K Number
K243086
Device Name
Unimed Reusable Finger Clip SpO2 Sensors (UXXX-91 Series) (U403-91); Unimed Reusable Finger Clip SpO2 Sensors (UXXX-91 Series) (U410-91)
Date Cleared
2025-02-20

(143 days)

Product Code
Regulation Number
870.2700
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Models: U403-91, U410-91 Unimed Reusable Finger Clip SpO2 Sensors are indicated for continuous non-invasive monitoring of functional oxygen saturation of arterial hemoglobin (SpO2) and pulse rate (PR) for adult patients weighing greater than 30 kg. These devices are for prescription use only.
Device Description
The subject devices, Unimed Reusable Finger Clip SpO2 Sensors (UXXX-91 Series), are fully compatible reusable sensors for use with Philips Itellivue MP30. These sensors are supplied non-sterile. The subject sensors (Models: U403-91 and U410-91) consist of a plug/connector (Philips D8 sensor connector), a cable, and a patient-contacting (finger clip) where light-emitting diode (LED) and photodetector (PD) are located. The subject sensors share the same principle of operation as the predicate device for functional oxygen saturation of arterial hemoglobin (SpO2) and pulse rate (PR) measurements. Patient-contacting materials of the subject sensors include ABS, silicone, and TPU, all of which have been qualified against biocompatibility requirements in ISO 10993-5, ISO 10993-10, and ISO 10993-23.
More Information

Not Found

No
The summary describes a standard pulse oximeter sensor that uses LEDs and a photodetector to measure SpO2 and pulse rate. There is no mention of AI, ML, or any related technologies in the device description, performance studies, or key metrics. The principle of operation is stated to be the same as the predicate device, which is a traditional pulse oximeter sensor.

No
The device is indicated for monitoring SpO2 and pulse rate, which are diagnostic/monitoring functions, not therapeutic interventions.

No

Explanation: The device is described as a sensor for "continuous non-invasive monitoring of functional oxygen saturation of arterial hemoglobin (SpO2) and pulse rate (PR)". While it measures physiological parameters, the provided information does not state that it is used to specifically diagnose a disease or condition, but rather to monitor existing parameters.

No

The device description explicitly states that the device consists of a plug/connector, a cable, and a patient-contacting finger clip containing hardware components (LED and photodetector). This indicates it is a hardware device, not software-only.

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

Here's why:

  • IVD Definition: In Vitro Diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections.
  • Device Function: The Unimed Reusable Finger Clip SpO2 Sensors are described as devices for "continuous non-invasive monitoring of functional oxygen saturation of arterial hemoglobin (SpO2) and pulse rate (PR)". This is done by placing the sensor on the finger and using light to measure these parameters directly on the patient.
  • No Sample Analysis: The description does not mention the collection or analysis of any biological samples from the patient.

Therefore, since the device operates by directly monitoring physiological parameters on the patient's body rather than analyzing samples taken from the body, it falls outside the definition of an In Vitro Diagnostic.

N/A

Intended Use / Indications for Use

Models: U403-91, U410-91 Unimed Reusable Finger Clip SpO2 Sensors are indicated for continuous non-invasive monitoring of functional oxygen saturation of arterial hemoglobin (SpO2) and pulse rate (PR) for adult patients weighing greater than 30 kg. These devices are for prescription use only.

Product codes

DOA

Device Description

The subject devices, Unimed Reusable Finger Clip SpO2 Sensors (UXXX-91 Series), are fully compatible reusable sensors for use with Philips Itellivue MP30. These sensors are supplied non-sterile.

The subject sensors (Models: U403-91 and U410-91) consist of a plug/connector (Philips D8 sensor connector), a cable, and a patient-contacting (finger clip) where light-emitting diode (LED) and photodetector (PD) are located. The subject sensors share the same principle of operation as the predicate device for functional oxygen saturation of arterial hemoglobin (SpO2) and pulse rate (PR) measurements.

Patient-contacting materials of the subject sensors include ABS, silicone, and TPU, all of which have been qualified against biocompatibility requirements in ISO 10993-5, ISO 10993-10, and ISO 10993-23.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Finger

Indicated Patient Age Range

adult patients weighing greater than 30 kg.

Intended User / Care Setting

Prescription Use

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 proposed devices met all design specifications as was Substantially Equivalent (SE) to the predicate devices. The conducted non-clinical tests conformed to the following the recognized standards:

  • IEC 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
  • ISO 80601-2-61 Medical electrical equipment - Part 2-61: Particular requirements for basic safety and essential performance of pulse oximeter equipment
  • ISO 10993-5 Biological evaluation of medical devices - Part 5: Tests for in vitro cytotoxicity
  • ISO 10993-10 Biological evaluation of medical devices - Part 10: Tests for skin sensitization
  • ISO 10993-23 Biological evaluation of medical devices Part 23: Tests for irritation ●

Clinical studies were conducted under an approved protocol with subject informed consent to determine the accuracy of proposed device. The clinical studies were conducted per following standards:

  • ISO 80601-2-61 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

Clinical hypoxia test results were obtained in human adult volunteers (the study population includes sufficient darkly pigmented subjects) to validate the accuracy of the subject devices versus arterial oxygen saturation (SaO2) as determined by co-oximetry. Twelve subjects were enrolled for the clinical study. The Fitzpatrick Scale was used to determine their skin pigmentation scores. Three dark subjects (Fitzpatrick Type 5-6) in this study allow a proper evaluation of the sensor accuracy in dark population. The study contains more than the minimum 200 data points, and the clinical study results support device accuracy claims for the specified saturation range.

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

Saturation Accuracy, No Motion: ± 3% (70-100%)
Pulse Rate Accuracy, No Motion: ± 3 bpm (30-250 bpm)
Low Perfusion Accuracy: SpO2 ±3% (70-100%), Pulse ±3 bpm (30-250 bpm)

Predicate Device(s)

K062605

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 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).

0

February 20, 2025

Image /page/0/Picture/1 description: The image contains the logos of the Department of Health and Human Services and the Food and Drug Administration (FDA). The Department of Health and Human Services logo is on the left, and the FDA logo is on the right. The FDA logo includes the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

Unimed Medical Supplies, Inc. Huanyu Zeng Regulatory Affairs Specialist Bld#8, Nangang 3rd Industrial Park, Tangtou, Shiyan, Baoan District Shenzhen, 518108 China

Re: K243086

Trade/Device Name: Unimed Reusable Finger Clip SpO2 Sensors (UXXX-91 Series) (U403-91); Unimed Reusable Finger Clip SpO2 Sensors (UXXX-91 Series) (U410-91); Regulation Number: 21 CFR 870.2700 Regulation Name: Oximeter Regulatory Class: Class II Product Code: DOA Dated: January 20, 2025 Received: January 21, 2025

Dear Huanyu Zeng:

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 (the 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 available at https://www.accessdata.fda.gov/scripts/cdrb/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

Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).

Your device is also subject to, among other requirements, the Quality System (OS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).

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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.

All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rule"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-device-advicecomprehensive-regulatory-assistance/unique-device-identification-system-udi-system.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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-regulatory

2

assistance/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,

Bradley Q. Quinn -S

Bradley Quinn Assistant Director DHT1C: Division of Anesthesia, Respiratory, and Sleep Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT, and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

3

Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: 07/31/2026 See PRA Statement below.

Submission Number (if known)

K243086

Device Name

Unimed Reusable Finger Clip SpO2 Sensors (UXXX-91 Series) (U403-91); Unimed Reusable Finger Clip SpO2 Sensors (UXXX-91 Series) (U410-91)

Indications for Use (Describe)

Models: U403-91, U410-91 Unimed Reusable Finger Clip SpO2 Sensors are indicated for continuous non-invasive monitoring of functional oxygen saturation of arterial hemoglobin (SpO2) and pulse rate (PR) for adult patients weighing greater than 30 kg. These devices are for prescription use only.

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."

4

Image /page/4/Picture/0 description: The image shows the logo for Unimed medical supplies. The logo includes the text "A brand of Xinwell" above the word "UNIMED" in a bold, sans-serif font. Below the word "UNIMED" is the text "medical supplies" in a smaller font. To the right of the text is a red oval containing a white stylized "UM".

510(K) Summary

1. Submitter

Date Prepared:Jan. 20, 2025
Submitter/Manufacturer:Unimed Medical Supplies Inc.
Bld#8, Nangang 3rd Industrial Park, Tangtou,
Shiyan, Baoan District, Shenzhen, China 518108
FDA Establishment Number: 3007307487
Contact:Zeng Huanyu
RA Specialist
Tel: +86-755 26695165
E-mail: zenghy@unimed.cn
510(k) Submission TypeThis is a traditional 510(k).
2. Proposed Device
Trade Name:Unimed Reusable Finger Clip SpO2 Sensors (UXXX-91 Series)
Common Name:Oximeter Sensor
Model NumbersU403-91, U410-91
Classification:Medical Specialty: Cardiovascular
Regulation: 21 CFR 870.2700 – Oximeter
Product Code: DQA
Class: II

3. Predicate Device

510(K) No.Trade Name
K062605Philips Reusable SpO2 Sensor, Models M1196A and
M1196T

4. Device description

The subject devices, Unimed Reusable Finger Clip SpO2 Sensors (UXXX-91 Series), are fully compatible reusable sensors for use with Philips Itellivue MP30. These sensors are supplied non-sterile.

The subject sensors (Models: U403-91 and U410-91) consist of a plug/connector (Philips D8 sensor connector), a cable, and a patient-contacting (finger clip) where light-emitting

5

Image /page/5/Picture/0 description: The image shows the logo for Unimed medical supplies. The logo includes the text "A brand of Xinwell" above the word "Unimed" in large, bold letters. Below "Unimed" are the words "medical supplies" in a smaller font. To the right of the text is a red circle containing a stylized white design.

diode (LED) and photodetector (PD) are located. The subject sensors share the same principle of operation as the predicate device for functional oxygen saturation of arterial hemoglobin (SpO2) and pulse rate (PR) measurements.

Patient-contacting materials of the subject sensors include ABS, silicone, and TPU, all of which have been qualified against biocompatibility requirements in ISO 10993-5, ISO 10993-10, and ISO 10993-23.

5. Intended use/Indications for use

Models: U403-91, U410-91

Unimed Reusable Finger Clip SpO2 Sensors are indicated for continuous non-invasive monitoring of functional oxygen saturation of arterial hemoglobin (SpO2) and pulse rate (PR) for adult patients weighing greater than 30 kg. These devices are for prescription use only.

| Feature | Subject Device
(Model: U410-91,
U403-91) | Predicate Device
(K062605) | Comparison to
Predicate Device |
|--------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------|
| General Information | | | |
| Device name | Unimed Reusable
Finger Clip SpO2
Sensors (UXXX-91
Series) | Philips Reusable SpO2
Sensor, Models
M1196A and M1196T | / |
| Classification
Regulation/ Product
Code | 21 CFR 870.2700,
Class II/DQA | 21 CFR 870.2700,
Class II/DQA | Identical |
| Intended
use/Indications for use | Models:
U403-91,
U410-91
Unimed
Reusable
Finger
Clip
SpO2
Sensors
are indicated
for
continuous
non-invasive
monitoring
of
functional
oxygen
saturation
of
arterial
hemoglobin (SpO2) and | The
M1196A
and
M1196T reusable Clip
sensors
provide
continuous,
non-invasive
measurement of arterial
oxygen
saturation
(pulse rate signal and
plethysmograph wave)
to any SpO2 device that
has passed validation | Substantially
equivalent |
| Feature | Subject Device
(Model: U410-91,
U403-91) | Predicate Device
(K062605) | Comparison to
Predicate Device |
| pulse rate (PR) for
adult patients weighing
greater than 30 kg.
These devices are for
prescription use only. | testing. Either sensor
can be comfortably
clipped onto the finger
of patients weighing >
40 kg (typically adult
patients). | | |
| Principle of operation | Two-wavelength
relative optical
absorption | Two-wavelength
relative optical
absorption | Identical |
| Intended patient
population | Adults | Patients weighing > 40
kg (typically adult
patients) | Substantially
equivalent |
| Intended application
site | Finger | Finger | Identical |
| Prescription or OTC | Rx Only | Rx Only | Identical |
| Use type | Reusable | Reusable | Identical |
| Sensor Structure
Composition | Sensor connector,
cable, LED&PD, finger
clip | Sensor connector,
cable, LED&PD, finger
clip | Identical |
| Raw material | Sensor connector:
Philips D Connect 8
pin connector.
Cable: Copper
conductor in TPU
jacket.
LED wavelength: 663
nm/890 nm
Patient-contacting
material:
ISO10993-compliant | Sensor connector:
Philips D Connect 8
pin connector.
Cable: Copper
conductor in TPU
jacket.
LED wavelength: ~660
nm/~890 nm
Patient-contacting
material:
ISO10993-compliant | Substantially
equivalent |
| Performance (Arms) | | | |
| Saturation Accuracy,
No Motion | $\pm$ 3% (70-100%) | $\pm$ 3% (70-100%) | Identical |
| Pulse Rate Accuracy,
No Motion | $\pm$ 3 bpm (30-250 bpm) | $\pm$ 2% or 1 bpm,
whichever is greater | Substantially
equivalent¹ |
| Feature | Subject Device
(Model: U410-91,
U403-91) | Predicate Device
(K062605) | Comparison to
Predicate Device |
| | (30 to 300 bpm) | | |
| Low Perfusion
Accuracy | SpO2 ±3% (70-100%) | SpO2 ±3% (70-100%) | Identical |
| | Pulse ±3 bpm (30-250
bpm) | Pulse ±2% or 1 bpm,
whichever is greater
(30 to 300 bpm) | Substantially
equivalent¹ |
| Environmental | | | |
| Operating Temperature | 5 to +40 °C | 0 to 40 °C (32 to 104
°F) | Substantially
equivalent |
| Operational/Storage
Humidity | 10-85% | 15 to 90% | Substantially
equivalent |
| Biocompatibility | Pass ISO 10993
cytotoxicity, skin
irritation and skin
sensitivity tests | Pass ISO 10993
cytotoxicity, skin
irritation and skin
sensitivity tests | Identical |
| Energy source | Monitor power supply | Monitor power supply | Identical |

Comparison to predicate devices 6.

6

Image /page/6/Picture/0 description: The image shows the logo for Unimed medical supplies, a brand of Xinwell. The word "Unimed" is written in a bold, sans-serif font, with the words "medical supplies" written in a smaller font below. To the right of the word "Unimed" is a red circle with the letters "UM" written in white. The word "Xinwell" is written in blue.

7

Image /page/7/Picture/0 description: The image shows the logo for Unimed medical supplies. The logo includes the text "A brand of Xinwell" at the top, followed by the word "Unimed" in a large, bold font. Below the word "Unimed" is the text "medical supplies" in a smaller font. To the right of the text is a red oval with a white design inside.

Note:

  1. According to the requirements of "201.12.1.104 Pulse rate ACCURACY" of ISO 80601-2-61:2017, both Subject Device and Predicate Device have validated accuracy over the claimed pulse range and are therefore considered substantially equivalent.

7. Non-clinical test data

Non-clinical tests were conducted to verify that the proposed devices met all design specifications as was Substantially Equivalent (SE) to the predicate devices. The conducted non-clinical tests conformed to the following the recognized standards:

  • IEC 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
  • ISO 80601-2-61 Medical electrical equipment - Part 2-61: Particular requirements for basic safety and essential performance of pulse oximeter equipment
  • ISO 10993-5 Biological evaluation of medical devices - Part 5: Tests for in vitro cytotoxicity
  • ISO 10993-10 Biological evaluation of medical devices - Part 10: Tests for skin

8

Image /page/8/Picture/0 description: The image shows the logo for Unimed medical supplies. The logo includes the text "A brand of Xinwell" in blue, followed by the word "UNIMED" in gray, and the words "medical supplies" in a smaller gray font. To the right of the text is a red oval containing a white design.

sensitization

  • ISO 10993-23 Biological evaluation of medical devices Part 23: Tests for irritation ●

Clinical test data 8.

Clinical studies were conducted under an approved protocol with subject informed consent to determine the accuracy of proposed device. The clinical studies were conducted per following standards:

  • ISO 80601-2-61 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

Clinical hypoxia test results were obtained in human adult volunteers (the study population includes sufficient darkly pigmented subjects) to validate the accuracy of the subject devices versus arterial oxygen saturation (SaO2) as determined by co-oximetry.

Twelve subjects were enrolled for the clinical study. The Fitzpatrick Scale was used to determine their skin pigmentation scores. Three dark subjects (Fitzpatrick Type 5-6) in this study allow a proper evaluation of the sensor accuracy in dark population. The study contains more than the minimum 200 data points, and the clinical study results support device accuracy claims for the specified saturation range.

9. Substantial Equivalence Statement

Based on the comparison, analysis, and the submitted non-clinical data, Unimed believes that the Unimed Reusable Finger Clip SpO2 Sensors (UXXX-91 Series) are as safe and effective and are substantially equivalent to the predicate devices.