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510(k) Data Aggregation
(290 days)
The 'Transcend 365 miniCPAP Auto System' provides positive airway pressure to support treatment of adults over 66 pounds (30 kg) with Obstructive Sleep Apnea (OSA). The device is intended for home and hospital/institutional use. The integrated humidifier provides humidification of air delivered from the Transcend 365 devices. The use of the humidifier is optional.
The Transcend 365 miniCPAP Auto System (Transcend 365) is a new member of Somnetics' family of devices used to treat obstructive sleep apnea which includes the Transcend Auto and Transcend Heated Humidifier devices and accessories cleared via K132127 and K131388. The Transcend 365 utilizes the same blower and the same algorithm as the Transcend Auto for respiratory event detection and therapy for sleep disordered breathing events. The Transcend 365 includes the following main modifications:
- Integrated CPAP and humidification system .
- . Modifications from predicate Transcend Auto device
- Graphic LCD interface vs LED in predicate o
- Housing design O
- Updated air inlet filter o
- Use of a standard 22-mm connection port for air hose attachment O
- Integrated heated humidifier with water reservoir attached with magnets o
- Integrated humidifier uses Capillary Force Vaporization™ (Vapore) technology ●
- o Wick to a ceramic heater vaporizes water (instead of continuous heating with a heater plate)
- Similar to PARI Hydrate V (K072982); same supplier (Vapore) o
- Allows for a smaller water reservoir and footprint o
The Transcend 365 is a microprocessor-controlled, blower-based system that generates positive airway pressure to support treatment of obstructive sleep apnea. It utilizes a differential pressure sensor connected to an internal pneumotach positioned in the airstream to determine flow levels. When interfaced with a mask though use of a 22 mm breathing hose, this flow signal, coupled with pressure sensing, is used to monitor breathing and adjust pressure. The system provides fixed or auto-adjust pressure from 4 to 20 cmH20 above the ambient atmospheric pressure to a patient's oral/nasal airway.
The humidifier uses Capillary Force Vaporization technology similar to that used in the PARI Hydrate V (Humidifier, Respiratory Gas (Direct Patient Interface); 868.5450, Product Code BTT) cleared under K072982. Water is drawn from a reservoir by a wick to a ceramic heater, which vaporizes the water resulting in comparable humidification output to the predicate devices. There is no heater plate and the water reservoir is not heated. Several humidification levels are available, with higher settings increasing the amount of water vapor. The humidifier is attached to the lower portion of the PAP through the use of magnets.
It includes the following components and accessories, which are all single patient reusable:
- . Filter Media
- P10 Battery ●
- Transcend 365 miniCPAP Unit .
- USB cable* ●
- Heater Cartridge .
- Wick
- Reservoir .
- Power supply PSA3 ●
- US 2-prong power cord
Here's a breakdown of the acceptance criteria and study information for the Transcend 365 miniCPAP Auto System, based on the provided FDA 510(k) summary:
1. Table of Acceptance Criteria and Reported Device Performance
The provided document does not explicitly present a table of acceptance criteria with corresponding performance numbers for the Transcend 365. Instead, it lists the various tests and assessments conducted and states that "Results of tests and assessments did not raise new safety or efficacy questions" and that the device "meets acceptance criteria." It also notes specific performance metrics for some features in the "Substantial Equivalence Comparison" table.
However, based on the provided comparison table and performance data section, we can infer some criteria and the device's meeting of those criteria:
| Feature/Test | Acceptance Criteria (Inferred from Predicate/Standard) | Reported Device Performance |
|---|---|---|
| Intended Use | Treatment of obstructive sleep apnea (OSA) in adults over 66 pounds (30 kg), with an option for humidification (similar to predicate devices). | "The Indications for Use statement for the Transcend 365 is not identical to the predicates; however, the differences do not alter the intended therapeutic use of the device nor do they affect the safety and effectiveness relative to the predicate." (Effectively, it meets the intended use of the predicates) |
| Biocompatibility | Compliance with ISO 10993-1, -5, -10, ISO 18562-1, -2, -3, -4, and FDA Guidance for biological evaluation. | "Evaluation and testing were conducted in accordance with the following standards and guidance documents: ISO 10993-1, -5, -10; FDA Guidance; ISO 18562-1, -2, -3, -4." "Testing and risk assessment confirm the biocompatibility of the new materials and device." "Results of tests and assessments did not raise new safety or efficacy questions." |
| Electrical Safety & EMC | Compliance with IEC 60601-1, -1-2, -1-6, -1-11, ISO 80601-2-70, ISO 80601-2-74, IEC 62133, UL 2054, RTCA/DO-160G (Section 21, Category M). | "The system complies with the following standards for electrical safety and EMC: IEC 60601-1, -1-2, -1-6, -1-11; ISO 80601-2-70, ISO 80601-2-74; IEC 62133; UL 2054; RTCA/DO-160G (Section 21, Category M)." "Results of tests and assessments did not raise new safety or efficacy questions." |
| Software Verification & Validation | Compliance with FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices" for a moderate level of concern. | "Software verification and validation testing were conducted and documentation was provided as recommended by FDA's Guidance... The software in this device is considered a moderate level of concern." "Results of tests and assessments did not raise new safety or efficacy questions." |
| Sound Power Level | Similar to predicate devices, and meeting acceptance criteria based on ISO 80601-2-70 (specific dBA unknown from document for predicate, but generally low noise for sleep therapy). | "46.2 dBA." "Tested according to 80601-2-70. Device emitted a sound power level of 46.2 dBA meeting acceptance criteria." (Predicate Transcend Auto: 34.6 dBA; Transcend Heated Humidifier: 29.1 dBA. While higher, it states it met acceptance criteria.) |
| Pressure Delivery (Therapy Pressure) | 4-20 cm H2O (Identical to primary predicate). | "4-20 cm H2O." "Identical to Primary Predicate." |
| Pressure Regulation | ± 1 cm H2O or 10%, whichever is greater (Identical to primary predicate). | "± 1 cm H2O or 10%, whichever is greater." "Identical to Primary Predicate." |
| Ramp Time | 0 – 45 min (Identical to primary predicate). | "0 – 45 min." "Identical to Primary Predicate." |
| IP Rating (Water Ingress Protection) | IP21 or higher (Predicate devices were IP21). | "IP22." "Similar. IP22 is a more rigorous test than IP21. Does not impact safety or effectiveness." |
| Humidifier Output (ISO 8185) | Providing heated humidified air in accordance with industry standard ISO 8185. | "Similar to predicate; Devices have a method for providing heated humidified air in accordance with industry standard (ISO 8185)." (Implies compliance) |
| Humidifier Run Time (with water reservoir) | Sufficient run time for typical sleep duration (predicate was 325 ml, lasting 8 hours). | "Humidifier contains water for 8 hours." (with 195 ml to fill line - effectively similar to predicate in duration despite smaller volume, likely due to Capillary Force Vaporization™ technology efficiency). |
| Mechanical/Reliability | Functional after component cycling, altitude testing, 20-degree spill test, out-of-water detection, and overall operational tests, without impacting safety or effectiveness. | Performed tests including "component cycling, pressure regulation, auto adjust functionality, sound power levels, flow, altitude testing, expiratory pressure relief, humidifier reservoir gas leakage, 20-degree spill test, out-of-water detection, humidifier runtime, and humidifier output." "Results of tests and assessments did not raise new safety or efficacy questions." (Specific numerical results are not provided for each, but the overall statement implies meeting criteria). |
| Usability | Compliance with IEC 60601-1-6, ensuring changes to user interface do not impact safety or effectiveness. | "Changes are not significant and do not impact safety or effectiveness as confirmed by usability testing (60601-1-6)." |
2. Sample Size Used for the Test Set and Data Provenance
The 510(k) summary does not specify sample sizes for specific test sets (e.g., patient data for algorithm testing). The performance data cited are primarily related to general device performance (biocompatibility, electrical safety, mechanical, software validation) rather than a clinical study involving patient data.
- Sample Size: Not explicitly stated for any clinical or patient-related test sets. The tests mentioned are largely bench-top, engineering, and compliance tests.
- Data Provenance: Not applicable in the context of clinical trials/patient data. The data provenance is from various engineering and laboratory testing according to international standards (e.g., ISO, IEC, UL, RTCA).
3. Number of Experts Used to Establish Ground Truth and Qualifications
This information is not provided in the summary, as the performance data submitted are primarily for engineering and regulatory compliance rather than clinical efficacy studies requiring expert reader ground truth. The device is a "non-continuous ventilator" (CPAP), whose core function for OSA treatment is well-established, and the submission focuses on demonstrating substantial equivalence to existing cleared devices rather than proving a new clinical efficacy claim through extensive clinical data/expert review.
4. Adjudication Method
Not applicable, as no clinical study requiring a ground truth established by expert adjudication is detailed in this 510(k) summary.
5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study was done
No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not explicitly mentioned or performed. This type of study is typically done for diagnostic or screening devices to compare human performance with and without AI assistance on a set of cases. The Transcend 365 is a therapeutic device (CPAP), and the submission focuses on its engineering performance and equivalence to predicate devices, not on physician interpretation or diagnostic aid effectiveness.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
Yes, a standalone performance of the algorithm (e.g., for auto-adjust functionality and AHI measurement) was implicitly done. The document states:
- "The Transcend 365 utilizes the same blower and the same algorithm as the Transcend Auto for respiratory event detection and therapy for sleep disordered breathing events."
- Under "Substantial Equivalence Comparison," for "Algorithm," it explicitly states: "Algorithm is identical to primary predicate" for "Auto-adjust," "AHI Measurement," and "Ramp."
- "Mechanical and Acoustic Testing" included "auto adjust functionality" as a tested parameter.
This indicates that the algorithm's performance, being identical to a previously cleared predicate device, was evaluated, but likely through engineering tests simulating respiratory events rather than a new full-scale clinical trial. The "results of tests and assessments did not raise new safety or efficacy questions" applies to this functionality as well.
7. The Type of Ground Truth Used
For the integrated algorithm's performance (respiratory event detection and therapy adjustment), the ground truth would have been established during the original clearance of the predicate device (Transcend Auto, K132127). For a CPAP device, this typically involves:
- Polysomnography (PSG) data: For validating the accuracy of event detection (apneas, hypopneas) and pressure titration algorithms against direct physiological measurements.
- Bench-top simulation: Using standardized breathing simulation equipment and models to test the device's response to various respiratory patterns and ensure accurate pressure delivery and adjustment.
For non-algorithmic aspects (e.g., biocompatibility, electrical safety, mechanical durability), the ground truth is established by the specifications of the relevant international standards (ISO, IEC, UL, RTCA).
8. The Sample Size for the Training Set
The 510(k) summary provides no information on the sample size for a training set. This is consistent with the nature of the submission, which relies on the algorithm being identical to a previously cleared predicate. Any algorithm training would have occurred during the development of the predicate device (Transcend Auto).
9. How the Ground Truth for the Training Set Was Established
As above, the 510(k) summary provides no information on how the ground truth for an algorithm training set was established. This process would have been part of the original development and clearance of the predicate Transcend Auto (K132127). For sleep apnea algorithms, ground truth for training data would typically involve:
- Expert-scored polysomnography (PSG) studies: A large dataset of sleep study recordings where respiratory events (apneas, hypopneas, RERAs) are manually identified and classified by sleep disorder experts according to established scoring rules (e.g., AASM guidelines). This forms the "ground truth" labels for algorithm development and training.
- Standardized physiological signals: Using calibrated sensors and data from patients or simulations that accurately represent the physiological changes associated with sleep-disordered breathing.
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(99 days)
The Transcend Auto provides positive airway pressure for treatment of obstructive sleep apnea (OSA) in adults weighing over 66 pounds (30 kg). The device is intended for home and hospital/institutional use.
The Transcend Auto is a microprocessor-controlled, blower-based system that generates positive airway pressure to support treatment of obstructive sleep apnea. It utilizes a differential pressure sensor connected to an internal pneumotach positioned in the airstream to determine flow levels. This flow signal, coupled with pressure sensing, is used to monitor breathing and adjust pressure. When interfaced with a mask, the system provides pressure from 4 to 20 cmHzO above the ambient atmospheric pressure to a patient's oral/nasal airway.
Here's a breakdown of the acceptance criteria and study information for the Transcend Auto device, based on the provided text:
Acceptance Criteria and Reported Device Performance
| Criteria | Acceptance Criteria (Predicate Device) | Reported Device Performance (Transcend Auto) |
|---|---|---|
| Pneumatic Performance: | ||
| Therapy Pressure (cm H2O) | 4-20 | 4-20 |
| Pressure Regulation | Transcend CPAP: ±1 cm H2O or 10%, whichever is greaterREMstar Auto CPAP: <10.0 cm H2O (±0.5 cm H2O), ≥10.0 to 20.0 cm H2O (±1.0 cm H2O) | ±1 cm H2O or 10%, whichever is greater (Identical to Transcend CPAP, equivalent to REMstar) |
| Ramp Time (min) | 0-45 (5 min increments) | 0-45 (5 min increments) |
| Environmental Performance: | ||
| Operating Altitude (ft) | Transcend CPAP: 0 to 8,000REMstar Auto CPAP: 0 - 7500 | 0 to 8,000 (Identical to Transcend CPAP) |
| Operating Temperature (°C / °F) | 5° C (41° F) to 35° C (95° F) | 5° C (41° F) to 35° C (95° F) |
| Operating Humidity (% relative humidity) | Transcend CPAP: 10 - 80%, non-condensingREMstar Auto CPAP: 15 - 95%, non-condensing | 10 - 80%, non-condensing (Identical to Transcend CPAP) |
| Shipping/Storage Temperature (°C / °F) | -20° C (-4° F) to 60° C (140° F) | -20° C (-4° F) to 60° C (140° F) |
| Shipping/Storage Humidity (% relative humidity) | Transcend CPAP: 10 - 90%, non-condensingREMstar Auto CPAP: 15 - 95%, non-condensing | 10 - 90%, non-condensing (Identical to Transcend CPAP) |
| Functional Features: | ||
| Auto Adjust | Transcend CPAP: NoREMstar Auto CPAP: Yes | Yes (Equivalent to REMstar) |
| Expiratory Pressure Relief | Transcend CPAP: NoREMstar Auto CPAP: Yes | Yes (Identical to REMstar) |
| Data Storage/Download | Transcend CPAP: PC connectionREMstar Auto CPAP: Data card; PC connection | PC connection (Identical to Transcend CPAP) |
| Electrical/Safety: | ||
| Power Supply (VAC, Hz) | 100-240 VAC, 50/60 Hz | 100-240 VAC, 50/60 Hz |
| IEC 60601 Classification | Class II, Type BF | Class II, Type BF |
| Other: | ||
| Warranty (years) | 2 | 2 |
| Intended Population of Use | Adult | Adult |
Study Information
-
Sample Size Used for the Test Set and Data Provenance:
- Sample Size: 41 adult patients.
- Data Provenance: The document does not explicitly state the country of origin. It does state that the study was a clinical evaluation, which implies it was prospective.
-
Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts:
- The document describes a clinical evaluation based on "apnea hypopnea index (AHI) during treatment." While an AHI is a clinical metric derived from sleep study data, the document does not specify if multiple independent experts reviewed the sleep studies to establish this "ground truth" or the qualifications of any such experts. It focuses on the device's performance in reducing AHI, rather than the process of establishing AHI as ground truth.
-
Adjudication Method for the Test Set:
- The document does not describe an adjudication method for establishing ground truth for the AHI. The focus is on the measured AHI during treatment rather than a consensus interpretation of raw data.
-
Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
- No, an MRMC comparative effectiveness study was not done in the context of human readers analyzing cases. This study was a clinical evaluation comparing two devices (Transcend Auto vs. REMstar Auto) based on their therapeutic effectiveness (AHI reduction) in patients. The comparison was of device performance, not human reader performance with or without AI assistance.
-
Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study:
- Yes, the clinical evaluation essentially represents a standalone performance. The Transcend Auto device automatically adjusts pressure without direct human intervention during the night. The study assessed the device's ability, by itself, to achieve non-inferiority in AHI compared to a predicate auto-CPAP device.
-
Type of Ground Truth Used:
- The ground truth used was clinical outcome data, specifically the apnea hypopnea index (AHI) during treatment. AHI is a measure of the severity of sleep apnea based on the number of apneas and hypopneas per hour of sleep. The study aimed to demonstrate non-inferiority in reducing this index.
-
Sample Size for the Training Set:
- The document does not provide information about a separate "training set" for the Transcend Auto's algorithm. The study described is a clinical validation study, not an algorithm development study where training sets are typically discussed.
-
How the Ground Truth for the Training Set Was Established:
- As no training set is described, there is no information on how its ground truth might have been established. It's common for such devices to rely on established physiological principles and prior clinical knowledge in their auto-adjusting algorithms, rather than training on a specific, explicitly defined dataset in the way a machine learning model would be.
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(135 days)
The Transcend Heated Humidifier is indicated for the humidification of the air delivered from a compatible Transcend positive airway pressure therapy device. The Humidifier is intended for single patient re-use in the home environment and in a hospital/institutional environment. The Humidifier is for use only as recommended by a physician.
The Transcend Heated Humidifier is a humidifier that is designed to humidify the air delivered to the airway during positive airway pressure (PAP) therapy with a compatible Transcend PAP device.
The provided document describes the acceptance criteria and supporting studies for the Transcend Heated Humidifier, a medical device for humidifying air during positive airway pressure (PAP) therapy.
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria for the Transcend Heated Humidifier are primarily based on compliance with recognized consensus standards and direct comparison to a predicate device (ResMed HumidAire 2i™). The document presents a comparison of various characteristics, some of which serve as performance criteria.
| Acceptance Criterion | Specifics/Standard | Reported Device Performance (Transcend Heated Humidifier) | Comparison to Predicate / Compliance |
|---|---|---|---|
| Standards Compliance | |||
| Electrical Safety | IEC 60601-1 | Compliant | Compliant |
| Electromagnetic Compatibility | IEC 60601-1-2 | Compliant with IEC 60601-1-2 | Identical (Predicate also compliant) |
| Usability | IEC 60601-1-6 | Not explicitly stated, but implied compliance through substantial equivalence | Implied compliance |
| Home Health Care Environment | IEC 60601-1-11 | Not explicitly stated, but implied compliance through substantial equivalence | Implied compliance |
| Respiratory Humidifiers | ISO 8185:2007 | Compliant (Stated for multiple parameters) | Confirmed compliance, predicate's compliance unknown |
| Biological Evaluation | ISO 10993-1 | Biocompatible: Yes | Identical |
| Risk Management | ISO 14971 | Implied compliance through risk assessments | Implied compliance |
| Performance Characteristics (compared to predicate or ISO 8185) | |||
| Indications for Use | Humidification of air for compatible Transcend PAP device, single patient re-use in home/hospital | The Transcend Heated Humidifier is indicated for the humidification of the air delivered from a compatible Transcend positive airway pressure therapy device. The Humidifier is intended for single patient re-use in the home environment and in a hospital/institutional environment. | Similar (Transcend is single-patient vs. predicate's multi-patient option). |
| Intended Population of Use | Adult | Adult | Identical |
| Compatible Devices | Transcend PAP device and associated accessories | Transcend PAP device and associated accessories | Similar (both are manufacturer-specific) |
| Disinfection | None (single patient re-use only) | Differs from predicate (which should be disinfected between patients) | |
| Cleaning | Distilled water using a mild detergent | Distilled water using a mild detergent | Identical |
| Sterilization | Not sterilized | Not sterilized | Identical |
| Pressure Regulation | Determined by compatible PAP device | Determined by compatible PAP device | Identical |
| Working Pressure Range | 4-20 cm H₂O | 4-20 cm H₂O | Identical |
| Humidifier Settings | 1-5 | Similar (Predicate has 1-6 settings) | |
| Inspiratory / Expiratory Pressure Drop | Meets ISO 8185 requirements | 0.375 cmH₂O at 50 L/min | Meets ISO 8185 |
| Gas Leak at Max Operating Pressure | Meets ISO 8185 requirements | 4.85 L/min | Meets ISO 8185 |
| Sound Power Level at 10 cm H₂O static pressure | Meets ISO 8185 requirements | 37 dB | Meets ISO 8185 |
| Maximum Heater Plate Temperature | Meets ISO 8185 requirements | 131 °F | Meets ISO 8185 (Predicate: 167°F) |
| Maximum Output Humidity | >95% | >95% | Similar (Predicate: 95%) |
| Maximum Gas Temperature | Meets ISO 8185 requirements | 77 °F | Meets ISO 8185 |
| Water Capacity | Enough water to last a minimum of 8 hours | 325 ml | Similar (Predicate: 400ml; both intended for 8+ hours) |
| Operating Temperature | Based on compatible PAP device | +41°F to +95°F | Similar (Predicate: +41°F to +104°F) |
| Operating Humidity | Based on compatible PAP device | 10 - 80% relative humidity, non-condensing | Similar (Predicate: 10-95% RH) |
| Shipping/Storage Temperature | -4° F to +140° F | Identical | |
| Gas Inlet Temperature Range | Based on compatible PAP device | +41°F to +95°F | Similar (Predicate: +41°F to +104°F) |
| Shipping/Storage Humidity | 10 - 90% relative humidity, non-condensing | Similar (Predicate: 15-95% RH) | |
| Power Supply | 100-240 VAC, 50/60 Hz | 100-240 VAC, 50/60 Hz | Identical |
| IEC 60601-1 Classification | Type BF or CF (ISO 8185 section 6.8.2-14) | Type BF | Subject device is compliant |
2. Sample Size Used for the Test Set and Data Provenance
The document does not detail specific sample sizes for particular performance tests. The studies conducted are described as "Device design was qualified through the following tests and assessments" which implies these were bench and lab-based tests, not human studies. Therefore, typical "sample sizes" (as in patient data) and "data provenance" (e.g., country of origin, retrospective/prospective) are not applicable in the context of this device's premarket submission, which focuses on engineering, safety, and performance characteristics rather than clinical diagnostic accuracy. The studies performed are:
- Electrical Safety
- Electromagnetic Compatibility
- Biocompatibility Assessment
- Cleaning Validation
- Software Validation
- Packaging and Shipping
- Performance: physical (cycling), resistance to flow, spillage, flow sensing, sound power level, humidification output, out of water shutdown, temperature, runtime, warm-up duration, and reservoir gas leak
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This section is not applicable. The device relies on physical and electrical performance data, and compliance with engineering standards (e.g., ISO 8185, IEC 60601-1). Ground truth is established by the specifications defined in these standards and by direct laboratory measurements, not by expert interpretation of patient data.
4. Adjudication Method for the Test Set
This section is not applicable. Adjudication methods (e.g., 2+1, 3+1) are typically used in clinical studies where multiple experts evaluate ambiguous cases to reach a consensus for ground truth. This submission focuses on engineering and performance testing, where outcomes are determined by objective measurements against predefined criteria.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. This type of study is typically performed for diagnostic devices where human readers (e.g., radiologists) interpret images or data, and their performance with and without AI assistance is compared. The Transcend Heated Humidifier is a therapeutic accessory, not a diagnostic device involving human interpretation of complex data.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
This section is not applicable in the typical sense of AI algorithms. The "device" itself operates "standalone" in its function as a humidifier, based on its internal programming and hardware. However, it's not an AI algorithm in the context of data analysis or diagnostic support where a "human-in-the-loop" would be relevant. The software validation mentioned ensures the device's internal algorithms and controls function correctly, which is a standalone performance test.
7. The Type of Ground Truth Used
The ground truth for the device's performance is based on:
- Engineering Standards and Specifications: Metrics defined by standards such as ISO 8185 (e.g., maximum output humidity, pressure drop, gas leak, sound power level, temperatures).
- Predicate Device Characteristics: Direct comparison of physical, functional, and safety attributes against a legally marketed predicate device.
- Laboratory Measurements: Objective measurements of the device's performance against the specified criteria (e.g., humidification output, temperature, water capacity).
8. The Sample Size for the Training Set
This section is not applicable. This device is not an AI/machine learning model where a "training set" of data would be used to develop an algorithm. Its design and validation are based on traditional engineering principles and testing.
9. How the Ground Truth for the Training Set Was Established
This section is not applicable as there is no "training set" in the context of this device.
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