K Number
K221040
Device Name
Electronic Sphygmomanometers, Model: X1, X2, X5, X6, X7,X8, X11)
Date Cleared
2022-08-31

(146 days)

Product Code
Regulation Number
870.1130
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
Electronic Sphygmomanometers is intended to measure the systolic blood pressure as well as the pulse rate of adult person and adolescents age 18 through 21 years of age .It can be used at medical facilities or at home.
Device Description
The Electronic Sphygmomanometers, including X1, X2, X5, X6, X7, X8, X11, is suitable for measurement of systolic blood pressure, diastolic blood pressure and the pulse rate of adult person and adolescents 18 to 21 years old with arm circumference ranging from 22 cm to 42 cm by the oscillometric technique. The error is controlled within the range specified in IEC 80601-2-30 Non-invasive automated monitor. User can select the blood pressure unit mmHg or kPa. The initial inflation pressure of the cuff is zero pressure. When start the device, the cuff will be inflated and deflated. The device consists of the microprocessor, pressure sensor, operation keys, pump, deflation control valve, LCD screen and cuff. And all models are powered by 4 AAA dry batteries (DC 6V). The device has a memory function that automatically stores 2*99 sets data of the latest measurements. It can also display the latest measurement result. Additionally, the device also can read the data through voice broadcast function. The seven models have the same intended use, working principle, measuring range, accuracy, cuff, and conformance standard; only appearance have some difference.
More Information

No
The description details a standard oscillometric blood pressure monitor with a microprocessor, pressure sensor, pump, valve, LCD, and memory. There is no mention of AI/ML algorithms for data analysis, interpretation, or prediction. The performance study is a comparative clinical study against predicate and mercury devices, not an AI/ML model validation.

No
The device is used for measurement and monitoring of blood pressure and pulse rate, not for treating a condition.

No

The device measures blood pressure and pulse rate, which are physiological parameters. While these measurements can be used by a healthcare professional to assist in diagnosis, the device itself simply provides data and does not interpret that data to identify a disease, condition, or state of health or to determine a prognosis.

No

The device description explicitly lists hardware components such as a microprocessor, pressure sensor, operation keys, pump, deflation control valve, LCD screen, and cuff. It also mentions being powered by batteries. This indicates it is a physical medical device with integrated software, not a software-only device.

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

Here's why:

  • IVD Definition: In Vitro Diagnostics are medical devices used to examine specimens taken from the human body, such as blood, urine, or tissue, to provide information for diagnosis, monitoring, or screening.
  • Device Function: The Electronic Sphygmomanometer measures blood pressure and pulse rate directly from the human body (specifically, the arm) using a cuff and oscillometric technique. It does not analyze samples taken from the body.
  • Intended Use: The intended use is to measure blood pressure and pulse rate, not to analyze biological samples for diagnostic purposes.

Therefore, this device falls under the category of a non-invasive medical device used for physiological measurement, not an In Vitro Diagnostic.

N/A

Intended Use / Indications for Use

Electronic Sphygmomanometers is intended to measure the systolic blood pressure as well as the pulse rate of adult person and adolescents age 18 through 21 years of age .It can be used at medical facilities or at home.

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

DXN

Device Description

The Electronic Sphygmomanometers, including X1, X2, X5, X6, X7, X8, X11, is suitable for measurement of systolic blood pressure, diastolic blood pressure and the pulse rate of adult person and adolescents 18 to 21 years old with arm circumference ranging from 22 cm to 42 cm by the oscillometric technique. The error is controlled within the range specified in IEC 80601-2-30 Non-invasive automated monitor. User can select the blood pressure unit mmHg or kPa. The initial inflation pressure of the cuff is zero pressure. When start the device, the cuff will be inflated and deflated.

The device consists of the microprocessor, pressure sensor, operation keys, pump, deflation control valve, LCD screen and cuff. And all models are powered by 4 AAA dry batteries (DC 6V).

The device has a memory function that automatically stores 2*99 sets data of the latest measurements. It can also display the latest measurement result. Additionally, the device also can read the data through voice broadcast function.

The seven models have the same intended use, working principle, measuring range, accuracy, cuff, and conformance standard; only appearance have some difference.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Arm

Indicated Patient Age Range

adult person and adolescents age 18 through 21 years of age

Intended User / Care Setting

It can be used at medical facilities or at home.

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 Study: Non-clinical tests were conducted to verify that the proposed device meets the same design specifications which supports the conclusion that it's Substantially Equivalent (SE) to the predicate device. The testing results demonstrate that the proposed device complies with the following standards: ANSI AAMI ES 60601-1, IEC 60601-1-2, IEC 60601-1-11, IEC 80601-2-30, ISO 81060-2.
Software: Software verification and validation test according to the requirements of the FDA "Guidance for Pre Market Submissions and for Software Contained in Medical Devices".
Biocompatibility Testing: The biocompatibility evaluating for the body-contacting component (arm cuff) of this device was conducted in accordance with the "Use of International Standard ISO 10933-1, Biological Evaluation of Medical Device – Part 1: Evaluation and Testing Within a Risk Management Process", as recongnized by FDA. The arm cuff has performed and passed the Biocompatibility test. The arm cuff complies with the following standards: ISO 10993-5, ISO 10993-10.
Clinical Study: A comparative clinical study was conducted to verify the performance of the proposed device and predicate device as well as a mercury sphygmomanometer according to ISO 81060-2. The study demonstrated a significant correlation in the performance of proposed device and predicate device.

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

Accuracy: Pressure: ± 3mmHg( ± 0.4kPa), or 2% of the reading Pulse Rate: ± 5%

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.

K191894

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.

K200649, K200939

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

§ 870.1130 Noninvasive blood pressure measurement system.

(a)
Identification. A noninvasive blood pressure measurement system is a device that provides a signal from which systolic, diastolic, mean, or any combination of the three pressures can be derived through the use of tranducers placed on the surface of the body.(b)
Classification. Class II (performance standards).

0

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.

August 31, 2022

Jiangxi AICARE Medical Technology Co., Ltd % Bing Huang Registration engineer Feiying Drug and Medical Consulting Technical Service Group Rm 2401 Zhenye International Business Center, No. 3101-90, Qianhai Road Shenzhen, Guangdong 518052 China

Re: K221040

Trade/Device Name: Electronic Sphygmomanometers, (Model: X1, X2, X5, X6, X7, X8, X11) Regulation Number: 21 CFR 870.1130 Regulation Name: Noninvasive Blood Pressure Measurement System Regulatory Class: Class II Product Code: DXN Dated: June 15, 2022 Received: June 22, 2022

Dear Bing Huang:

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.

1

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 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.

LCDR Stephen Browning Assistant Director Division of Cardiac Electrophysiology, Diagnostics and Monitoring Devices Office of Cardiovascular Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K221040

Device Name

Electronic Sphygmomanometers (Model: X1,X2,X5,X6,X7,X8,X11)

Indications for Use (Describe)

Electronic Sphygmomanometers is intended to measure the systolic blood pressure as well as the pulse rate of adult person and adolescents age 18 through 21 years of age .It can be used at medical facilities or at home.

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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3

510 (k) Summary

This summary of 510(k) safety and effectiveness information is submitted in accordance with requirements of Title 21, CFR Section 807.92.

1) Applicant information:

510(k) owner's name:Jiangxi AICARE Medical Technology Co., Ltd.
Address:No.6, South Side of Nanhuan Road Qianping Industrial Park, Le'an
County, Fuzhou City, 344300 Jiangxi Province, China
Contact person:Lizhu Xiao
Phone number:+86 794 6577516
Fax number:+86 794 6577516
Email:xiaolizhu@spt-tek.com
Date of summary prepared:August 4, 2022

2) Proprietary name of the device

| Trade name/model: | Electronic Sphygmomanometers
/X1, X2, X5, X6, X7, X8, X11 |
|--------------------|--------------------------------------------------------------|
| Common name: | Noninvasive blood pressure measurement system |
| Regulation number: | 21 CFR 870.1130 |
| Product code: | DXN |
| Review panel: | Cardiovascular |
| Regulation class: | Class II |

3) Predicate and reference device

> Predicate device

SponsorShenZhen ZhengKang Technology Co., Ltd
Device Name and ModelUpper Arm Blood Pressure Monitor Model: ZK-B868, ZK-B869, ZK-B872, ZK-B876
510(k) NumberK191894
Product CodeDXN
Regulation Number21CFR870.1130.
Regulation ClassII

> Reference device

SponsorJOYTECH Healthcare Co., LtdJiangsuYuyueMecical
Equipment& Supply Co., Ltd
Device Name and ModelArm-typeFullyAutomaticElectronicBloodPressure
Digital Blood Pressure MonitorMonitor : YE620B, YE620D,

4

Model:
DBP-1305b,
DBP-1319b,
DBP-1333b,
DBP-1257b,
DBP-1359bDBP-1307b,
DBP-1318b,
DBP-1332b,
DBP-1307b,
DBP-1358bYE660E, YE660F and YE680B
510(k) NumberK200649K200939
Product CodeDXNDXN
Regulation Number21CFR870.113021CFR870.1130
Regulation ClassIIII

4) Description/ Design of device:

The Electronic Sphygmomanometers, including X1, X2, X5, X6, X7, X8, X11, is suitable for measurement of systolic blood pressure, diastolic blood pressure and the pulse rate of adult person and adolescents 18 to 21 years old with arm circumference ranging from 22 cm to 42 cm by the oscillometric technique. The error is controlled within the range specified in IEC 80601-2-30 Non-invasive automated monitor. User can select the blood pressure unit mmHg or kPa. The initial inflation pressure of the cuff is zero pressure. When start the device, the cuff will be inflated and deflated.

The device consists of the microprocessor, pressure sensor, operation keys, pump, deflation control valve, LCD screen and cuff. And all models are powered by 4 AAA dry batteries (DC 6V).

The device has a memory function that automatically stores 2*99 sets data of the latest measurements. It can also display the latest measurement result. Additionally, the device also can read the data through voice broadcast function.

The seven models have the same intended use, working principle, measuring range, accuracy, cuff, and conformance standard; only appearance have some difference.

| Component

nameMaterial of ComponentBody Contact CategoryContact Duration
CuffNylon polyesterSurface skin contactLess than 24 hours

Materials

We have directly purchased cuff from qualified supplier which has obtained Biocompatibility test reports. For details, please refer to "Biocompatibility Discussion".

5) Intended use / indications:

Electronic Sphygmomanometers is intended to measure the systolic and diastolic blood pressure as well as the pulse rate of adult person and adolescents age 18 through 21 years of age .It can be used at medical facilities or at home.

6) Technological characteristics and substantial equivalence:

5

ItemProposed devicePredicate deviceReference device1Reference device2Remark
Trade nameElectronic
Sphygmomanomete
rs
(Model:X1,X2,X5,
X6,X7,X8,X11)Upper Arm Blood
Pressure Monitor
(Model:ZK-B868,
ZK-B869,
ZK-B872,
ZK-B876)Arm-type
Fully
Automatic
Digital
Blood
Pressure
Monitor
(Model:
DBP-1307b,
DBP-1305b,
DBP-1318b,
DBP-1319b,
DBP-1332b,
DBP-1333b,
DBP-1307b,
DBP-1257b,
DBP-1358b,
DBP-1359b)Electronic
Blood /
Pressure Monitor :
YE620B, YE620D,
YE660E, YE660F
andYE680B/
510
(k)
numberK221040K191894K200649K200939/
Manufactur
erJiangxi AICARE
Medical
Technology
Co.,
Ltd.ShenZhen
ZhengKang
Technology
Co.,
Ltd.JOYTECH
Healthcare
Co.,
Ltd.Jiangsu Yuyue
Medical
Equipment&
Supply Co., Ltd/
Regulation
number21 CFR 870.113021 CFR 870.113021 CFR 870.113021 CFR 870.1130Same
Regulation
descriptionNoninvasive blood
pressure
measurement
systemNoninvasive blood
pressure
measurement
systemNoninvasive blood
pressure
measurement
systemNoninvasive blood
pressure
measurement
systemSame
Product
codeDXNDXNDXNDXNSame
ClassIIIIIIIISame
Indications
for use/
Intended
useElectronic
Sphygmomanomete
rs is intended to
measure the
systolic and
diastolic blood
pressure as well as
the pulse rate of
adult person and
adolescents age 18
through 21 years of
age .It can be used
at medical facilities
or at home.This Upper Arm
Blood Pressure
Monitor is intended
to measure the
systolic and
diastolic blood
pressure as well as
the pulse rate of
adult person. It can
be used at medical
facilities or at
home.The Full Automatic
Blood Pressure
Monitors are
intended to
measure blood
pressure (systolic
and diastolic) and
pulse rate of adults
and adolescents age
12 through 21 years
of age.Electronic blood
pressure monitor is
intended to
measure the blood
pressure and pulse
rate adult in
household or
medical facilities.
(Not suitable for
neonate, pregnancy
or pre-eclampsia)Similar
Note 1
Patient
populationAdult and 18
through 21 years of
ageAdultAdult and 12
through 21 years of
ageAdultSimilar
Note 1
Location
for useOTCOTCOTCOTCSame
Environme
nt of useMedical facilities
or homeMedical facilities
or home/household or
medical facilitiesSame
Operation
principleOscillometricOscillometricOscillometricOscillometricSame
Measureme
nt ranePressure: 0 ~
295mmHg, Pulse
Rate:
(40 ~ 160) times
per minutePressure: 0 ~
295mmHg Pulse
Rate: 40~195
bpmSystolic
Pressure:60mmHg
~280 mmHg
Diastolic Pressure:
30 mmHg ~ 200
mmHg
Pulse:30 ~ 180
Beats/MinutePressure:0 ~ 300
mmHg
Pules:40 ~
200beats/minSimilar
AccuracyPressure:
$\pm$ 3mmHg( $\pm$
0.4kPa), or 2% of
the reading
Pulse Rate: $\pm$ 5%Pressure:
$\pm$ 3mmHg( $\pm$
0.4kPa)
Pulse Rate: $\pm$ 5%Static Pressure:
$\pm$ 3mmHg
Pulse: $\pm$ 5%Pressure:
$\pm$ 3mmHg( $\pm$
0.4kPa)
Pulse Rate: $\pm$ 5% of
reading valueSame
Display
screenLCDLCDLCDLCDSame
Scale
selectionmmHg/kPammHg/kPammHgmmHg/kPaSame
Cuff
circumference22cm-42cm22cm-32cm22-36cmTypeSimilar
Note 2
Type A(22cm-32cm,
22cm-45cm
optional)
Type B
A(22cm-32cm,
22cm-45cm
optional)
Memory2*99sets2*99 sets/Up to 99x2 sets of
dataSame
Power
supplyBattery:4AAA
batteries(DC 6V)
or optional
adapt
er with
USB
cable(DV5V/500
m A)Battery:4AA
batteries
(DC6V)-(ZK-B868
)
4AAA batteries
(DC6V)-(ZK-869/Z
K-872/ZK-B876)
or optional adapter
with
USB
cable(DV5V/500m
A)For models
DBP-1318b,
DBP-1257b,
DBP-1358b,DBP-1
359b:4×1.5V AAA
battery or Medical
AC adapter (DC
6V,600mA)(recom
mended, not
Provided); For
other models:4 ×
1.5V AA battery or
Medical AC
adapter (DC
6V,600mA)(recom
mended4 AA batteries or
6V/600mA AC
adaterSame
Operating
EnvironmentTemperature:+5 ℃
~+40 ℃;
Humidity:15
~ 90%RH
Atmospheric
pressure: 70 kpa ~
106 kpaTemperature:+5 ℃
~+40 ℃;
Humidity:15
80%RHTemp.: +10 ℃~
+40 ℃
Humidity:15 ~
93%RH
Atmospheric:700hPa
a~1060hPaTemperature:+5 ℃
~+40 ℃;
Humidity:15
90%RHSimilar
Storage
EnvironmentTemperature:-25 ℃
~+55 ℃;
Humidity:10
~ 95%RHTemperature:-20 ℃
~+55 ℃;
Humidity:10
93%RHTemp.: -25 ℃ ~
+55 ℃
Humidity:
90%RHTemperature:-20 ℃
~+55 ℃;
Humidity:15
90% RH(no
condensation)Similar
Type of
transmissionNon-transmissionNon-transmissionBluetooth/Same
Compliance
withANSI AAMI
ESIEC 60601-1;
IEC 60601-1-2;AAMI/ANSI
60601-1IEC 60601-1;
IEC60601-1-2;Same
60601-1;
voluntary
standardsIEC 60601-1-2;
IEC 60601-1-11;
IEC 80601-2-30;
ISO 10993-1,-5,10;
ISO 81060-2IEC 60601-1-11;
IEC 80601-2-30;
ISO 10993-1,-5,10;
ISO 81060-2IEC 80601-2-30:2009
IEC 60601-1-11
IEC 60601-1-2
EN 300328
EISI EN 301489-1
EISI EN 301489-17IEC60601-1-6;
IEC60601-1-11;
ANSI AAM
IEC80601-2-30;
ISO 81060-2

6

7

8

Comparison in details:

Note 1: Although the patient population is a little different between the proposed and predicate device, but it's within the scope of Reference device 1, the difference is insignificant and do not affect safety and effectiveness. And the proposed device has been validated to be in conformity with its claimed range.

Note 2: Although the Cuff circumference is a little different between the proposed and predicate device, but it's within the scope of Reference device 2, the difference is insignificant and do not affect safety and effectiveness. And the proposed device has been validated to be in conformity with its claimed range

Conclusion:

Electronic Sphygmomanometers is substantially equivalent to the predicate device.

7) Test summary:

The following performance data is provided in support of the substantial equivalence determination.

Non-Clinical Study:

Non-clinical tests were conducted to verify that the proposed device meets the same design specifications which supports the conclusion that it's Substantially Equivalent (SE) to the predicate device.. The testing results demonstrate that the proposed device complies with the following standards:

Electrical and EMC Safety:

The electrical safety and EMC safety testing was performed as per the following standards and passed:

  • . ANSI AAMI ES 60601-1, Medical electrical equipment -- Part 1: General requirements for basic safety and essential performance
  • . IEC 60601-1-2, Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral standard: Electromagnetic disturbances - Requirements and tests
  • . IEC 60601-1-11, Medical electrical equipment -- Part 1-11: General requirements Page 6 of 8

9

for basic safety and essential performance -- Collateral standard: Requirements for medical electrical equipment and medical electrical systems used in the home healthcare environment

Performance Data:

The performance testing was performed as per the following standards and passed:

  • . IEC 80601-2-30, Medical electrical equipment - Part 2-30: Particular requirements for the basic safety and essential performance of automated noninvasive sphygmomanometers
  • . ISO 81060-2, Non-invasive sphygmomanometers - Part 2: clinical validation of automated measurement type [Including: Amendment 1(2020)]
  • FDA Guidance No-Invasive Blood Pressure (NIBP) Monitor Guidance .

Software:

We have also conducted Software verification and validation test according to the requirements of the FDA "Guidance for Pre Market Submissions and for Software Contained in Medical Devices".

Biocompatibility Testing:

The biocompatibility evaluating for the body-contacting component (arm cuff) of this device was conducted in accordance with the "Use of International Standard ISO 10933-1, Biological Evaluation of Medical Device – Part 1: Evaluation and Testing Within a Risk Management Process", as recongnized by FDA. The arm cuff has performed and passed the Biocompatibility test. So we have reason to believe that the arm cuff is safe for the users. The arm cuff complies with the following standards:

  • . ISO 10993-5, Biological Evaluation of Medical Devices - Part 5: Tests for InVitro Cytotoxicity
  • . ISO 10993-10, Biological Evaluation of Medical Devices - Part 10: Tests for Irritation and Skin Sensitization.

Clinical Study:

We conducted a comparative clinical study to verify the performance of the proposed device and predicate device as well as a mercury sphygmomanometer according to ISO 81060-2. The study demonstrated a significant correlation in the performance of proposed device and predicate device. The design of the proposed device specifications is substantially the same as the predicate.

All the labeling and characteristics of the Electronic Sphygmomanometers are the same as the predicate device, and most normal blood pressure monitors currently on the market. The proposed device and predicate device both use similar measuring methodologies and components to achieve the measurements.

10

8) Conclusion

Based on the above analysis and non-clinical/clinical tests performed, it can be concluded that the proposed device Electronic Sphygmomanometers is as safe, as effective, and performs as well as the legally marketed predicate device, K191894, Upper Arm Blood Pressure Monitor Model: ZK-B868, ZK-B869, ZK-B872, ZK-B876.