K Number
K243898
Device Name
Chlorine Sentinel II
Date Cleared
2025-04-11

(113 days)

Product Code
Regulation Number
876.5665
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Chlorine Sentinel II is intended for use by hemodialysis professionals as a secondary chlorine device to provide continuous monitoring of Combined Chlorine. It is not intended to replace the primary method of monitoring chlorine as part of the hemodialysis water treatment system. It functions completely independent of the water treatment system does not come into direct contact with feed water used to prepare dialysate.
Device Description
Chlorine Sentinel II is a complete system that attaches to the drain of a hemodialysis water treatment system sample port. It detects dissolved combined chlorine in concentrations at or above 10 PPB by primary detection technology. It self-monitors for maintenance-required conditions and loss of electrical power. The Chlorine Sentinel II is self-testing. It uses chlorinated city water to automatically test the chlorine detecting functionality of the device once a day and records if the test passed, failed to detect chlorine, or didn't rinse out after detecting chlorine. The device is designed to use as little water as possible. The sampling water is only used for the length of time that it takes for the chlorine test to be completed. The customer determines how frequently the test needs to be taken from every 5 minutes to every 20 minutes. The user also sets the start time and end time for each day of the week. The Chlorine Sentinel II has two combined chlorine concentration set points. The user can set a warning set-point at a value of 0.01 PPM to 0.09 PPM. Once the chlorine concentration exceeds this value, the device will alarm at 2-HZ to warn the user of chlorine present at that set-point. The second set-point is factory set at 0.10 PPM. A chlorine concentration equal to or above the 0.10 PPM set-point will activate the buzzers and the red chlorine alarm indicators at 5 HZ for as long as the condition exists. The buzzers can only be muted for 3 minutes (then automatically reset) for as long as the condition exists. The alarms can be by-passed. When by-passed the pulsing lights will turn solid and the buzzer will double click over 15 minutes. The front cover of the device has two screens. The screen of the chlorine monitor indicates the presence of combined chlorine when the value is not 0.000. The touch screen is used to enter user data and show the statuses of the device.
More Information

K193169/S001

Not Found

No.

The device description focuses on sensing, pre-set alarms, and basic self-testing functionalities, which do not suggest the presence of an AI model. There is no mention of machine learning, deep learning, or any adaptive or predictive capabilities beyond simple threshold-based alerts.

No.
The device monitors chlorine levels in water for hemodialysis, but it does not directly treat or diagnose a medical condition in a patient; it is an analytical instrument for water quality.

No

The Chlorine Sentinel II monitors the concentration of combined chlorine in water and alarms when set points are exceeded; it does not diagnose a medical condition in a patient.

No

The device is not a software-only medical device because it is described as a "complete system that attaches to the drain of a hemodialysis water treatment system sample port" and "detects dissolved combined chlorine in concentrations at or above 10 PPB by primary detection technology," indicating a hardware component for sensing and physical interaction. It also mentions "front cover of the device has two screens" and physical alarms (buzzers, lights), further supporting the presence of hardware beyond just software. The software component mentioned is for controlling and managing the hardware functions.

No.
The device monitors chlorine levels in water for hemodialysis systems, which is an environmental monitor, not a diagnostic test performed on human specimens.

N/A

Intended Use / Indications for Use

The Chlorine Sentinel II is intended for use by hemodialysis professionals as a secondary chlorine device to provide continuous monitoring of Combined Chlorine. It is not intended to replace the primary method of monitoring chlorine as part of the hemodialysis water treatment system. It functions completely independent of the water treatment system does not come into direct contact with feed water used to prepare dialysate.

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

MSY, PSX

Device Description

Chlorine Sentinel II is a complete system that attaches to the drain of a hemodialysis water treatment system sample port. It detects dissolved combined chlorine in concentrations at or above 10 PPB by primary detection technology. It self-monitors for maintenance-required conditions and loss of electrical power.

The Chlorine Sentinel II is self-testing. It uses chlorinated city water to automatically test the chlorine detecting functionality of the device once a day and records if the test passed, failed to detect chlorine, or didn't rinse out after detecting chlorine.

The device is designed to use as little water as possible. The sampling water is only used for the length of time that it takes for the chlorine test to be completed. The customer determines how frequently the test needs to be taken from every 5 minutes to every 20 minutes. The user also sets the start time and end time for each day of the week.

The Chlorine Sentinel II has two combined chlorine concentration set points. The user can set a warning set-point at a value of 0.01 PPM to 0.09 PPM. Once the chlorine concentration exceeds this value, the device will alarm at 2-HZ to warn the user of chlorine present at that set-point. The second set-point is factory set at 0.10 PPM.

A chlorine concentration equal to or above the 0.10 PPM set-point will activate the buzzers and the red chlorine alarm indicators at 5 HZ for as long as the condition exists.

The buzzers can only be muted for 3 minutes (then automatically reset) for as long as the condition exists.

The alarms can be by-passed. When by-passed the pulsing lights will turn solid and the buzzer will double click over 15 minutes.

The front cover of the device has two screens. The screen of the chlorine monitor indicates the presence of combined chlorine when the value is not 0.000. The touch screen is used to enter user data and show the statuses of the device.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

hemodialysis professionals

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)

Bench testing was performed, including a Linearity Study to CLSI standard EP06-A and a Limit of Blank, Limit of Quantitation, Limit of Detection Study to CLSI standard EP17-A2. Software validation was also performed.

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

Not Found

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

K193169/S001

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

Not Found

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

Not Found

§ 876.5665 Water purification system for hemodialysis.

(a)
Identification. A water purification system for hemodialysis is a device that is intended for use with a hemodialysis system and that is intended to remove organic and inorganic substances and microbial contaminants from water used to dilute dialysate concentrate to form dialysate. This generic type of device may include a water softener, sediment filter, carbon filter, and water distillation system.(b)
Classification. Class II (special controls). The device, when it is a water purification subsystem disinfectant, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.

FDA 510(k) Clearance Letter - Chlorine Sentinel II

Page 1

U.S. Food & Drug Administration
10903 New Hampshire Avenue
Silver Spring, MD 20993
www.fda.gov

Doc ID # 04017.07.05

April 11, 2025

Nelson Environmental Technologies, Inc.
Quochuy (Huy) Nguyen
Finance Manager / New Product Development Manager
813 E. Fir Avenue
McAllen, Texas 78501

Re: K243898
Trade/Device Name: Chlorine Sentinel II
Regulation Number: 21 CFR 876.5665
Regulation Name: Water Purification System For Hemodialysis
Regulatory Class: Class II
Product Code: MSY, PSX
Dated: March 18, 2025
Received: March 18, 2025

Dear Quochuy (Huy) Nguyen:

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/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.

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"

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K243898 - Quochuy (Huy) Nguyen Page 2

(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 (QS) 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 (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-reporting-combination-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-devices/device-advice-comprehensive-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-devices/medical-device-safety/medical-device-reporting-mdr-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/medical-devices/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-devices/device-advice-comprehensive-regulatory-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).

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K243898 - Quochuy (Huy) Nguyen Page 3

Sincerely,

Maura Rooney -S

Maura Rooney
Assistant Director
DHT3A: Division of Renal, Gastrointestinal,
Obesity, and Transplant Devices
OHT3: Office of Gastrorenal, ObGyn,
General Hospital, and Urology Devices
Office of Product Evaluation and Quality
Center for Devices and Radiological Health

Enclosure

Page 4

DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration

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

Indications for Use

Submission Number (if known)
K243898

Device Name
Chlorine Sentinel II

Indications for Use (Describe)

The Chlorine Sentinel II is intended for use by hemodialysis professionals as a secondary chlorine device to provide continuous monitoring of Combined Chlorine. It is not intended to replace the primary method of monitoring chlorine as part of the hemodialysis water treatment system. It functions completely independent of the water treatment system does not come into direct contact with feed water used to prepare dialysate.

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.

Page 5

NELSON WATER SYSTEMS FOR HEMODIALYSIS

FDA-Cleared Systems for Hemodialysis 510k) # 993877
FDA-Cleared Systems for Nelson Sentinel Series Basic Chlorine Sentinel 510k) # 193169
ISO 13485:2016 Certified Certificate# C2023-05290

NELSON ENVIRONMENTAL TECHNOLOGIES, INC

P.O. Box 5026, McAllen, TX 78502-5026 http://www.nws.bz
10518 Cash Rd., Stafford, TX 77477
Tel: 281-265-0666 / Fax: 832-539-6607
1312 Corporate Dr. E Suite F, Arlington, TX 76006
Tel: 817-652-1152 / Fax: 817-470-4975
813 E Fir Ave , McAllen, TX 78501
Tel: 956-618-0375 / Fax: 956-618-0375

6. Summary of 510(k)

This 510(k) Summary is in conformance with 21CFR 807.92

Submitter: Nelson Environmental Technologies, Inc.
813 E. Fir Avenue
McAllen, TX 78501
Phone: 956-618-0375

Primary Contact: QuocHuy (Huy) Nguyen
Email: admin@nws.bz
Phone: 956-618-0375
Fax: 956-618-4330

Date Prepared: 2024 December 18

Device Name and Classification

Trade Name: Chlorine Sentinel II
Common Name: Water Purification System for Hemodialysis
Classification: Class II
Regulation Number: 21 CFR 876.5665 Water Purification System for Hemodialysis
Classification Panel: Gastroenterology/Urology
Product Code: MSY, PSX

Predicate Device:

Predicate Device
Trade NameNelson Basic Chlorine Sentinel Basic Chlorine Sentinel
Common NameBasic Chlorine Sentinel
510(k) Submitter / HolderNelson Environmental Technologies, Inc.
510(k) NumberK193169/S001
Regulation Number21 CFR 876.5665 Water purification system for hemodialysis
Classification PanelGastroenterology/Urology
Product CodePSX, FIP

K243898
Page 1 of 11

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K243898
Page 2 of 11

Device Description

Chlorine Sentinel II is a complete system that attaches to the drain of a hemodialysis water treatment system sample port. It detects dissolved combined chlorine in concentrations at or above 10 PPB by primary detection technology. It self-monitors for maintenance-required conditions and loss of electrical power.

The Chlorine Sentinel II is self-testing. It uses chlorinated city water to automatically test the chlorine detecting functionality of the device once a day and records if the test passed, failed to detect chlorine, or didn't rinse out after detecting chlorine.

The device is designed to use as little water as possible. The sampling water is only used for the length of time that it takes for the chlorine test to be completed. The customer determines how frequently the test needs to be taken from every 5 minutes to every 20 minutes. The user also sets the start time and end time for each day of the week.

The Chlorine Sentinel II has two combined chlorine concentration set points. The user can set a warning set-point at a value of 0.01 PPM to 0.09 PPM. Once the chlorine concentration exceeds this value, the device will alarm at 2-HZ to warn the user of chlorine present at that set-point. The second set-point is factory set at 0.10 PPM.

A chlorine concentration equal to or above the 0.10 PPM set-point will activate the buzzers and the red chlorine alarm indicators at 5 HZ for as long as the condition exists.

The buzzers can only be muted for 3 minutes (then automatically reset) for as long as the condition exists.

The alarms can be by-passed. When by-passed the pulsing lights will turn solid and the buzzer will double click over 15 minutes.

The front cover of the device has two screens. The screen of the chlorine monitor indicates the presence of combined chlorine when the value is not 0.000. The touch screen is used to enter user data and show the statuses of the device.

Indications for Use

The Chlorine Sentinel II is intended for use by hemodialysis professionals as a secondary chlorine device to provide continuous monitoring of Combined Chlorine. It is not intended to replace the primary method of monitoring chlorine as part of the hemodialysis water treatment system. It functions completely independent of the water treatment system does not come into direct contact with feed water used to prepare dialysate.

Risk Analysis Method

Chlorine Sentinel II was assessed to determine risks to health associated with the use of the device, a risk analysis was conducted in accordance with ISO 14971: 2007, Medical devices – Application of risk management to medical devices.

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K243898
Page 3 of 11

Substantial Equivalence

The Chlorine Sentinel II is essentially the same as the Nelson Basic Chlorine Sentinel with the following differences:

  1. A Touch Screen and PLC replace the electrical components of the Basic Chlorine Sentinel;
  2. It is inside one enclosure instead of two;
  3. User can set a warning set-point for chlorine concentration;
  4. User can set the start and stop times for each day;
  5. User can set the sampling rate times from 5 minutes to 20 minutes;
  6. The Touch Screen highlights alarm statuses;
  7. Includes water Shut-off Device.

The table below provides a detailed comparison of Nelson Sentinel Series Basic Chlorine Sentinel to the predicate and reference devices.

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K243898
Page 4 of 11

Detailed Comparison of the Subject and Predicate Devices

ItemSubject DevicePredicate DeviceReference DeviceComparison to Predicate Device
Chlorine Sentinel IINelson Sentinel Series Basic Chlorine SentinelHach CM130 Chlorine Monitor(Noted reference device comparison for items that are closer to it)
Intended Use/ Indications for UseThe Chlorine Sentinel II is an instrument that is intended for use by hemodialysis professionals as a secondary chlorine monitor to indicate the presence of combined chlorine in feed water used in hemodialysis systems. It can be used as a secondary chlorine test. It is not intended to be used as a primary chlorine detection deviceNelson Sentinel Series Basic Chlorine Sentinel is indicated for detection of Total Chlorine in Water. Nelson Sentinel Series Basic Chlorine Sentinel is indicated for testing water used to prepare dialysate.Hach CM130 is intended for use in hemodialysis Water treatment systems to read Total Chlorine concentration.Same as Predicate
Provides Exact Chlorine Value?No; Intended to indicate chlorine presence above 0.01 PPM and reference value.Approximate valuesYes; presents an exact chlorine value on its display intended to be used to make clinical decisionsSame as Predicate
Provides Exact Combined Chlorine Value?Yes; presents an exact combined chlorine value on its displayYesNo; measures total chlorine which may be free, combined dissolved, and suspended chlorinated solidsSame as Predicate
Detection Chemistry/ TechnologyDirect measuring polarographic sensor utilizing a special polymeric membrane.Direct measuring polarographic sensor utilizing a special polymeric membrane.DPD Colorimetric MethodSame as Predicate
Chlorine Sensor TypePolarography (Amperometry)Polarographic sensorPhotometric sensorSame as Predicate
Interference with other compounds in potable waterNoneNoneChlorinated organics/suspended solidsSame as Predicate
ReagentsNone (Ammonium Sulfate if used with municipal free chlorine disinfected water)Ammonium sulfateIndicator solution (DPD indicator with potassium iodide), buffer solutionSame as Predicate

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Reagent DeliveryN/APeristaltic pumpPeristaltic pumpSame
Type of Chlorine DetectedDissolved Combined Chlorine, free chlorine to a lesser degreeDissolved Combined Chlorine, free chlorine to a lesser degreeTotal Chlorine (free chlorine plus total chloramines)Same as Predicate
Detection Range> 0.01 mg/L0.05 mg/L Cl₂ – 0.15 mg/L Cl₂0.03 mg/L Cl₂ – 0.20 mg/L Cl₂Same as Predicate
Chlorine Level Alarm0.1 mg/L Cl₂0.1 mg/L Cl₂0.1 mg/L Cl₂Same as Predicate
Warning Chlorine Set-point0.01PPM – 0.09PPMNANADifferent. Warning set-point is a customer requested feature to allow them to be proactive when the presence of combined chlorine is detected versus reactive when the AAMI standard chlorine concentration is reached.
Self-TestingAutomatic testing daily with test passed notification, manual reset. Manual testing for maintenance and calibrationAutomatic testing daily with test passed notification, manual reset. Manual testing for maintenance and calibrationNoneSame as Predicate
SamplingThe chlorine sensor is located on the downstream side of a water treatment test sample port. The sampled water is then discharged down the drain.The chlorine sensor is located on the downstream side of a water treatment test sample port. The sampled water is then discharged down the drain.Feed water is sampled. Water that flows into the CM130 device exits the device to a drain. The water samples, once tested, are also discarded to a drain.Same as Predicate
Water Sample Conditioning and DeliveryAutomaticAutomatedAutomatedSame as Predicate
Measurement Interval5 -30 MinutesContinuous5 minutesDifferent. Chlorine Sentinel II only uses water during the sampling cycle. This significantly reduces the amount of water used over the life of the device

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K243898
Page 6 of 11

| Alarms/ Alerts | Controller: Multi-color Touch Screen highlighted Colors (green for power indication, Red for Chlorine over set-points, yellow for maintenance notification, orange for past chlorine detected, blue for auto-test passed) and a buzzer. Remote Module: Four colors (green for power indication, red for chlorine alerts, yellow for maintenance notification, blue for auto test passed) and a buzzer | Controller: Three colors (green for power indication, 2 yellow, and red for alerts) and a buzzer. Remote Module: Three color lights (green for power indication, 2 yellow, and a red for alerts) and a buzzer | Analyzer: Two colors (amber and red) on the display and three sounds for notifications. Remote Indicator: Two lights show the analyzer status (blue, amber, or red). Two lights show the chlorine status (blue, amber, or red). Three different sounds: hardware alarm, medium-high chlorine alert, and high chlorine alarm. | Different. Auto-test successful light is blue instead of yellow (chlorine Detected) in the predicate device. Lights and buzzers pulse at two different rates depending on user-set set-point and 0.10 mg/L set-point for combined chlorine concentration. |
| Sounds | Piezoelectric buzzer providing 5 Hz pulses for chlorine over 0.10 mg/L, 2 Hz chlorine over user-defined Warning Set-Point or for maintenance notification, solid if PLC failure. 15-minute double chirp if any alarms have been by-passed | | Analyzer: Two different sounds identify a hardware alarm or high chlorine alarm. Remote Indicator: Three different sounds identify a power-loss alarm, hardware alarm or high chlorine alarm. | Different. Predicate device has solid buzzer. Chlorine Sentinel II has added two pulse frequencies to indicate Chlorine over set-points and action-required notifications. |
| Measurement Log | Unlimited | 3000 measurements maximum | | Different. Predicate device has no log. |
| Measurement Point | Between the primary and secondary carbon tanks (filters) | After the secondary carbon filter, before the reverse osmosis (RO) machine. | Between the primary and secondary carbon tanks (filters). | Same as Predicate |
| Device Location | Remote Module is located in the nurse's station; all other components are located in the water room | Remote Module is located in the nurse's station; all other components are located in the water room | Remote indicator is located in the patient room; all other components are located in the water room | Same as Predicate |

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K243898
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EnclosureV0 Fire-rated ABS, IP66 rated with door closed. Remote Indicator Material: PC/ABSV0 Fire-rated ABS, IP66 rated with door closed. Remote Indicator Material: PCEnclosure Rating: IP52 rated with the door closed. Enclosure Material: PC/ABS case, PC door, PC hinges & latches, 316 SST hardware. Remote Indicator Material: PC/ABSSame as Predicate
External Drain Sample PortOn right side wall of enclosure designed for easy access of sample bottles.On right side wall of enclosure designed for easy access of sample bottles.Same as Predicate
Enclosure to protect electronics from splashing or spillsPhysical splash barrierNAYesPredicate had separate enclosures to separate electronics from water. Substantially equivalent. Similar to CM130
Water Treatment RequiredNoNoNoSame as Predicate
Device ComponentsAnalyzer, Remote IndicatorController, Probe/Tester, Remote ModuleAnalyzer, Remote IndicatorSubstantially equivalent to Predicate
Control MechanismPLC – Siemens 1200 Touch Screen - MitsubishiMicrocontrollerMicrocontrollerDifferent. Substantially equivalent to Reference
MaintenanceQuarterlyQuarterlyMonthlySame as Predicate
Data LoggerSD CardNo data logger3000 measurements maximumDifferent. Substantially equivalent to Reference
Status Outputs1. Combined chlorine over set-point (Default 0.100) 2. Analyzer Self-Diagnostic system failures or maintenance required. 3. Auto-Test Passed notification 4. Loss of analyzer signal 5. Loss of analyzer electrical power 6. Auto-Test Failed5 water treatment status outputs - RO shut-down, flood, loss of electricity, device maintenance, and high chlorineTwo levels of chlorine, power statusesSubstantially equivalent to Predicate

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K243898
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Data OutputsMODBUS TCPMODBUS TCP
Data HistoryThe measurement history is available through the Ethernet connection. Measurement History & Event History can be copied to an SD card as two separate files.NAThe measurement history is available through the Ethernet connection. Measurement History & Event History can be copied to an SD card as two separate files.Different. Substantially equivalent to Reference
Display17.9 cm (7") Color Touch ScreenMonitor: Backlit LCD: 1.91 cm (0.75 in.) high 4-digit main display, 0.76 cm (0.3 in.) 5x7 dot matrix 12-digit secondary display10.9 cm (4.3 in.) color display, backlit LCD