K Number
K212346
Device Name
Infrared Thermometer, Model: PG-IRT1612, PG-IRT1613, PG-IRT1615, PG-IRT1618
Date Cleared
2022-05-05

(281 days)

Product Code
Regulation Number
880.2910
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
PG-IRT1612 & PG-IRT1618 Infrared Forehead Thermometer is intended to measure human body temperature by measuring forehead. The device can be used on people of all ages at home or in hospital environment. PG-IRT1613 & PG-IRT1615 Infrared Ear/Forehead Thermometer is intended to measure human body temperature by measuring ear canal or forehead. The device can be used on people of all ages at home or in hospital environment.
Device Description
The proposed device includes 4 models, which are PG-IRT1613, PG-IRT1613, PG-IRT1615 and PG-IRT1618. All models of infrared thermometers are intended for people of all age. The proposed devices, Infrared Forehead Thermometers, Model PG-IRT1612 and PG-IRT1618, are hand-held, reusable, battery powered device, which are intended to measure human body temperature by measuring forehead. They are non-contact infrared thermometers. The distance of the measurement is 3~5cm. The proposed devices, Infrared Ear/Forehead Thermometers, Model PG-IRT1613 and PG-IRT1615, are hand-held, reusable, battery powered device, which are intended to measure human body temperature by measuring ear canal or forehead. The ear cavity mode is contact measurement. The forehead mode is non-contact measurement and the measurement distance is 1~5mm. The proposed devices are operated in adjusted mode. The body site used to reference the adjusted temperature value displayed on the proposed device of each model is oral. Principle of operation The proposed device uses a temperature sensor, which can detect the object temperature (OBJ) [human body temperature], environment temperature (NTC) and temperature of sensor itself (AMB); these temperatures are then transfer to electronic signal and amplified; and then it is transferred to digital signal by AD module (signal conversion module) in MCU (Microcontroller Unit) of the proposed device. MCU will calculate the body temperature based on OBJ, NTC and AMB, and then transfer to screen for display.
More Information

Not Found

No
The description details a standard infrared thermometer using a temperature sensor and MCU for calculation, with no mention of AI or ML.

No
The device is described as an "Infrared Forehead Thermometer" or "Infrared Ear/Forehead Thermometer" and is "intended to measure human body temperature." Its function is diagnostic (measurement), not therapeutic (treatment).

Yes
The device is intended to measure human body temperature. While temperature measurement itself is not a diagnosis, it provides essential data used to identify fever, which can be indicative of underlying medical conditions, making it a tool used in the diagnostic process.

No

The device description explicitly states that the devices are "hand-held, reusable, battery powered device" and describes hardware components like a temperature sensor, AD module, and MCU. This indicates it is a physical device with embedded software, not a software-only medical device.

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

Here's why:

  • IVDs analyze samples taken from the human body (like blood, urine, tissue). This device measures temperature of the human body externally (forehead or ear canal).
  • The intended use is to measure human body temperature. This is a physiological measurement, not an analysis of a biological sample.
  • The principle of operation involves detecting infrared radiation emitted from the body. This is a physical measurement, not a chemical or biological analysis of a sample.

Therefore, while it is a medical device, it falls under the category of a non-IVD medical device.

N/A

Intended Use / Indications for Use

PG-IRT1612 & PG-IRT1618

Infrared Forehead Thermometer is intended to measure human body temperature by measuring forehead. The device can be used on people of all ages at home or in hospital environment.

PG-IRT1613 & PG-IRT1615

Infrared Ear/Forehead Thermometer is intended to measure human body temperature by measuring ear canal or forehead. The device can be used on people of all ages at home or in hospital environment.

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

FLL

Device Description

The proposed device includes 4 models, which are PG-IRT1613, PG-IRT1613, PG-IRT1615 and PG-IRT1618. All models of infrared thermometers are intended for people of all age.

The proposed devices, Infrared Forehead Thermometers, Model PG-IRT1612 and PG-IRT1618, are hand-held, reusable, battery powered device, which are intended to measure human body temperature by measuring forehead. They are non-contact infrared thermometers. The distance of the measurement is 3~5cm.

The proposed devices, Infrared Ear/Forehead Thermometers, Model PG-IRT1613 and PG-IRT1615, are hand-held, reusable, battery powered device, which are intended to measure human body temperature by measuring ear canal or forehead. The ear cavity mode is contact measurement. The forehead mode is non-contact measurement and the measurement distance is 1~5mm.

The proposed devices are operated in adjusted mode. The body site used to reference the adjusted temperature value displayed on the proposed device of each model is oral.

Principle of operation

The proposed device uses a temperature sensor, which can detect the object temperature (OBJ) [human body temperature], environment temperature (NTC) and temperature of sensor itself (AMB); these temperatures are then transfer to electronic signal and amplified; and then it is transferred to digital signal by AD module (signal conversion module) in MCU (Microcontroller Unit) of the proposed device. MCU will calculate the body temperature based on OBJ, NTC and AMB, and then transfer to screen for display.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Forehead, Ear canal

Indicated Patient Age Range

all ages

Intended User / Care Setting

at home or in hospital 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 (study type, sample size, AUC, MRMC, standalone performance, key results)

Controlled human clinical studies were conducted in accordance with ASTM E1965-98 (Reapproved 2016), clinical bias, clinical uncertainty and clinical repeatability have been evaluated per clinical validation for infrared thermometer. The clinical trial results verify that the clinical accuracy of the proposed device is not inferior to that of predicate device.

Total 120 subjects and three age groups, including age 01 (40 subjects), age 15 (40 subjects) and age above 5 (40 subjects) are included in each clinical study, including febrile persons. Compared statistical result of clinical bias and clinical repeatability of two comparison groups, the results of proposed device are not being inferior to that of predicate device. The result of proposed device was not inferior to that of predicate device, and the proposed device complies with ASTM E1965-98 (Reapproved 2016).

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

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K182597

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 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 contains 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.

May 5, 2022

Shenzhen Pango Medical Electronics Co., Ltd. % Diana Hong General Manager Mid-Link Consulting Co., Ltd P.O. Box 120-119 Shanghai. 200120 China

Re: K212346

Trade/Device Name: Infrared Thermometer, Model: PG-IRT1613, PG-IRT1613, PG-IRT1615, PG-IRT1618 Regulation Number: 21 CFR 880.2910 Regulation Name: Clinical Electronic Thermometer Regulatory Class: Class II Product Code: FLL Dated: March 26, 2022 Received: April 5, 2022

Dear Diana Hong:

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.

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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 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.

David Wolloscheck For 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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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

510(k) Number (if known) K212346

Device Name

Infrared thermometer, Model: PG-IRT1612, PG-IRT1613, PG-IRT1615, PG-IRT1618

Indications for Use (Describe)

PG-IRT1612 & PG-IRT1618

Infrared Forehead Thermometer is intended to measure human body temperature by measuring forehead. The device can be used on people of all ages at home or in hospital environment.

PG-IRT1613 & PG-IRT1615

Infrared Ear/Forehead Thermometer is intended to measure human body temperature by measuring ear canal or forehead. The device can be used on people of all ages at home or in hospital 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

This 510(k) Summary is being submitted in accordance with requirements of Title 21, CFR Section 807.92.

The assigned 510(k) Number: K212346

    1. Date of Preparation: 04/22/2022
    1. Sponsor Identification

Shenzhen Pango Medical Electronics Co., Ltd.

No. 25, 1st Industry Zone, Fenghuang Road, Xikeng Village, Henggang Town, Longgang District, Shenzhen, Guangdong, 518115, China

Establishment Registration Number: 3006792041

Contact Person: Youjian Xie Position: Technical Director Tel: +86-755-33825988-301 Fax: +86-755-33825989 Email: xie_you_jian@163.com

    1. Designated Submission Correspondent
      Ms. Diana Hong (Primary Contact Person) Ms. Jinlei Tang (Alternative Contact Person)

Mid-Link Consulting Co., Ltd. P.O. Box 120-119, Shanghai, 200120, China

Tel: +86-21-22815850, Fax: 360-925-3199 Email: info@mid-link.net

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4. Identification of Proposed Device

Trade Name: Infrared thermometer Common Name: Clinical electronic thermometer Model: PG-IRT1612, PG-IRT1613, PG-IRT1615, PG-IRT1618

Regulatory Information

Classification Name: Clinical electronic thermometer; Classification: II; Product Code: FLL; Regulation Number: 21CFR 880.2910 Review Panel: General Hospital;

Indications for Use:

PG-IRT1612 & PG-IRT1618

Infrared Forehead Thermometer is intended to measure human body temperature by measuring forehead.

The device can be used on people of all ages at home or in hospital environment.

PG-IRT1613 & PG-IRT1615

Infrared Ear/Forehead Thermometer is intended to measure human body temperature by measuring ear canal or forehead.

The device can be used on people of all ages at home or in hospital environment.

Device Description

The proposed device includes 4 models, which are PG-IRT1613, PG-IRT1613, PG-IRT1615 and PG-IRT1618. All models of infrared thermometers are intended for people of all age.

The proposed devices, Infrared Forehead Thermometers, Model PG-IRT1612 and PG-IRT1618, are hand-held, reusable, battery powered device, which are intended to measure human body temperature by measuring forehead. They are non-contact infrared thermometers. The distance of the measurement is 3~5cm.

The proposed devices, Infrared Ear/Forehead Thermometers, Model PG-IRT1613 and PG-IRT1615, are hand-held, reusable, battery powered device, which are intended to measure human body temperature by measuring ear canal or forehead. The ear cavity mode is contact measurement. The forehead mode is non-contact measurement and the measurement distance is 1~5mm.

The proposed devices are operated in adjusted mode. The body site used to reference the adjusted

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temperature value displayed on the proposed device of each model is oral.

Principle of operation

The proposed device uses a temperature sensor, which can detect the object temperature (OBJ) [human body temperature], environment temperature (NTC) and temperature of sensor itself (AMB); these temperatures are then transfer to electronic signal and amplified; and then it is transferred to digital signal by AD module (signal conversion module) in MCU (Microcontroller Unit) of the proposed device. MCU will calculate the body temperature based on OBJ, NTC and AMB, and then transfer to screen for display.

  • న. Identification of Predicate Device
    510(k) Number: K182597 Device Name: Infrared Thermometer Model: PG-IRT1601 Infrared Ear Thermometer PG-IRT1602 Infrared Forehead Thermometer (selected as predicate device) PG-IRT1603 Infrared Ear/Forehead Thermometer (selected as predicate device)

    1. Comparison of Technological characteristics
ITEMProposed Device K212346Predicate Device K182597Remark
ModelPG-IRT1612 and PG-IRT1618PG-IRT1602/
Product CodeFLLFLLSame
Regulation Number21 CFR 880.291021 CFR 880.2910Same
Indications for UsePG-IRT1612 & PG-IRT1618 Infrared
Forehead Thermometer is intended to
measure human body temperature by
measuring forehead.
The device can be used on people of all
ages at home or in hospital
environment.PG-IRT1602 Infrared Forehead
Thermometer is intended to measure
human body temperature by measuring
forehead.
The device can be used on people of all
ages.Similar
Principle of OperationThe proposed device uses a
temperature sensor, which can detect
the object temperature (OBJ) [human
body temperature], environment
temperature (NTC) and temperature of
sensor itself (AMB); these
temperatures are then transfer to
electronic signal and amplified; andThe proposed device uses a temperature
sensor, which can detect the object
temperature (OBJ) [human body
temperature], environment temperature
(NTC) and temperature of sensor itself
(AMB); these temperatures are then
transfer to electronic signal and
amplified; and then it is transferred toSame
Table 1 Comparison of Technology Characteristics of Infrared Forehead Thermometers
Features and characteristicsNon-contacting, Infrared Temperature MeasurementNon-contacting, Infrared Temperature MeasurementSame
Measurement SiteForeheadForeheadSame
Measurement MethodInfrared radiation detectionInfrared radiation detectionSame
Measurement Range$34.0°C ~43.0°C$
$(93.2 ~ 109.4 °F)$$34.0°C ~43.0°C$
$(93.2 ~ 109.4 °F)$Same
Accuracy$±0.2°C (0.4°F) at 35.0°C ~ 42.0°C$
$(95.0°F ~ 107.6 °F)$
$Others ±0.3°C (0.5 °F)$$±0.2°C (0.4°F) at 35.0°C ~ 42.0°C$
$(95.0°F ~ 107.6 °F)$
$Others ±0.3°C (0.5 °F)$Same
Display$0.1°C (0.1°F)$$0.1°C (0.1°F)$Same
Memory32 sets9 setsDifferent
Display typeLCDLCDSame
ActivationScan buttonScan buttonSame
Measurement distance3~5cm3~5cmSame
Sensor nameThermal Infrared Detectors 10TP583T
manufactured by Semitec Inshizuka
Electronics CorporationThermal Infrared Detectors 10TP583T
manufactured by Semitec Inshizuka
Electronics CorporationSame
Sensor typeThermopileThermopileSame
Scale Selection°C/°F°C/°F
Auto power-off while no operationYesYesSame
Response time1s1sSame
Operation environment$10.0°C ~ 40.0°C (50.0 ~ 104.0 °F)$
$15%~93% RH$$10.0°C ~ 40.0°C (50.0 ~ 104.0 °F)$
$15%~93% RH$Same
Storage environment$-25.0°C~+55.0°C (-13.0~+131.0°F)$
$0%~93% RH$$-25.0°C~+55.0°C (-13.0~+131.0°F)$
$0%~93% RH$Same
Service life5 years5 yearsSame
Power requirementsTwo pieces of 1.5V AAA batteriesTwo pieces of 1.5V AAA batteriesSame
SafetyComplied with IEC 60601-1Complied with IEC 60601-1Same
PerformanceComplied with ISO 80601-2-56Complied with ISO 80601-2-56Same
Complied with ASTM E1965-98Complied with ASTM E1965 -98Same
Patient-contact
MaterialsShell Material: ABS;
lens: PMMA;
Button: High density polyethylene
(HDPE);
Color additivesShell Material: ABS;
lens: PMMA;
Button: High density polyethylene
(HDPE);
Color additivesSame
BiocompatibilityComplied with ISO 10993-5Complied with ISO 10993-5Same
Complied with ISO 10993-10Complied with ISO 10993-10Same

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Table 2 Comparison of Technology Characteristics of Infrared Ear/Forehead Thermometers
ITEMProposed Device K212346Predicate Device K182597Remark
ModelPG-IRT1613 and PG-IRT1615PG-IRT1603/
Product CodeFLLFLLSame
Regulation Number21 CFR 880.291021 CFR 880.2910Same
Indications for UsePG-IRT1613 & PG-IRT1615 Infrared
Ear/Forehead Thermometer is intended
to measure human body temperature
by measuring ear canal or forehead.
The device can be used on people of
all ages at home or in hospital
environment.PG-IRT1603 Infrared Ear/Forehead
Thermometer is intended to measure
human body temperature by measuring
ear canal or forehead.
The device can be used on people of all
ages.Similar
Principle
of
OperationThe proposed device uses a
temperature sensor, which can detect
the object temperature (OBJ) [human
body temperature], environment
temperature (NTC) and temperature of
sensor itself (AMB); these
temperatures are then transfer to
electronic signal and amplified; and
then it is transferred to digital signal by
AD module in MCU of the proposed
device. MCU will calculate the body
temperature based on OBJ, NTC and
AMB, and then transfer to screen for
display.The proposed device uses a
temperature sensor, which can detect
the object temperature (OBJ) [human
body temperature], environment
temperature (NTC) and temperature of
sensor itself (AMB); these
temperatures are then transfer to
electronic signal and amplified; and
then it is transferred to digital signal by
AD module in MCU of the proposed
device. MCU will calculate the body
temperature based on OBJ, NTC and
AMB, and then transfer to screen for
display.Same
Features
and
characteristicsNon-contacting, Infrared Temperature
MeasurementNon-contacting, Infrared Temperature
MeasurementSame
Measurement SiteForehead and eardrumForehead and eardrumSame
MeasurementInfrared radiation detectionInfrared radiation detectionSame
Method
Measurement34.0°C~43.0°C
(93.2~109.4 °F)34.0°C~43.0°C
(93.2~109.4 °F)Same
Range±0.2°C (0.4°F) at 35.0°C ~ 42.0°C
(95.0°F~107.6 °F)
Others ±0.3°C (0.5 °F)±0.2°C (0.4°F) at 35.0°C ~ 42.0°C
(95.0°F~107.6 °F)
Others ±0.3°C (0.5 °F)Same
Accuracy0.1°C (0.1°F)0.1°C (0.1°F)Same
Display32 sets9 setsDifferent
MemoryLCDLCDSame
Display typeScan buttonScan buttonSame
ActivationContact (Ear)
1~5mm (Forehead)0~5mmDifferent
Measurement
distanceThermal Infrared Detectors 10TP583T
manufactured by Semitec Inshizuka
Electronics CorporationThermal Infrared Detectors 10TP583T
manufactured by Semitec Inshizuka
Electronics CorporationSame
Sensor nameThermopileThermopileSame
Sensor type°C/°F°C/°FSame
Scale SelectionYesYesSame
Auto power-off
while no operation1s1sSame
Response time10.0°C ~ 40.0°C (50.0 ~ 104.0 °F)
15%~93% RH10.0°C ~ 40.0°C (50.0 ~ 104.0 °F)
15%~93% RHSame
Operation
environment-25.0°C ~ +55.0°C (-13.0 ~ +131.0°F)
0%~93% RH-25.0°C ~ +55.0°C (-13.0 ~ +131.0°F)
0%~93% RHSame
Storage
environment5 years5 yearsSame
Service lifeTwo pieces of 1.5V AAA batteriesTwo pieces of 1.5V AAA batteriesSame
Power requirementsComplied with IEC 60601-1Complied with IEC 60601-1Same
SafetyComplied with IEC 60601-1-2Complied with IEC 60601-1-2Same
EMCComplied with ISO 80601-2-56
Complied with ASTM E1965-98Complied with ISO 80601-2-56
Complied with ASTM E1965 -98Same
PerformanceShell Material: ABS;
lens: PMMA;
Button: High density polyethylene (HDPE);
Color additivesShell Material: ABS;
lens: PMMA;
Button: High density polyethylene (HDPE);
Color additivesSame
Patient-contact
MaterialsComplied with ISO 10993-5Complied with ISO 10993-5Same
BiocompatibilityComplied with ISO 10993-10Complied with ISO 10993-10Same

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Similar - Indications for Use

The Indications for Use for the proposed device is not exactly the same as the predicate device. The

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Indication for Use for the proposed device includes the use environment, i.e. at home and hospital. The performance test environment condition complies with standards. It does not affect the measurement function of the proposed device. The different will not affect the safety and effectiveness of the proposed device.

Different - Memory

The memory function for the proposed device is different from the predicate device. The memory of the proposed device is 32 sets, while the memory of the predicate device is only 9 sets. The proposed device has more memory than the predicate device, which allows users to access more records to get a better grasp of recent body temperature. Software validation and verification test demonstrate the subject devices performance as intended. The difference does not affect the indications for use. In addition, the working principle and measurement methods and parameters of the proposed device are the same as those of the predicate device. Therefore, the different will not affect the safety and effectiveness of the proposed device.

Different - Measurement distance

The measurement distance for the proposed device is different from the predicate device. The forehead mode of the proposed device is non-contact measurement distance is 1~5mm, which can be covered by the predicate device. While the ear cavity mode for the proposed device is contact measurement. However, the biocompatibility test of the human contact part of the proposed device was performed and the results showed no adverse effect. In addition, the performance test and clinical test were performed on the proposed device and the test results demonstrate that the proposed device meets the requirements of ASTM E1965-98 (Reapproved 2016). Therefore, the different will not affect the safety and effectiveness of the proposed device.

    1. Non-Clinical Test Conclusion
      Non clinical tests were conducted to verify that the proposed device met all design specifications. The test performed on the proposed device include

Biocompatibility testing

The biocompatibility test for the proposed device was conducted in accordance with the FDA guidance "Use of International Standard ISO 10993-1. Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process". The biocompatibility testing items include cytotoxicity, Sensitization and Irritation test, the test result demonstrated that there was no adverse effect, thereby, it can be determined that the device can comply with the following standards:

  • A ISO 10993-5: 2009 Biological evaluation of medical devices - Part 5: Tests for in vitro cytotoxicity
  • A ISO 10993-10: 2010 Biological evaluation of medical devices - Part 10: Tests for irritation and skin sensitization

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Electrical safety and EMC

Electrical safety and EMC testing were conducted on the proposed device and the test result demonstrated that the device can operate normally and did not raise any performance degradation and safety issue, thereby, it can be determined that the device can comply with the following standards:

  • IEC 60601-1: 2005+CORR.1(2006)+CORR.2(2007)+AMI(2012) Medical electrical equipment-Part 1: general requirement for basic safety and essential performance

  • IEC 60601-1-2:2014 Medical Electrical Equipment- Part 1-2: General Requirements for Basic Safety And Essential Performance - Collateral Standard: Electromagnetic Compatibility-Requirements And Tests.

  • ISO 80601-2-56: 2017+A1: 2018 Medical Electrical Equipment- Part 1-2: Particular Requirements for Basic Safety And Essential Performance of Clinical thermometers for body temperature measurement

  • ▲ 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

The software verification and validation were conducted in accordance with the "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices," dated May 11, 2005. The test results demonstrated the software function met the requirements.

    1. Clinical Test Conclusion
      Controlled human clinical studies were conducted in accordance with ASTM E1965-98 (Reapproved 2016), clinical bias, clinical uncertainty and clinical repeatability have been evaluated per clinical validation for infrared thermometer. The clinical trial results verify that the clinical accuracy of the proposed device is not inferior to that of predicate device.

Total 120 subjects and three age groups, including age 01 (40 subjects), age 15 (40 subjects) and age above 5 (40 subjects) are included in each clinical study, including febrile persons. Compared statistical result of clinical bias and clinical repeatability of two comparison groups, the results of proposed device are not being inferior to that of predicate device. The result of proposed device was not inferior to that of predicate device, and the proposed device complies with ASTM E1965-98 (Reapproved 2016).

    1. Conclusion
      Based on the performance testing, comparison and analysis above, the proposed devices are substantially equivalent to the predicate device K182597.