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510(k) Data Aggregation

    K Number
    K213754
    Date Cleared
    2023-06-12

    (559 days)

    Product Code
    Regulation Number
    868.1840
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Inofab Saglik Teknolojileri A.S

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    SpiroHome is intended to be used by adults and children over 5 years old in physician's offices, clinics and home setting to conduct basic lung function and spirometry testing.

    Device Description

    The SpiroHome Ultrasonic Spirometer (SUS) is a portable spirometer designed to perform pulmonary function tests in patients over the age of 5 in office (clinical) and home settings. The SpiroHome spirometer is used together with a SpiroWay mouthpiece that is inserted into and lines the entire airway of the device. SpiroHome derives pulmonary function data from airflow measurements taken by its ultrasonic sensors during a spirometry test. All of the information recorded by the device is displayed on the relevant SpiroHome app running on a Bluetoothconnected device. The pulmonary function test (PFT) data recorded by the SpiroHome device during a spirometry test is also compared against the patient's predicted values which are obtained from internationally accepted PFT equations. The user interfaces with the SpiroHome app during the entire use of the SpiroHome spirometer.

    The associated accessories include: SpiroWay mouthpiece

    AI/ML Overview

    The SpiroHome Ultrasonic Spirometer's acceptance criteria and performance are detailed in comparison to predicate and reference devices, and through various performance, electrical, and biocompatibility tests.

    1. Table of Acceptance Criteria and Reported Device Performance:

    AttributeAcceptance Criteria (from Subject Device - SpiroHome)Reported Device Performance (from Subject Device - SpiroHome)
    Functional RequirementsATS 2019 / ERS waveform simulator testingMeets
    ISO 26782:2009Meets
    ISO 23747:2015Meets
    High Altitude PerformanceMeets
    Flow ResistanceMeets
    Electrical RequirementsAAMI ANSI ES 60601-1Meets
    IEC 60601-1-11Meets
    IEC 60601-1-2Meets
    BiocompatibilityISO 10993-1Meets
    (Contact Type & Duration:ISO 10993-3Meets
    Surface Contact, Mucosa,ISO 10993-5Meets
    Externally Communicating,ISO 10993-10Meets
    Tissue; permanent (>30 days))ISO 10993-11Meets
    ISO/FDIS 18562-1Meets
    ISO/FDIS 18562-2Meets
    ISO/FDIS 18562-3Meets
    Shipping Requirements,ASTM D4332Meets
    Packaging and DistributionASTM D7386Meets
    ASTM F1886/F1886MMeets
    ISO 17664Meets
    ISO 11737-1Meets
    CleaningISO 17664Meets
    AAMI TIR30Meets
    AAMI TIR12Meets
    ASTM E2314Meets
    ISO 15883-1Meets
    ISO 11737-1Meets
    ISO/TS 15883-5Meets
    Software and SystemGuidance for the Content of Premarket Submissions forMeets
    Verification and ValidationSoftware Contained in Medical Devices
    IEC 62304Meets
    Human Factors StudyGuidance for Applying Human Factors and UsabilityMeets
    Engineering to Medical Devices
    AAMI/ANSI HE75:2009Meets
    ANSI/AAMI/IEC 62366-1:2015Meets
    Volume Range & Accuracy0-10 L, ± 2.5% or ± 0.050 LConforms to permissible margins in ATS guidelines and ISO 286782
    Flow Range & Accuracy0 - 14 L/s, ±10% or ± 170 mL/sConforms to permissible margins in ISO 286782

    Note: The document states "Meets" for all listed performance and safety standards, implying the device successfully passed the tests conducted against these criteria.

    2. Sample Size Used for the Test Set and Data Provenance:
    The document does not explicitly state the sample size for any specific test set or the data provenance (e.g., country of origin, retrospective or prospective) for the performance data.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications:
    This information is not provided in the document. The performance data seems to be based on compliance with established standards (e.g., ATS, ERS, ISO) rather than expert-established ground truth from a test set of patient data.

    4. Adjudication Method for the Test Set:
    The document does not describe any adjudication method as it appears to rely on objective testing against technical and safety standards rather than expert consensus on diagnostic outcomes.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done:
    No, an MRMC comparative effectiveness study is not mentioned in the provided document. The study focuses on demonstrating substantial equivalence through technical and performance comparisons with predicate and reference devices, and by meeting various regulatory standards.

    6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) Was Done:
    The document does not specifically detail a standalone algorithm-only performance study. The performance testing section outlines functional, electrical, biocompatibility, shipping, cleaning, software, and human factors tests. For a device like a spirometer, "standalone" performance typically refers to the accuracy of its physical measurements and calculations, which are covered by the functional and electrical requirements. The software verification and validation would also assess the algorithm's performance.

    7. The Type of Ground Truth Used:
    For the technical performance of the device (e.g., volume and flow accuracy), the ground truth appears to be based on internationally accepted performance standards and guidelines, such as ATS guidelines and ISO 286782. For other aspects like electrical safety and biocompatibility, the ground truth is adherence to the specified IEC, AAMI, and ISO standards.

    8. The Sample Size for the Training Set:
    This information is not provided in the document. The document refers to the device's technological characteristics and its compliance with standards, not typically a "training set" in the machine learning sense for a diagnostic device that performs direct physiological measurements.

    9. How the Ground Truth for the Training Set Was Established:
    As there's no mention of a training set for an AI/ML algorithm in the context of this traditional medical device submission, the method for establishing ground truth for a training set is not applicable or provided. The device's operation is based on ultrasonic sensor technology and PFT equations, not a learning algorithm that requires a labeled training set.

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