K Number
K201977
Device Name
TempTraq
Date Cleared
2020-12-03

(140 days)

Product Code
Regulation Number
880.2910
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Wireless thermometers are battery-operated electronic devices with intended use of measuring human body temperature precisely. The devices are single-use and intended for armpit temperature measurement for persons of all ages.
Device Description
TempTraq is a single-use device used to monitor temperature. The type of temperature that can be taken by the TempTraq patch is axillary only. The TempTraq temperature patches consist of a flexible circuit board that is positioned between two pieces of foam. The TempTraq temperature sensor patch is applied to the patient via foam that is backed with a biocompatible adhesive and transmits body temperature data via low energy Bluetooth transmission to a smart device running a TempTraq application. The patch is worn on the underarm and senses, processes, stores, and transmits temperature data to a smart device running a compatible TempTrag application using Bluetooth LE.
More Information

Not Found

No
The summary describes a device that senses, processes, stores, and transmits temperature data. It mentions standard software validation, cybersecurity, and usability testing, but there is no mention of AI, ML, or any related concepts like training sets, test sets, or specific algorithms associated with AI/ML. The performance studies focus on accuracy, battery life, biocompatibility, and adherence, not on AI/ML model performance.

No.

The device is a thermometer used for measuring human body temperature. While temperature monitoring can be part of a therapeutic process, the device itself does not provide therapy or treatment.

No.

The device is a wireless thermometer used for measuring human body temperature. While temperature measurement can be part of a diagnostic process, the device itself only provides a physiological measurement and does not interpret this measurement to diagnose a condition.

No

The device description explicitly states that the device consists of a flexible circuit board, foam, adhesive, and transmits data via Bluetooth. It also mentions battery-operated electronic devices. This indicates the presence of hardware components beyond just software. The performance studies also include extensive testing of hardware aspects like temperature range, operating time, battery capacity, electrical safety, and adherence properties.

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 description clearly states the device measures human body temperature. This is a direct measurement of a physiological parameter in vivo (within the living body), not a test performed on a sample in vitro (in a lab setting).
  • Intended Use: The intended use is to measure human body temperature, which aligns with a general medical device for monitoring vital signs, not an IVD.
  • Device Description: The description details a wearable patch that senses and transmits temperature data from the body. This is consistent with an in vivo measurement device.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples, reagents, or laboratory procedures, which are hallmarks of IVD devices.

Therefore, the TempTraq Wireless Thermometer is a medical device for measuring body temperature, but it does not fit the definition of an In Vitro Diagnostic.

N/A

Intended Use / Indications for Use

The Wireless thermometers are battery-operated electronic devices with intended use of measuring human body temperature precisely. The devices are single-use and intended for armpit temperature measurement for persons of all ages.

Product codes

FLL

Device Description

TempTraq is a single-use device used to monitor temperature. The type of temperature that can be taken by the TempTraq patch is axillary only. The TempTraq temperature patches consist of a flexible circuit board that is positioned between two pieces of foam.
The TempTraq temperature sensor patch is applied to the patient via foam that is backed with a biocompatible adhesive and transmits body temperature data via low energy Bluetooth transmission to a smart device running a TempTraq application. The patch is worn on the underarm and senses, processes, stores, and transmits temperature data to a smart device running a compatible TempTraq application using Bluetooth LE.
The TempTraq temperature sensor patch is available in three (3) different configurations: TT-100 (24-hour operating time), TT-200 (48-hour operating time), and TT-300 (72-hour operating time).

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Armpit

Indicated Patient Age Range

all ages

Intended User / Care Setting

Home User, Hospital Patient, Clinician.
Use Environment: Home and Clinical

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

Non-Clinical Testing to Determine Substantial Equivalence:

  • System verification was performed via bench testing, including testing to E1112-00 standard specification for electronic thermometer for intermittent determination of patient temperature, temperature range testing, operating time testing, and distance testing. (Performed for predicate K143267, applicable to subject device)
  • Real time aging tests confirmed shelf life of all packaged TempTraq models to be four years.
  • Biocompatibility testing for TT-100, TT-200, and TT-300 was repeated for updated materials.
  • Battery capacity for TT-200 and TT-300 was tested to confirm 48-hour and 72-hour operational life respectively.
  • Electrical safety (IEC 60601-1 Edition 3.1) and EMC testing (IEC 60601-1-2 4th Edition) was repeated for updated circuit board.
  • Engineering Analysis and Verification Testing confirmed that the updated TempTraq System (with updated circuit and device design) meets predicate requirements.
  • Bench testing for TT-100, TT-200, and TT-300 confirmed patch performance including accuracy, temperature stabilization, and operating time. Confirmed TT-200 and TT-300 meet performance of TT-100.
  • Adherence properties of TT-200 and TT-300 were tested to confirm consistency with TT-100.
  • Software verification and validation was performed for TempTraq Consumer Mobile Application, TempTraq Patient Mobile Application, and TempTraq Clinician Mobile Application (iOS and Android) and TempTraq Web Application (Chrome, Safari, Firefox) in accordance with FDA's "Guidance for Industry and FDA Staff: General Principles of Software Validation" (January 11, 2002) and IEC 62304:2015.
  • Cybersecurity testing was performed for the TempTraq system, including Software Penetration Verification and Validation Testing for Android and iOS Apps, confirming appropriate information security controls based on "Guidance for Industry and Food and Drug Administration Staff: Content of Premarket Submissions for Management of Cybersecurity in Medical Devices" (October 2, 2014).
  • Software verification and validation was performed for TempTraq Connect cloud services to determine that sharing data functionality was safe and effective.
  • Usability testing was performed for the TempTraq System in accordance with IEC 60601-1-6 and based on "Guidance for Industry and Food and Drug Administration Staff: Applying Human Factors and Usability Engineering to Medical Devices" (February 3, 2016).

Key Metrics

Accuracy: +/- 0.1 °C (0.2 °F) between 30 °C ~ 42.4 °C (86 °F ~ 108.3 °F)

Predicate Device(s)

K143267

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.

December 3, 2020

Blue Spark Technologies Inc. % Rita King CEO MethodSense, Inc. 1 Copley Pkwy. Ste. 410 Morrisville, North Carolina 27560

Re: K201977

Trade/Device Name: TempTraq, Model: TT-100, TT-200, TT-300 Regulation Number: 21 CFR 880.2910 Regulation Name: Clinical Electronic Thermometer Regulatory Class: Class II Product Code: FLL Dated: November 3, 2020 Received: November 4, 2020

Dear Rita King:

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/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 medical devices and radiation-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,

for Payal Patel Acting 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) K201977

Device Name

TempTraq, Model: TT-100, TT-200, TT-300

Indications for Use (Describe)

The Wireless thermometers are battery-operated electronic devices with intended use of measuring human body temperature precisely. The devices are single-use and intended for armpit temperature measurement for persons of all ages.

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)

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Summary of 510(k)

Blue Spark Technologies Inc. K201977

This 510(k) Summary is in conformance with 21CFR 807.92

| Submitter: | Blue Spark Technologies Inc.
806 Sharon Drive, Suite G,
Westlake, OH 44145 USA
Phone: 440-249 5400
Fax: Phone: 440-249 5400 |
|------------------|-----------------------------------------------------------------------------------------------------------------------------------------|
| Primary Contact: | Rita King, CEO
MethodSense, Inc.
Email: ritaking@methodsense.com
Phone: 919-313-3961
Fax: 919-313-3979 |
| Company Contact: | John Gannon
CEO
Email: jgannon@bluesparktechnologies.com |
| Date Prepared: | November 3rd 2020 |

Device Name and Classification

Trade Name:TempTraq TT-100, TT-200, TT-300
Common Name:Clinical electronic thermometer
Classification:Class II
Regulation Number:21 CFR 820.2910
Classification Panel:General Hospital
Product Code:FLL

Predicate Device:

Predicate
Trade NameTempTraq TT-100
Common NameClinical Electronic Thermometer
510(k) Submitter / HolderBlue Spark Technologies Inc.
510(k) NumberK143267
Regulation Number21 CFR 820.2910
Classification PanelGeneral Hospital
Product CodeFLL

Device Description

TempTraq is a single-use device used to monitor temperature. The type of temperature that can be taken by the TempTraq patch is axillary only. The TempTraq temperature patches consist of a flexible circuit board that is positioned between two pieces of foam.

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The TempTraq temperature sensor patch is applied to the patient via foam that is backed with a biocompatible adhesive and transmits body temperature data via low energy Bluetooth transmission to a smart device running a TempTraq application. The patch is worn on the underarm and senses, processes, stores, and transmits temperature data to a smart device running a compatible TempTrag application using Bluetooth LE.

The TempTraq temperature sensor patch is available in three (3) different configurations: TT-100 (24-hour operating time), TT-200 (48-hour operating time), and TT-300 (72-hour operating time). The TempTraq temperature sensor patches are intended to be used in different use environments. The patches can only be connected to specific TempTraq applications depending on their intended use environment:

Patch ModelCompatible TempTraq ApplicationsUse Environment
TT-100TempTraq Consumer Mobile Application
TempTraq Patient Mobile Application
TempTraq Clinician Mobile Application
TempTraq Clinician Web ApplicationHome and Clinical
TT-200TempTraq Consumer Mobile ApplicationHome
TT-300TempTraq Patient Mobile Application
TempTraq Clinician Mobile Application
TempTraq Clinician Web ApplicationClinical

Table 1: Compatible TempTraq Patches, Applications, and Use Environments

To view temperature data from the TempTraq temperature sensor patch, a user can use one of four configurations of the TempTraq application, depending on the role of the user:

Table 2: TempTraq Applications Use Environments and End Users
-----------------------------------------------------------------------
TempTraq ApplicationUse EnvironmentEnd Users
TempTraq Consumer Mobile ApplicationHomeHome User
TempTraq Patient Mobile ApplicationClinicalHospital Patient
TempTraq Clinician Mobile ApplicationClinicalClinician
TempTraq Clinician Web ApplicationClinicalClinician

The TempTraq Consumer Mobile Application is intended to be used by home users to receive data to their smart device from TempTraq TT-100 and TT-200 patches via Bluetooth connection. Multiple patches can transmit data to the application so that multiple patients' temperatures can be monitored. Additionally, the application features an optional TempTraq Connect cloud service that allows temperature data to be shared with other TempTraq Connect users and an export function that allows data to be shared with others via email.

The TempTrag Patient Mobile application is intended to be used by hospital patients to receive data to their smart device from TempTraq TT-100 and TT-300 patches. Only the patient's own data can be viewed in the patient application and all data is shared with their clinician via TempTraq Connect cloud services. The patient's Clinician can then view the temperature data via the TempTrag Clinician Mobile Application or TempTraq Clinician Web Application. Multiple patients can be added to and monitored via the Clinician Mobile and Web Applications. If patients do not own a smart device, data from the TempTrag patches can also be obtained via Bluetooth gateways strategically placed throughout a hospital which then transmit data directly to the TempTraq Connect cloud services.

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Indications for Use

The Wireless thermometers are battery-operated electronic devices with intended use of measuring human body temperature precisely. The devices are single-use and intended for armpit temperature measurement for persons of all ages.

Substantial Equivalence

The table below provides a detailed comparison of TempTraq to the predicate device.

| ltem | Subject Device
TempTraq, models
TT-100, TT-200 and TT-300 | Predicate Device
TempTraq, model TT-100 | Comparison |
|----------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------|
| Indications
for Use | The Wireless thermometers
are battery-operated
electronic devices with
intended use of measuring
human body temperature
precisely. The devices are
single-use and intended for
armpit temperature
measurement for persons of
all ages. | The Wireless thermometer,
model TT-100, is a battery-
operated electronic device
with intended use of
measuring human body
temperature precisely. This
device is single-use and
intended for armpit
temperature measurement
for persons of all age. | Similar.
See Note 1. |
| Product
Code | FLL | FLL | Identical |
| Regulation # | 21CFR880.2910 | 21CFR880.2910 | Identical |
| Display Use
Specification | iOS device display, Android
device display, Web based | iOS device display and
Android device display | Similar.
See Note 2. |
| Working
Voltage | 3.0V DC | 3.0V DC | Identical |
| Battery | Two (2) Blue Spark 1.5 V
batteries (103-UT1) | Two (2) Blue Spark 1.5 V
batteries (103-UT1) | Identical |
| Measurement
Range | 30 - 42.4 °C (86 °F ~ 108.3
°F) | 30 - 42.4 °C (86 °F ~ 108.3
°F) | Identical |
| Accuracy | +/- 0.1 °C (0.2 °F) between
30 °C ~ 42.4 °C (86 °F ~
108.3 °F) | +/- 0.1 °C (0.2 °F) between
30 °C ~ 42.4 °C (86 °F ~
108.3 °F) | Identical |
| Temperature
Unit | °C or °F | °C or °F | Identical |
| Signal
Transmission | Wireless Bluetooth BLE 4.0
operating at 2.4Ghz | Wireless Bluetooth BLE 4.0
operating at 2.4Ghz | Identical |
| Receiver | Wireless Bluetooth BLE 4.0
enabled smart devices
running Apple operating
system iOS 9.0 and further
or Android operating system
4.3 and further | Wireless Bluetooth BLE 4.0
enabled smart devices
running Apple operating
system iOS 7.1 through 8.1
or Android operating system
4.3 through 4.4.4 | Similar.
See Note 3. |
| Valid
Transmission | Up to 40 feet | Up to 40 feet | Identical |
| Item | Subject Device
TempTraq, models
TT-100, TT-200 and TT-300 | Predicate Device
TempTraq, model TT-100 | Comparison |
| Operating
Temperature | 16 C ~ 40 °C (60.8 °F ~ 104 °F) | 16 C ~ 40 °C (60.8 °F ~ 104 °F) | Identical |
| Operating
Humidity | 15%-95% RH | 15%-95% RH | Identical |
| Anatomical
Application | Armpit
peel-and-stick contact
thermometer sensor | Armpit
peel-and-stick contact
thermometer sensor | Identical |
| Patient
Usage | Single-Use | Single-use | Identical |
| Temperature
Measurement
Interval | Continuous-transmitter
measures body temperature
every 10 seconds | Continuous-transmitter
measures body temperature
every 10 seconds | Identical |
| Memory
Function | TT-100: Can store up to 24
hours of readings
TT-200: Can store up to 48
hours of readings
TT-300: Can store up to 72
hours of readings | TT-100: Can store up to 24
hours of readings | Different.
See Note 4. |
| Storage | Data back-up- Stored in app
and optionally TempTraq
Connect | Data back-up- stored in App | Different.
See Note 5. |
| Run Time | TT-100: 24-Hours
TT-200: 48-Hours
TT-300: 72-Hours | TT-100: 24-Hours | Different.
See Note 6. |
| Patient
Contacting
Materials | ISO 10993-1:2009(R)2013
Compliant Silicone Gel
Adhesive | ISO 10993-1:2009(R)2013
Compliant Acrylic Adhesive | Different.
See Note 7. |
| Applications | TempTraq Consumer Mobile
Application
TempTraq Patient Mobile
Application
TempTraq Clinician Mobile
Application
TempTraq Clinician Web
Application | TempTraq Mobile Application | Different.
See Note 8. |
| Dimensions | Length: 100.0 mm
Height: 50.0 mm
Thickness: 2.0 mm
Weight: 5.1 grams | Length: 98.2 mm
Height: 46.6 mm
Thickness: 3.0 mm
Weight: 4.5 grams | Different.
See Note 9. |
| Item | Subject Device
TempTraq, models
TT-100, TT-200 and TT-300 | Predicate Device
TempTraq, model TT-100 | Comparison |
| Flexible
Printed
Circuit | Version 6.0 | Version 4.0 | Similar.
See Note 10. |
| Storage
Temperature | -4 to 122 °F (-20 °C to 50 °C) | -4 to 122 °F (-20 °C to 50 °C) | Identical |
| Storage
Humidity
Range | 15 - 95% RH (non-
condensing) | 15 - 95% RH (non-
condensing) | Identical |

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  • Note 1. The Indications for Use of the proposed TempTrag System, models TT-100, TT-200 and TT-300, is similar to the predicate device, but is inclusive of all models. This difference does not affect safety and effectiveness.
  • Note 2. The Display Use Specification for the proposed TempTraq System is similar to the predicate device, with an additional web-based display use specification. Software Verification and Validation and Performance testing was conducted to demonstrate this difference does not affect safety and effectiveness.
  • Note 3. The Receiver for the proposed TempTraq System differs from the predicate device, with different operating system compatibility. Software Verification and Validation testing was conducted to demonstrate this difference does not affect safety and effectiveness.
  • Note 4. The Memory Function for the proposed TempTraq System differs from the predicate device. Performance testing was conducted to demonstrate this difference does not affect safety and effectiveness.
  • Note 5. The Storage for the proposed TempTraq System differs from the predicate device. Software Verification and Validation and Performance testing was conducted to demonstrate this difference does not affect safety and effectiveness.
  • Note 6. The Run Time for two new models (TT-200 and TT-300) of the proposed TempTraq System differs from the predicate device. Performance testing was conducted to demonstrate this difference does not affect safety and effectiveness.
  • Note 7. The patient contacting material for the proposed TempTraq System differs from the predicate device. Biocompatibility testing was conducted in accordance with ISO 10993-1 to demonstrate this difference does not affect safety and effectiveness.
  • Note 8. The Applications for the proposed TempTrag System differ from the predicate device. Software Verification and Validation and Performance testing was conducted to demonstrate this difference does not affect safety and effectiveness.
  • Note 9. The dimensions for the proposed TempTraq System differ from the predicate device. This difference does not have any impact on safety or effectiveness.
  • Note 10. The Flexible Printed Circuit for the proposed TempTrag System is similar to the predicate device. Electrical Safety (IEC 60601-1 Edition 3.1) and EMC testing (IEC 60601-1-2 4th Edition) was conducted to demonstrate this difference does not affect safety and effectiveness.

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Non-Clinical Testing to Determine Substantial Equivalence

As part of the previously cleared submission (K143267), the following testing was performed for the TempTraq TT-100 device. This testing is still applicable for this submission:

  • System verification was performed via bench testing, including testing to E1112-00 . standard specification for electronic thermometer for intermittent determination of patient temperature, temperature range testing, operating time testing, and distance testing.
    Blue Spark performed the following additional testing in order to demonstrate substantial equivalence for the proposed TempTraq System (TT-100, TT-200, and TT-300):

  • Real time aging tests were completed. The shelf life of all packaged TempTraq models . was confirmed to be four years.

  • . Biocompatibility testing for the TempTrag devices of TT-100. TT-200, and TT-300 was repeated for the updated materials of the TempTraq device.

  • . Battery capacity for the TempTrag devices of TT-200 and TT-300 was tested in order to confirm the battery life of the TT-200 supports a 48-hour operational life and TT-300 supports a 72-hour operational life. The testing was performed similar to the previous testing done on the TT-100 from the previously cleared submission (K143267).

  • . Electrical safety (IEC 60601-1 Edition 3.1) and EMC testing (IEC 60601-1-2 4th Edition) was repeated for the updated circuit board of TempTraq.

  • . Engineering Analysis and Verification Testing to confirm that the updated TempTraq System (with updated circuit and device design) meets the requirements of the predicate (K143267).

  • . Bench testing was completed for the TempTrag System (models TT-100, TT-200 and TT-300) to confirm the performance of the patch. These additional tests contain an accuracy test, temperature stabilization test, and an operating time test. They confirmed that the additional TT-200 and TT-300 models meet the performance of the TT-100 model previously cleared.

  • . Adherence properties of the TT-200 and TT-300 were tested in order to confirm that they are consistent with the adherence performance of the previously cleared TT-100 model.

  • . Software verification and validation was performed for the different configurations of the TempTraq Application (TempTraq Consumer Mobile Application, TempTraq Patient Mobile Application, and TempTrag Clinician Mobile Application for iOS and Android and TempTraq Web Application for Chrome, Safari, and Firefox) in accordance with FDA's "Guidance for Industry and FDA Staff: General Principles of Software Validation" (January 11, 2002) and IEC 62304:2015.

  • . Cybersecurity testing was performed for the TempTraq system. This includes Software Penetration Verification and Validation Testing, performed for both the Android App and iOS App. This testing confirmed that appropriate information security controls are implemented within the network and host environment to preserve the integrity,

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confidentiality, and availability of its information and computing resources based on considerations from "Guidance for Industry and Food and Drug Administration Staff: Content of Premarket Submissions for Management of Cybersecurity in Medical Devices" (October 2, 2014).

  • . Software verification and validation was performed for TempTraq Connect cloud services in order to determine that the sharing data functionality was safe and effective.
  • . Usability testing was performed for the TempTraq System in accordance with IEC 60601-1-6 and based on considerations from "Guidance for Industry and Food and Drug Administration Staff: Applying Human Factors and Usability Engineering to Medical Devices" (February 3, 2016).

Conclusions

Based on the performance testing, comparison, and analysis, the subject device is substantially equivalent to the predicate device.