(69 days)
The POCD Pulsed Oxygen Conserving Device is indicated for use to conserve oxygen for patients prescribed 1 to 4 liters per minute of supplemental oxygen and use nasal cannulas and USP bottled oxygen.
The Pulsed Oxygen Conserving Device or "POCD" is intended to be used as an accessory to an oxygen supply system to reduce or conserve the amount of oxygen used by the patient. The POCD is a battery operated electronic device that is microprocessor controlled and contains a capacitive breath sensor and a normally closed valve. When installed between the oxygen supply and patient's nasal cannula, the device detects the patient's inhalation opens the valve according to the device's breath skipping algorithm and delivers a preset bolus of oxygen to the patient. The valve closes and conserves the oxygen that would have been wasted during the end of inhalation and during exhalation.
The provided text describes a 510(k) submission for a Pulsed Oxygen Conserving Device (POCD). The submission focuses on demonstrating substantial equivalence to predicate devices through functional and environmental testing. However, the document does not contain the level of detail requested for acceptance criteria and a study proving those criteria, especially regarding clinical performance, human readers, or detailed ground truth establishment.
Here's a breakdown of what can be extracted and what information is missing:
1. Table of Acceptance Criteria and Reported Device Performance
The document describes functional, environmental, and power supply testing, and states that the device "meets its performance objectives and complies with applicable FDA guidelines." However, specific quantitative acceptance criteria for these tests are not provided, nor are the reported numerical results to compare against such criteria.
| Acceptance Criteria Category | Specific Acceptance Criteria (None explicitly stated in document) | Reported Device Performance (General statement only) |
|---|---|---|
| Functional Testing | e.g., Breath detection response time within X ms, Oxygen bolus volume within Y mL of target, Breath skipping algorithm accuracy within Z% | "demonstrated that it meets its performance objectives" |
| Environmental Testing | e.g., Withstands drop from X height, Operates within Y to Z temperature range, EMC compliance to standard A, ESD compliance to standard B | "demonstrated that it meets its performance objectives" |
| Power Supply Testing | e.g., Battery life of X hours at Y setting, Low battery indicator accuracy | "demonstrated that it meets its performance objectives" |
| Alarm Package | e.g., Disconnection alarm triggers within X seconds, Malfunction alarm triggers correctly | (Implied through functional testing, but no specific performance reported) |
2. Sample Size Used for the Test Set and Data Provenance
- Test Set Sample Size: Not specified. The document mentions "Extensive functional testing" and testing under "various environmental conditions," but does not quantify the number of devices or test conditions.
- Data Provenance: Not specified. The testing described appears to be laboratory-based and conducted by the manufacturer, Medical Electronic Devices Corp. There is no mention of clinical data, patient origin, or retrospective/prospective study design regarding performance.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
Not applicable. The described testing is technical and functional, not clinical where expert-established ground truth would typically be relevant (e.g., for diagnostic accuracy). The intended use is described, but no clinical study with expert ground truth is detailed.
4. Adjudication Method for the Test Set
Not applicable. Since no clinical test set with human assessment and ground truth establishment is described, there's no mention of an adjudication method.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No. The document makes no mention of an MRMC study or any study comparing human readers with and without AI assistance. The device is a "Pulsed Oxygen Conserving Device," not an AI diagnostic tool.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
The device itself is an "algorithm only" device in a sense, as its core function (breath sensing, valve actuation, breath skipping) is automated. The "Performance Data" section describes "Extensive functional testing" which would fall under standalone testing of the device's operational characteristics. However, this is not a diagnostic algorithm.
7. The Type of Ground Truth Used
For the functional and environmental testing described:
- Ground Truth: Engineering specifications, design requirements, and applicable FDA guidelines. The device's performance was likely compared against these pre-defined technical standards.
For the breath skipping algorithm, the document states it is a "clinically proven method of maintaining equivalent blood oxygen saturation versus prescribed continuous oxygen flow rates and used in all three of the predicate devices." This implies that the concept of the algorithm has clinical backing from predicate devices, but the document does not detail a clinical study where the POCD's breath-skipping performance was verified against physiological ground truth (e.g., direct blood oxygen saturation measurements) for this specific device.
8. The Sample Size for the Training Set
Not applicable. This device is a hardware-based electromechanical device controlled by software and a fixed algorithm (breath skipping algorithm, alarm logic). It does not appear to use machine learning or AI that would require a "training set" in the conventional sense for a diagnostic algorithm.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there's no mention of a training set for machine learning. The "ground truth" for its operational logic would be based on engineering design, clinical understanding of oxygen delivery, and the established principles demonstrated by its predicate devices.
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MEDICAL ELECTRONIC DEVICES CORP.
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POCD Pulsed Oxygen Conserving Device 510(k) Summary
Submitter's Name, Address, Telephone Number, and Contact Person
Submitter
Thomas Wenzel Medical Electronic Devices Corp. 2807 Oregon Court., "D6" Torrance, California 90503 Telephone: (310)618-0306 Facsimile: (310)618-1034
Contact Person
Thomas Wenzel Medical Electronic Devices Corp. 2807 Oregon Court., "D6" Torrance, California 90503 (310)618-0306 Telephone: (310)618-1034 Facsimile:
Date Prepared
September 15, 1998.
Name of Device
| Trade Name: | Pulsed Oxygen Conserving Device or POCD |
|---|---|
| Common name: | Oxygen Conserver |
| Classification name: | Ventilator, Non-Continuous (Respirator)21CFR 868.5905 |
Predicate Devices
(1) CHAD Therapeutics, Inc. Oxymatic-24 (K884562)
- (2) CHAD Therapeutics, Inc. Oxymatic Electronic Oxygen Conserver (K852650)
- (3) Airsep Corporation Impulse (K962766)
Intended Use
The POCD Pulsed Oxygen Conserving Device is indicated for use to conserve oxygen for patients prescribed 1 to 4 liters per minute of supplemental oxygen and use nasal cannulas and USP bottled oxygen.
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Technological Characteristics and Substantial Equivalence
The Pulsed Oxygen Conserving Device or "POCD" is intended to be used as an accessory to an oxygen supply system to reduce or conserve the amount of oxygen used by the patient. The POCD is a battery operated electronic device that is microprocessor controlled and contains a capacitive breath sensor and a normally closed valve. When installed between the oxygen supply and patient's nasal cannula, the device detects the patient's inhalation opens the valve according to the device's breath skipping algorithm and delivers a preset bolus of oxygen to the patient. The valve closes and conserves the oxygen that would have been wasted during the end of inhalation and during exhalation.
The POCD is intended to be used with USP bottled oxygen and nasal cannulas and is installed as shown in Figure 1.
Image /page/1/Figure/3 description: The image shows a diagram of an oxygen delivery system. The system includes a USP bottled oxygen tank connected to a pressure regulator and valve assembly that delivers 4 lpm flow at 20 psi. The oxygen then flows through oxygen supply tubing to a POCD oxygen conserver, and finally to a nasal cannula.
The front panel of the POCD has a selector switch and a battery status light. When the selector switch is set to the "Bat" position the battery status light will illuminate to give the user an indication of the condition of the battery in the device. I n addition to providing battery status information to the user while in the "Bat" setting, the POCD will indicate a low battery condition by flashing the battery status light Red if the unit is in any of the operational settings; "4", "3", "2", or "1", and the battery voltage falls below 1.10V.
When the selector switch is set to "4", "3", "2", or "1" the device operates as follows:
The capacitive pressure transducer changes its capacitance in response to the negative pressure produced by the user's inhalation effort. This change in capacitance is converted into a change in voltage and is amplified. When this amplified voltage exceeds the reference voltage of the comparator, the comparator's output changes state. This change is input into the microprocessor. The microprocessor then opens the valve for a preset time period to deliver 35 ml of oxygen or indexes a counter in the breath skipping algorithm.
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The breath skipping algorithm, a clinically proven method of maintaining equivalent blood oxygen saturation versus prescribed continuous oxygen flow rates and used in all three of the predicate devices, works by delivering a bolus of oxygen to the user according to the following schedule:
| Selector SwitchSetting | EquivalentContinuous FlowPrescription | POCD Breath Skipping Algorithm |
|---|---|---|
| 4 | 4 lpm | Delivery on almost every breath (99%) |
| 3 | 3 Ipm | Delivery on 3 out of 4 breaths (75%) |
| 2 | 2 Ipm | Delivery on every other breath (50%) |
| 1 | 1 Ipm | Delivery on 1 out of 4 breaths (25%) |
The POCD contains an alarm package which is designed to alert the user in the event of disconnection or restriction of the cannula or unit malfunction. The POCD will produce an audible alarm tone to alert the user if it has not detected sufficient negative pressure to cause the comparator output to change states within 30 seconds. The POCD will also produce an intermittent audible tone if the device's continuous self check routine has detected a matfunction in the microprocessor or software control code.
The POCD is substantially equivalent in intended use and principal of operation to other oxygen conserving devices including the CHAD Therapeutics Oxymatic-24 (K884562), CHAD Therapeutics Oxymatic Electronic Oxygen Conserver (K852650), and the Airsep Impulse (K962766). These predicate devices, like the POCD, are electronic products that use a breath sensor and normally closed valve. Additionally, the predicate devices. like the POCD. use a breath skipping algorithm to conserve oxygen while maintaining patient oxygen saturation levels equivalent to 1 to 4 liter per minute continuous oxygen flow delivery.
Performance Data
Extensive functional testing of the POCD has been performed. In addition, testing of the device has been performed under various environmental conditions, including impact/drop testing, storage temperature testing, electromagnetic interference testing, electrostatic discharge testing and surface temperature testing. Power supply testing was also performed; these tests included battery life testing and low power indicator testing. The functional, environmental and power supply testing performed on the device demonstrated that it meets its performance objectives and complies with applicable FDA guidelines.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is a stylized image of three human profiles facing to the right, with flowing lines representing hair or movement.
Public Health Service
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
FEB 2 6 2002
Mr. Thomas Wenzel Medical Electronic Devices Corp. 2807 Oregon Court D6 Torrance, CA 90503
Re: K983459
Pulsed Oxygen Conserving Device Regulation Number: 868.5905 Regulation Name: Noncontinuous Ventilator Regulatory Class: II (two) Product Code: 73 NFB
Dear Mr. Wenzel:
This letter corrects our substantially equivalent letter of December 8, 1998, regarding the Pulsed Oxygen Conserving Machine. Our letter identified the product code as 73 BZD. This is in error; the correct product code is 73 NFB as indicated above.
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. 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.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such 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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Page 2 - Mr. Thomas Wenzel
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); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 21 CFR Part 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4648. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html
Sincerely yours,
DeWitt
Bram D. Zuckerman, M.D. Acting Director Division of Cardiovascular and Respiratory Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Medical Electronic Devices Corp. Pulsed Oxygen Conserving Device Indications for Use Statement
510(k) Reference Number:
This is an initial submission; no number has yet been assigned.
Statement of Indications for Use:
The POCD Pulsed Oxygen Conserving Device is indicated for use to conserve The TOOD Fulloed Oxygon Sonoor 4 to 4 liters per minute of supplemental oxygen and use nasal cannulas and USP bottled oxygen.
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE) MOJT
(Division Sign-Off) Division of Cardiovascular, Respiratory, and Neurological Devices 510(k) Number
Prescription Use (Per 21 CFR 801.109)
OR
Over-The-Counter Use
(Optional Formal 1-2-96)
§ 868.5905 Noncontinuous ventilator (IPPB).
(a)
Identification. A noncontinuous ventilator (intermittent positive pressure breathing-IPPB) is a device intended to deliver intermittently an aerosol to a patient's lungs or to assist a patient's breathing.(b)
Classification. Class II (performance standards).