K Number
K221798
Date Cleared
2023-05-04

(317 days)

Product Code
Regulation Number
870.2700
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Fingertip Pulse Oximeter are intended for measuring function of arterial hemoglobin (SpO2) and pulse rate for both adults and adolescent as not checking in home and professional caring environment. It is designed for fingers between 7mm and 25.4mm in diameter (0.28 inches to 1.0inches). And it is not intended to be used under motion or low perfusion scenarios.

Device Description

The Fingertip Pulse Oximeter X1609P is a fingertip device, which can measure the arterial SpO2 and pulse rate value and can display the results to the user. Moreover, the X1609P also has the function of low battery voltage indicate and automatically power off. The power source is 2xAAA batteries. Fingertip Pulse Oximeter X1609P is small in volume, light in weight and convenient in carrying. It is composed of light signal driving circuit, preamplification circuit, low pass filtering circuit, DC bias circuit, gain control circuit, display control circuit, and main control circuit. The device is for prescription. It is neither for life-supporting nor for implanting. It does not contain any drug or biological product and it does not need to be sterile.

AI/ML Overview

Here's an analysis of the provided FDA 510(k) summary for the Finger Pulse Oximeter, Model: X1906P, organized to address your specific points about acceptance criteria and study proof.

It's important to note that this document is a summary for a 510(k) submission, and therefore provides high-level information. Full details of the protocols, raw data, and statistical analyses would be found in the complete submission documents, which are not provided here.


Acceptance Criteria and Device Performance

The core of the performance evaluation for a pulse oximeter revolves around its accuracy in measuring oxygen saturation (SpO2) and pulse rate (PR). The key standard referenced is ISO 80601-2-61: 2017 Medical electrical equipment — Part 2-61: Particular requirements for basic safety and essential performance of Fingertip Pulse Oximeter Equipment. The acceptance criteria are typically derived from this standard.

1. Table of Acceptance Criteria and Reported Device Performance:

ParameterAcceptance Criteria (from ISO 80601-2-61)Reported Device Performance (Model: X1906P)
SpO2 Accuracy70% to 99% range: $\pm$ 2% ARMS (as per ISO 80601-2-61)"The measure result between the SpO2 measured by subject device and the SaO2 measured by the blood gas analyzer... were conformed with the requirements of this clinical trial and related standards." (Implicitly meets $\pm$ 2% within 70-99% range as per standard)
Pulse Rate AccuracyAs per ISO 80601-2-61, Clause 201.12.1.104 (typically $\pm$ 3 bpm or $\pm$ 2% for specific ranges)"Pulse Rate Accuracy meets the requirements defined in ISO 80601-2-61, Clause 201.12.1.104." (Implicitly meets the standard's criteria)

Note on Acceptance Criteria Interpretation: The document states that "Bench testing was conducted, and the results show that the subject device complies with the ISO 80601-2-61: 2017... standard. And Pulse Rate Accuracy meets the requirements defined in ISO 80601-2-61, Clause 201.12.1.104." This implies the acceptance criteria were the specific performance requirements outlined in that ISO standard for accuracy, which is typically Average Root Mean Square (ARMS) difference for SpO2. The specific numerical ARMS values are not explicitly stated for the device's performance, but rather that it "conformed with the requirements."


Study Details

2. Sample Size Used for the Test Set and Data Provenance:

  • Sample Size: 13 adult volunteers.
    • Breakdown: 5 males, 8 females.
    • Fitzpatrick skin types included: 3 subjects with Fitzpatrick VI, 3 subjects with Fitzpatrick II, and 7 subjects with Fitzpatrick IV. This inclusion of diverse skin tones is crucial for pulse oximetry accuracy.
  • Data Provenance: The document does not explicitly state the country of origin for the clinical study. Given the manufacturer (Shenzhen Changkun Technology Co., Ltd. from China) and consultant (Shenzhen Reanny Medical Devices Management Consulting Co., Ltd. from China), it is highly probable the study was conducted in China.
  • Retrospective or Prospective: The study description "Clinical studies were conducted to verify the accuracy of proposed device" and "There were 13 adult volunteers to validated the accuracy of finger pulse oximeter" indicates a prospective clinical study.

3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:

The document does not mention the use of experts to establish ground truth in the traditional sense of image adjudication or clinical interpretation, as this is a pulse oximeter accuracy study. The "ground truth" for SpO2 and pulse rate is established through direct, highly accurate physiological measurements:

  • SpO2 Ground Truth: Measured by a blood gas analyzer (SaO2).
  • Pulse Rate Ground Truth: Measured by a patient monitor (HR).

These are considered gold standards for these physiological parameters. Therefore, the concept of "experts establishing ground truth" as it applies to subjective interpretation (like radiology reads) is not directly applicable here. The expertise lies in the certified laboratory/clinical personnel performing the blood gas analysis and operating the patient monitor, ensuring proper calibration and technique. Specific qualifications of these operators are not detailed but are assumed to be standard for clinical laboratory and patient monitoring practices.

4. Adjudication Method for the Test Set:

Not applicable in the context of this study. This study directly compares the device's numerical output against gold-standard physiological measurements (blood gas analyzer for SaO2, patient monitor for HR). There is no "adjudication" of the device's readings by human experts in the sense of consensus reading or interpretation.

5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done:

No, an MRMC comparative effectiveness study was not done. This type of study is more common for diagnostic imaging devices where human readers interpret medical images with and without AI assistance. For a pulse oximeter, the study design is centered on direct numerical accuracy against a gold standard, not human reader performance.

6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Study was done:

Yes, the clinical accuracy study described for the pulse oximeter is effectively a standalone study. The device's measurement (SpO2 and PR) is directly compared to the reference measurement (blood gas analyzer and patient monitor) without an explicit "human-in-the-loop" component influencing the device's output or the ground truth measurement. The user of the oximeter reads the displayed value, but the study validates the intrinsic accuracy of the measurement.

7. The Type of Ground Truth Used:

  • SpO2 Ground Truth: Physiological measurement via arterial blood gas analysis (SaO2). This is considered a gold standard for true arterial oxygen saturation.
  • Pulse Rate Ground Truth: Physiological measurement via a patient monitor (HR). This is also considered a gold standard for heart rate.

8. The Sample Size for the Training Set:

The document does not provide information on a training set size. For a traditional medical device like a pulse oximeter, "training set" is usually not a relevant concept in the same way it is for AI/ML algorithms. The device's underlying principles (Lambert Beer Law, photo-plethysmography) are based on established physics and physiology, not on learning from a dataset. Any internal calibration or algorithm refinement would be part of the engineering design process, not typically referred to as a "training set" in the context of FDA submissions for such devices.

9. How the Ground Truth for the Training Set was Established:

As there is no mention of a "training set" in the context of AI/ML, this question is not applicable. The device's design and calibration are based on established scientific principles and engineering practices, not on a machine learning training dataset. The clinical study validates the final, produced device's performance against established physiological ground truth.

{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.

Mav 4, 2023

Shenzhen Changkun Technology Co., Ltd. % Reanny Wang General Manager Shenzhen Reanny Medical Devices Management Consulting.. Ltd Room 1407, Jingting Building, Dongzhou Community, Guangming Street, Guangming District Shenzhen, Guangdong 518000 China

Re: K221798

Trade/Device Name: Finger Pulse Oximeter, Model: X1906P Regulation Number: 21 CFR 870.2700 Regulation Name: Oximeter Regulatory Class: Class II Product Code: DQA Dated: May 4, 2023 Received: May 4, 2023

Dear Reanny Wang:

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 and Part 809); 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.

James J. Lee -S

James J. Lee, Ph.D. Director DHT1C: Division of 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) K221798

Device Name Finger Pulse Oximeter, Model: X1906P

Indications for Use (Describe)

The Fingertip Pulse Oximeter are intended for measuring function of arterial hemoglobin (SpO2) and pulse rate for both adults and adolescent as not checking in home and professional caring environment. It is designed for fingers between 7mm and 25.4mm in diameter (0.28 inches to 1.0inches). And it is not intended to be used under motion or low perfusion scenarios.

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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

{3}------------------------------------------------

510(k) Summary

This summary of 510(K) safety and effectiveness information is being submitted in accordance with the requirements of SMDA and 21 CFR §807.92.

The assigned 510(k) number is:_____K221798

1.0 Information of Submitter and Correspondent

Submitter's information:

Company Name: Shenzhen Changkun Technology Co. Ltd.

Address: Room 501, Changkun Technology Building A, 12 Shijia Road, Biling Community, Biling Subdistrict, Pingshan District, Shenzhen City, Guangdong Province, 518118, P.R. China

Telephone: +86(755)-29100487 Contact Person: Wang Qingpeng General Manager Contact Title:

Contact Email: 757168025@qq.com

Submission correspondent's information:

Company Name: Shenzhen Reanny Medical Devices Management Consulting Co., Ltd

Address: Room 1407, Jingting Building, Dongzhou Community, Guangming Street,

Guangming District, Shenzhen, Guangdong Province, China

Contact person: Reanny Wang

E-Mail: Reanny@reanny.com

2.0 Device Information

Type of 510(k) submission:Traditional
Trade Name:Fingertip Pulse Oximeter
Model:X1906P
Classification name:Oximeter
Review Panel:Anesthesiology
Product Code:DQA
Device Class:Class II
Regulation Number:870.2700

{4}------------------------------------------------

3.0 Predicate Device Information

Sponsor:Beijing Choice Electronic Technology Co., Ltd.
Device:Fingertip Pulse Oximeter
510(K) Number:K160268

4.0 Intended Use

The Fingertip Pulse Oximeter are intended for measuring functional oxygen saturation of arterial hemoglobin (SpO2) and pulse rate for both adults and adolescent as non-invasive spot checking in home and professional caring environment. It is designed for fingers between 7mm and 25.4mm in diameter (0.28 inches to 1.0inches). And it is not intended to be used under motion or low perfusion scenarios.

5.0 Product introduction

The Fingertip Pulse Oximeter X1609P is a fingertip device, which can measure the arterial SpO2 and pulse rate value and can display the results to the user.

Moreover, the X1609P also has the function of low battery voltage indicate and automatically power off. The power source is 2xAAA batteries. Fingertip Pulse Oximeter X1609P is small in volume, light in weight and convenient in carrying. It is composed of light signal driving circuit, preamplification circuit, low pass filtering circuit, DC bias circuit, gain control circuit, display control circuit, and main control circuit.

The device is for prescription. It is neither for life-supporting nor for implanting. It does not contain any drug or biological product and it does not need to be sterile.

The intended use, design principle, operation principle, functions, material and the applicable standards of X1609P Fingertip Pulse Oximeter are the same as the predicated device MD300CG51 Fingertip Pulse Oximeter (K160268) manufactured by Beijing Choice Electronic Technology Co., Ltd.

6.0 Summary comparing technological characteristics with predicate device

{5}------------------------------------------------

Technological CharacteristicsComparison result
Indications for useSame
Design principleSame
AppearanceSimilar
Patients contact materialsSame
PerformanceSimilar
BiocompatibilitySame
Mechanical and Electrical safetySame
Standards metSame
EMCSame
FunctionSimilar

7.0 Performance Summary

Performance data includes "Non-Clinical Data", brief description of which are shown as below.

Non-Clinical Testing:

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

Biocompatibility testing

The biocompatibility evaluation for the Fingertip Pulse Oximeter was conducted in accordance with the International Standard ISO 10993-1 "Biological Evaluation of Medical Devices - Part 1: Evaluation and Testing within a Risk Management Process," as recognized by FDA. The testing included the following tests, results of which demonstrate the biocompatibility of the subject device:

  • Cytotoxicity
  • Skin Sensitization
  • Skin Irritation

Electrical safety, Home Healthcare environment and electromagnetic compatibility (EMC)

Electrical safety, Home Healthcare environment and EMC testing were conducted, and the results show that the subject device complies with the IEC 60601-1: 2005+CORR. 1 (2006)+CORR. 2 (2007)+A1: 2012 Medical electrical equipment Part 1: General requirements for basic safety and essential performance, IEC 60601-1-11: 2015 Medical

{6}------------------------------------------------

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 and the 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.

Bench Testing

Bench testing was conducted, and the results show that the subject device complies with the ISO 80601-2-61: 2017 Medical electrical equipment — Part 2-61: Particular requirements for basic safety and essential performance of Fingertip Pulse Oximeter Equipment standard. And Pulse Rate Accuracy meets the requirements defined in ISO 80601-2-61, Clause 201.12.1.104.

Software Verification and Validation Testing

Software documentation including verification & validation was provided in accordance with FDA Guidance: Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices for software with a moderate level of concern.

The above tests were selected to show substantial equivalence between the subject device and the predicate device.

Clinical test:

Clinical studies were conducted to verify the accuracy of proposed device. The clinical studies were conducted per following standards:

  • ISO 80601-2-61: 2017 Medical Electrical Equipment Part 2-61: Particular Requirements for Basic Safety and Essential Performance of Pulse Oximeter Equipment.
  • · Pulse Oximeters-Premarket Notification Submissions: Guidance for Industry and Food and Drug Administration Staff.

There were 13 adult volunteers to validated the accuracy of finger pulse oximeter (Model: X1906P). 5 males and 8 females (including 3 subjects with Fitzpatrick VI, 3 subjects with Fitzpatrick II and 7 with Fitzpatrick IV). The measure result between the SpO2 measured by subject device and the SaO2 measured by the blood gas analyzer, the measure result between the PR measured by subject device and the HR measured by the patient monitor

{7}------------------------------------------------

were conformed with the requirements of this clinical trial and related standards. The pulse oximeter had not been found any safety issues, adverse effects and complications during the clinical trial.

8.0 Comparison to predicate device

The subject device X1906P Fingertip Pulse Oximeter is substantially equivalent to MD300CG51 Fingertip Pulse Oximeter whose 510(k) number is K160268.

Elements ofComparisonSubject DevicePredicate DeviceJudgment
CompanyShenzhen ChangkunTechnology Co. Ltd.Beijing Choice ElectronicTechnology Co., Ltd.--
Device NameFingertip Pulse OximeterFingertip Pulse Oximeter--
ModelX1906PMD300CG51--
510(k) NumberPendingK160268--
Product codeDQADQASame
Intended patientpopulationAdult and ChildrenAdult, adolescent, childand infant patientSame,within therange ofpredicatedevice
Intendedapplication siteFingerFingerSame
Intended useThe Fingertip PulseOximeter are intended formeasuring functionaloxygen saturation ofarterial hemoglobin (SpO2)and pulse rate for bothadults and adolescent asnon-invasive spot checkingin home and professionalcaring environment. It isdesigned for fingersbetween 7mm and 25.4mmThe Fingertip PulseOximeter MD300CG11/D300CG51 is a portable,non-invasive deviceintended for spot checkingof oxygen saturation ofarterial hemoglobin (SpO2)and pulse rate of adult,adolescent, child and infantpatient with the fingersbetween 0.9 - 2.2 m (0.4 -0.9 inch) thick in hospital.Same, thedescriptionisdifferenceand thefinger thickrange havebeenevaluatedin clinicaltrialaccording
Elements ofComparisonSubject DevicePredicate DeviceJudgment
in diameter (0.28 inches to1.0inches). And it is notintended to be used undermotion or low perfusionscenarios.to ISO80601-2-61.
Presentation orOTCPresentationPresentationSame
Measurementrange of SPO20~99%0~99%Same
Accuracy of SPO270% to 99% range $\pm$ 2%;less than 70% areunspecified70%-99%, $\pm$ 2%;Less than 70% nodefinitionSame
Resolution ofSPO21%1%Same
Transducer ofSPO2Dual-wavelength LEDsensorDual-wavelength LEDsensorSame
Measurementwavelength ofSPO2Red light:660nm,Infrared light: 940nmRed light: 660nm,Infrared light: 940nmSame
Measurementrange of pulse rate30-250bpm30-235bpmSimilar
Accuracy of pulserate$\pm$ 3bpm30-99bpm, $\pm$ 2bpm; 100-235bpm, $\pm$ 2%Similar
Resolution ofpulse rate1 bpm1 bpmSame
Pulse intensity ofpulse rateBar graph indicatorBar graph indicatorSame
Design principleA mathematical formula is established making use ofLambert Beer Law according to Spectrum AbsorptionCharacteristics of Reductive hemoglobin(RHb) andOxyhemoglobin (HbO2) in glow and near-infrared zones.Operation principle of the instrument: PhotoelectricSame
Elements ofComparisonSubject DevicePredicate DeviceJudgment
Oxyhemoglobin Inspection Technology is adopted inaccordance with Capacity Pulse Scanning andRecording Technology, so that two beams of differentwavelength of lightscan be focused onto a human nail tipthrough a clamping finger-type sensor. A measuredsignal obtained by a photosensitive element, will beshown on the Oximeter's display through process inelectronic circuits and microprocessor shown on theOximeter's display through electronic circuits and amicroprocessor.
Power sourceInternal poweredequipmentDC3V, 2 x AAA batteriesInternal poweredequipment1 AAA-size alkaline batterySame
Dimensions60mm×35mm×37mmUnknown/
WeightAbout 56g (including 2AAA alkaline batteries)Unknown/
ClassificationInternally poweredequipment, type BFapplied partInternally poweredequipment, type BFapplied partSame
Grade ofwaterproofIP22IPX2Same
Material of pulseoximeterABS and silicone rubberABS and Silicone gelSame
PerformanceCompliance with ISO80601-2-61Compliance with ISO80601-2-61Same
BiocompatibilityAll the patient contactingmaterials are compliancewith ISO 10993-1/-5/-10All the patient contactingmaterials are compliancewith ISO 10993-1/-5/-10Same
Electrical SafetyCompliance with IEC60601-1Compliance with IEC60601-1Same
Safety of homehealthcareCompliance with IEC60601-1-11Compliance with IEC60601-1-11Same
Elements ofComparisonSubject DevicePredicate DeviceJudgment
environment
EMCCompliance with IEC60601-1-2Compliance with IEC60601-1-2Same

{8}------------------------------------------------

{9}------------------------------------------------

{10}------------------------------------------------

As seen in the comparison tables, the subject and predicate devices have same design principle, similar design features and performance specifications. The different technological characteristics between the subject and predicate devices will not raise different questions of safety or effectiveness

9. Conclusion

The Fingertip Pulse Oximeter is monitoring the patient's SpO2 and pulse rate in non-invasive, timely and convenient. Non-clinical testing and clinical testing were conducted on the subject device and all testing passed pre-specified criteria. The risks of Finger Pulse Oximeter also have been evaluated according to ISO 14971, the overall residual risk and side effect are acceptable, the benefit is greater than risk and hazard. Which demonstrate that the subject device is as safe, as effective, and performs as well as the legally marketed device predicate. The subject device is substantially equivalent to the predicate device.

10. Summary prepared date

May 4, 2023

§ 870.2700 Oximeter.

(a)
Identification. An oximeter is a device used to transmit radiation at a known wavelength(s) through blood and to measure the blood oxygen saturation based on the amount of reflected or scattered radiation. It may be used alone or in conjunction with a fiberoptic oximeter catheter.(b)
Classification. Class II (performance standards).