute care settings. It is not intended for use with Pentamidine.The Intelligent Mesh Nebulizer designed to aerosolized liquid medications for inhalation by patient, the device may be used with pediatric (>4 years of age) and adult patients in the home, hospital and sub-acute care settings. It is not intended for use with Pentamidine.same
Prescription/
OTCPrescriptionPrescriptionsame
Performance Comparison
Lithium
battery3.7Vd.c.3.7Vd.c.Same
Nebulizing
MethodVibrating MeshVibrating Meshsame
Vibration
FrequencyApprox. 110KHzApprox. 110KHzsame
Nebulization
Rate/Aerosol
Flow rate0.2ml/min minimum0.2ml/min minimumsame
Medicine
Capacity8ml maximum,0.5ml minimum8ml maximum,0.5ml minimumsame
Nebulizer
Components
CleanableYesYessame
UseSingle PatientSingle Patientsame
Patient
ConnectorMouthpiece or maskMouthpiece or masksame
Dimensions
(mm)Approx.
42(L)x55(W)x109(H)mm(MY-123)
49(L)x56(W)x120(H)mm(MY-125)
45(L)x47(W)x120(H)mm(MY-126)50mm(L)×74mm(W)×111mm(H)different
Weight (kg)MY-123:113±5g
MY-125:116±5gApprox.106gdifferent
MY-126: 110±5g
Operating
Conditions5°C to 40°C, 15% to 90% RH5°C to 40°C, 15% to 90% RHsame
Storage
Conditions-25°C to 70°C, ≤90% RH-25°C to 70°C, ≤90% RHsame
Safety Comparison
Patient
Contact
MaterialsPVCPVCsame
Cytotoxicity
Sensitization
IrritationComply with 10993-1Comply with 10993-1same
Electrical
safetyComply with 60601-1Comply with 60601-1same
EMCComply with 60601-1-2Comply with 60601-1-2same

8

9

Comparative particle test comparison can be refer to the following table:

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| Item | Subject Device | | | Subject Device | | | Subject Device | | | Intelligent Mesh Nebulizer (model:
NEB002) -K171549 | | |
|----------------------------------------|--------------------------|---------------------------|------------------------|--------------------------|---------------------------|------------------------|--------------------------|---------------------------|------------------------|--------------------------------------------------------|---------------------------|------------------------|
| | Mouthpiece | | | Small mask | | | Big mask | | | Big mask | | |
| | Salbutamol
(Ventolin) | Budesonide
(Pulmicort) | Ipratropium
bromide | Salbutamol
(Ventolin) | Budesonide
(Pulmicort) | Ipratropium
bromide | Salbutamol
(Ventolin) | Budesonide
(Pulmicort) | Ipratropium
bromide | Salbutamol
(Ventolin) | Budesonide
(Pulmicort) | Ipratropium
bromide |
| MMAD(µm) | 3.68±0.68 | 3.28±0.08 | 3.84 ± 0.66 | 3.75±0.63 | 3.25±0.11 | 3.85 ± 0.66 | 3.72±0.65 | 3.31±0.10 | 3.88 ± 0.68 | 3.70±0.66 | 3.29±0.12 | 3.87 ± 0.72 |
| GSD | 1.84±0.03 | 2.44±0.02 | 1.83 ± 0.035 | 1.86±0.05 | 2.46 ± 0.025 | 1.84 ± 0.035 | 1.82 ± 0.035 | 2.48 ± 0.031 | 1.84 ± 0.032 | 1.85±0.04 | 2.50 ± 0.033 | 1.81 ± 0.03 |
| Respirable
fraction
1 - 5 µm | 63.5% ± 10.5 | 61.7% ± 10.5 | 62.4% ± 10.6 | 63.8% ± 11.8 | 60.8 % ± 11.6 | 63.4% ± 11.3 | 64.5% ± 10.2 | 58.8% ± 10.2 | 64.5% ± 11.9 | 62.8% ± 11.3 | 57.6% ± 9.8 | 63.8% ± 11.6 |
| Coarse particle
fraction >5 µm | 36.1% ± 11.3 | 29.1% ± 11.3 | 36.2% ± 12.1 | 33.4% ± 13.0 | 27.4% ± 13.0 | 35.4% ± 12.2 | 38% ± 10.8 | 30.5% ± 12.3 | 33.8% ± 12.4 | 37.2% ± 12.3 | 31.6% ± 11.9 | 34.4% ± 12.3 |
| Fine particle
fraction (FPF 30 days) |
| 3 | Small mask | PP1120
TPE(TE-KJ3025TM) | | no | | |
| 4 | Atomizing cup | PC2456 | | no | | ● External |
| 5 | Seal ring | Silicone GA1053 | | no | | Communicating |
| 6 | Atomizing cup cover | PC2456 | | no | | (Indirect gas |
| 7 | nozzle | PC2456 | | no | | pathway) |

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8Mesh plateStainless304noTissue / Bone / Dentin communicating Duration of Use(> 30 days)
--------------------------------------------------------------------------------------------------

A biocompatibility evaluation for the proposed device was conducted in accordance with FDA ' s 2020 Guidance entitled. " Use of International Standard ISO 10993-1. "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process" . The evaluation included the following tests:

  • In Vitro Cytotoxicity Test -ISO10993-5 A
  • A Skin Sensitization Test(polar and non polar ) -ISO10993-10
  • Intracutaneous Reactivity Test-ISO10993-10

  • A Acute Systemic Toxicity Test (polar and non polar) -ISO10993-11
  • Ames Test (polar and DMSO Extract)--ISO10993-3

  • A In Vitro Mammalian Chromosomal Aberration test --ISO10993-3
  • A Mammalian Erythrocyte Micronucleus Test(polar and non polar) --ISO10993-3
  • A Subcutaneous Implantation Test--ISO10993-6
  • A Test for emissions of VOCs and aldehydes-ISO 18562-3
  • A Test for emissions of particulate matter ozone CO2 and CO- ISO 18562-2
  • A Biocompatibility evaluation- ISO 18562-1

Under the parameters of the tests it is concluded that they are biocompatible, and that there are no new issues of safety regarding their use as intended.

b. Electrical Safety and Electromagnetic Compatibility (EMC)

Electrical safety and EMC testing were conducted on the device. Testing established that, with respect to electrical safety, the device meets the applicable requirements of:

  • AAMI/ANSI ES60601-1:2005/(R)2012 and A1:2012, C1:2009/(R)2012 and A2:2010/(R)2012 (Consolidated Text) Medical electrical equipment - Part 1: General requirements for basic safety and essential performance (IEC 60601-1:2005,

15

MOD)

  • A 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
  • A 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

c. Software Verification and Validation Testing

The software for this device is of a "moderate" level of concern,Verification and validation testing was conducted in accordance with, and documentation was provided as recommended by FDA 's Guidance , " Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices, May 1, 2005".

d. Simulated shelf life testing, battery cycle life testing

e. Cleaning and Disinfection Validation

f. human factors validation testing

g. Particle size distribution testing per Section VII of the FDA Guidance: Reviewer Guidance for Nebulizers, Metered Dose Inhalers, Spacers and Actuators, and three kind of drugs used for each testing. Salbutamol (Ventolin), Budesomide (Pulmicort) , Ipratropium bromide.

9. Clinical Test Conclusion

No clinical study is included in this submission.

10. Substantial Equivalence Conclusion

Based on the comparison and analysis above, the proposed device is determined to be Substantially Equivalent (SE) to the predicate device.