K Number
K221857
Device Name
Aneroid sphygmomanometer with stethoscope, QL-50, Aneroid sphygmomanometer, QL-20, Aneroid sphygmomanometer, QL-201
Date Cleared
2022-10-13

(108 days)

Product Code
Regulation Number
870.1120
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The device is intended to be used by medical professionals or in the home for the measurement of systolic and diastolic pressure. The device is intended to be manually attached to a patient and manually inflated along with a manual method for detecting Korotkoff sounds. This product can measure the blood pressure of people aged 3 years and above.
Device Description
Aneroid sphygmomanometer Model QL-20, QL-201/ Aneroid sphygmomanometer with stethoscope, Model QL-50 are a manual non-invasive aneroid sphygmomanometer which respectively uses an inflation cuff wrapped around the upper arm. The cuff is inflated and deflated by a manual inflation bulb. Besides a manometer (Aneroid gauge), the accessories include cuff, inflation bulb, instruction manual and carrying case. Model OL-50 also includes a stethoscope. It is conjunction with stethoscope when use.
More Information

Not Found

No
The device description explicitly states it is a manual, non-invasive aneroid sphygmomanometer using a manual inflation bulb and manual detection of Korotkoff sounds. There is no mention of AI or ML in the description, intended use, or performance studies.

No.
The device is used for measurement (diagnosis) of blood pressure, not for therapy or treatment.

Yes

An aneroid sphygmomanometer measures systolic and diastolic pressure, which are vital signs used by medical professionals to assess a patient's health and diagnose conditions like hypertension.

No

The device description explicitly details physical components like an inflation cuff, manual inflation bulb, manometer (Aneroid gauge), and potentially a stethoscope, indicating it is a hardware-based medical device.

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

Here's why:

  • Intended Use: The intended use is to measure systolic and diastolic blood pressure. This is a physiological measurement taken directly from the patient's body.
  • Device Description: The device is a manual non-invasive aneroid sphygmomanometer. It works by physically interacting with the patient's arm to measure pressure.
  • IVD Definition: In vitro diagnostics (IVDs) are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections. This device does not analyze samples from the body.

The device is a medical device used for a physiological measurement, not an in vitro diagnostic test.

N/A

Intended Use / Indications for Use

The device is intended to be used by medical professionals or in the home for the measurement of systolic and diastolic pressure. The device is intended to be manually attached to a patient and manually inflated along with a manual method for detecting Korotkoff sounds. This product can measure the blood pressure of people aged 3 years and above.

Product codes

DXQ, LDE

Device Description

Aneroid sphygmomanometer Model QL-20, QL-201/ Aneroid sphygmomanometer with stethoscope, Model QL-50 are a manual non-invasive aneroid sphygmomanometer which respectively uses an inflation cuff wrapped around the upper arm. The cuff is inflated and deflated by a manual inflation bulb. Besides a manometer (Aneroid gauge), the accessories include cuff, inflation bulb, instruction manual and carrying case. Model OL-50 also includes a stethoscope. It is conjunction with stethoscope when use.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Upper arm(leg for child)

Indicated Patient Age Range

Aged 3 years and above

Intended User / Care Setting

Medical professionals or in the home. Hospital, home, office, and ambulance, etc.

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

Not Found

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

Not Found

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

Non clinical tests were conducted to verify that the subject device met all design specifications as was Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the subject device complies with the following standards:

  • A ISO 81060-1:2007, Non-invasive sphygmomanometers — Part 1: Requirements and test methods for non-automated measurement type ;
  • 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;

No clinical study is included in this submission.

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

Accuracy: Pressure : ± 3mmHg of reading

Predicate Device(s)

K190902

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 870.1120 Blood pressure cuff.

(a)
Identification. A blood pressure cuff is a device that has an inflatable bladder in an inelastic sleeve (cuff) with a mechanism for inflating and deflating the bladder. The cuff is used in conjunction with another device to determine a subject's blood pressure.(b)
Classification. Class II (performance standards).

0

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October 13, 2022

Zhejiang LuDe Technology Development Co., Ltd. Iris Du RA Manager NO. 298 Jichang North Road, Longwan District Wenzhou, Zhejiang 325024 China

Re: K221857

Trade/Device Name: Aneroid sphygmomanometer Model QL-20, QL-201, Aneroid sphygmomanometer with stethoscope, Model QL-50 Aneroid sphygmomanometer, QL-20, Aneroid sphygmomanometer, QL-201 Regulation Number: 21 CFR 870.1120 Regulation Name: Blood Pressure Cuff Regulatory Class: Class II Product Code: DXQ, LDE Dated: September 23, 2022 Received: September 23, 2022

Dear Iris Du:

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 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 Quality Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K221857

Device Name

Aneroid sphygmomanometer Model QL-20, QL-201, Aneroid sphygmomanometer with stethoscope, Model QL-50

Indications for Use (Describe)

The device is intended to be used by medical professionals or in the home for the measurement of systolic and diastolic pressure. The device is intended to be manually attached to a patient and manually inflated along with a manual method for detecting Korotkoff sounds. This product can measure the blood pressure of people aged 3 years and above.

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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Sponsor:Zhejianq LuDe Technology Development Co., Ltd. Subjective device: Aneroid sphygmomanometer Model QL-20, QL-201 Aneroid sphygmomanometer with stethoscope Model QL-50

Chapter 6. 510(K) Summary

1.submitter

Company name:Zhejiang LuDe Technology Development Co., Ltd. Address:NO.298 Jichang North Road, Longwan District, Wenzhou City, Zhejiang Province, China Postal Code:325024 TEL:86-0513-80580127 Contact person: Iris Du(RA Manager) E-mail:sara-xu(@)lordmed.com

2.Subject Device Information

Model: QL-20, QL-201, QL-50 Common name: Blood Pressure Kit(Blood Pressure Cuff) Trade name: Aneroid sphygmomanometer Model QL-20, QL-201/ Aneroid sphygmomanometer with stethoscope, Model QL-50 Product Code: DXQ,LDE Regulation name: 21CFR 870.1120 (Blood pressure cuff)/21CFR 870.1875(Stethoscope) Regulation class: II Review Panel: Cardiovascular

3.Predicate device

Sponsor:Wenzhou Renhua Instruments Co.,Ltd

Device Name: RH non-Automated Blood Pressure Meter, MODEL Max02 and RH non-

Automated Blood Pressure Meter with Stethoscope, MODEL Max0201, Max0202, Max0203

510(K) number: K190902

Product Code:DXQ,LDE

Regulation class: II

Review Panel: Cardiovascular

4

4.Intended use

The device is intended to be used by medical professionals or in the home for the measurement of systolic and diastolic pressure. The device is intended to be manually attached to a patient and manually inflated along with a manual method for detecting Korotkoff sounds.This product can measure the blood pressure of people aged 3 years and above.

5.Device description

Aneroid sphygmomanometer Model QL-20, QL-201/ Aneroid sphygmomanometer with stethoscope, Model QL-50 are a manual non-invasive aneroid sphygmomanometer which respectively uses an inflation cuff wrapped around the upper arm. The cuff is inflated and deflated by a manual inflation bulb. Besides a manometer (Aneroid gauge), the accessories include cuff, inflation bulb, instruction manual and carrying case. Model OL-50 also includes a stethoscope. It is conjunction with stethoscope when use.

6. Substantial equivalence comparison

It is substantially equivalence to the predicate device (K190902) RH non-Automated Blood Pressure Meter, MODEL Max02 and RH non-Automated Blood Pressure Meter with stethoscope MODEL Max0201,Max0202,Max0203 with respect to indication for use, device description, and technical description.

All comparison table for applied device are as following, and the substantial equivalence determination is based on the 510(K) Substantial Equivalence Decision-Making Process Flowchart which includes the comparison and discussion of indication for use, technology, and performance specifications.

The new device column includes the following device: Aneroid sphygmomanometer Model QL-20, QL-201/ Aneroid sphygmomanometer with stethoscope, Model QL-50

K221857

5

Subjective device: Aneroid sphygmomanometer Model QL-20, QL-201

Aneroid sphygmomanometer with stethoscope Model QL-50
ItemSubject DevicePredicate DeviceRemark
ApplicantZhejiang LuDe
Technology Development
Co., Ltd.Wenzhou Renhua
Instruments Co.,Ltd/
510(K)numberApplyingK190902/
Regulation
number21 CFR 870.112021 CFR 870.1120SE
Product codeDXQ.LDEDXQ.LDESE
ClassificationClass IIClass IISE
Intended useThe device is intended to
be used by medical
professional or at home for
the measurement of
systolic and diastolic
pressure by detecting
korotkoff sounds.The device is intended to be
used by medical professional
or at home for the
measurement of systolic and
diastolic pressure by
detecting korotkoff sounds.SE
Over-the-
counter useYesYesSE
Target
populationAged 3 years and aboveNew born, Infants,
children, youngadults,adultsSimilar
Note 1
Where usedHospital, home, office,and
ambulance, etc.Hospital, home, office,and
ambulance, etc.SE
Anatomical
sitesUpper arm(leg for child)Upper arm(leg for child)SE
Measurement
methodAusculatory Korotkoff
sounds methodAusculatory Korotkoff
sounds methodSE
InflationManual by inflation bulbManual by inflation bulbSE
DeflationManual deflation via valveManual deflation via valveSE
DisplayAneroid ManometerAneroid ManometerSE
The monitor
scaleFrom 0 to 300mmHg with
a minimum interval of
2mmHgFrom 0 to 300mmHg with a
minimum interval of
2mmHgSE
DesignThe device comprised
tubing attached to a cuff
with an integrated
inflatable bladder that is
wrapped around the
patient's limb and secured
by hook and loop closure.The device comprised tubing
attached to a cuff with an
integrated inflatable bladder
that is wrapped around the
patient's limb and secured
by hook and loop closure.SE
Design of
stethoscopeOne type option:
Single headThree types option:
Single head
Dual head
RappaportSimilar
Note2
MaterialsThe manometer :
aluminum and stainless
steel materials.
Cuff:Nylon cloth or cotton
cloth for outside layer.The manometer :aluminum
and stainless steel materials.
Cuff:Nylon cloth or cotton
cloth for outside layer.SE
AccuracyPressure : $\pm$ 3mmHg of
readingPressure : $\pm$ 3mmHg of
readingSE
CompatibilityIt can be used from 50°F toIt can be used from 50°F toSE

6

Subjective device: Aneroid sphygmomanometer Model QL-20, QL-201

Aneroid sphygmomanometer with stethoscope Model QL-50
14

| with
environment | 104°F (10°C to 40°C) and
15%~85% RH humidity . | 104°F (10°C to 40°C) and
15%~85% RH humidity . | |
|-------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------|
| Cuff size | 185mm55mm
255mm
75mm
345mm110mm
500mm
140mm
540mm145mm
615mm
175mm
780mm220mm | 20"×5.5"(510mm140mm)
21.7"×6.3"(550mm160mm)
24.4"×6.9"(620mm
175mm)
28.3"×8.3"(720mm210mm)
13.4"×4.15"(340mm
105mm)
10.2"×3"(260mm75mm) | Similar
Note3 |
| Cuff
circumference | Fits arm circumferences
100mm-660mm,the
standard cuff should be
available for use in
measuring a child's leg
blood pressure and for
children with larger arms. | Fits arm circumferences
8.7"to 17.3" (220mm-
440cm),the standard cuff
should be available for use
in measuring a child's leg
blood pressure and for
children with larger arms. | Similar
Note4 |
| Cuff bladder
size | 40mm
80mm
60mm120mm
80mm
150mm
120mm220mm
145mm
315mm
180mm370mm | 8.7"×4.7"(220mm120mm)
11.8"×5.9"(300mm150mm)
13.4"×6.7"(340mm
170mm)
6.9"×3.3"(175mm85mm)
7.5"x2"(190mm
50mm) | Similar
Note5 |
| Contents(with
accessories) | Aneroid gauge, Arm cuff,
inflation bulb, and
instruction manual,
stethoscope(option) | Aneroid gauge, Arm cuff,
inflation bulb, and
instruction manual,
stethoscope(option) | SE |
| Biocompatibility | Biocompatible as
requirement of
ISO 10993-1
ISO 10993-5
ISO 10993-10 | Biocompatible as
requirement of
ISO 10993-1
ISO 10993-5
ISO 10993-10 | SE |
| Performance | Compatible as requirement
of ISO 81060-1 | Compatible as requirement
of ISO 81060-1 | SE |

Discussion of difference:

Note IDJustification
Note 1The population range of subject device is smaller than predicate
device. The different population range don't raise any safety or
effectiveness issue and the performance of subject device was tested
in accordance with ISO 81060-1 and no safety issue was found.
Note 2The subject device only has one kind of the stethoscope (Single head
stethoscope), while the predicate has three kinds of stethoscope(Single
head stethoscope, Dual head stethoscope, Rappaport stethoscope). The
Page 4 of 5

7

Subjective device: Aneroid sphygmomanometer Model QL-20, QL-201

Aneroid sphygmomanometer with stethoscope Model QL-50

different type of stethoscopes don't raise any safety or effectiveness issue.
Note 3, Note 4
and Note 5The different sizes of the cuffs and bladders,cuff circumstance are
provided in order to accommodate varies target population. All
performance have been tested in this submission in accordance with
ISO 81060-1 standard and do not raised any safety or effectiveness
issue. Therefore, these differences do not raise any new issues on
safety and effectiveness of the subject device.

Discussion:

Compared with predicate device, the subject device has same intended use, component, patient of population, accuracy and etc. The only difference is the cuff and bladder size, cuff circumference. This difference is discussed and evaluated in the above table and it shows that there is no new issues of safety and effectiveness raised. So subject device is as safe, as effective, and performs as well as the legally marketed predicate device.

7. Non-clinical testing

Non clinical tests were conducted to verify that the subject device met all design specifications as was Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the subject device complies with the following standards:

  • A ISO 81060-1:2007,Non-invasive sphygmomanometers — Part 1: Requirements and test methods for non-automated measurement type ;
  • 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;

8. Clinical testing

No clinical study is included in this submission.

9.Conclusion

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