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510(k) Data Aggregation

    K Number
    K221024
    Date Cleared
    2023-06-20

    (440 days)

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

    Thorasys Thoracic Medical Systems, Inc.

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

    The tremoflo C2 Airwave Oscillometry System is intended to measure respiratory system impedance using the Forced Oscillation Technique (FOT). The tremoflo C2 Airwave Oscillometry System is intended for use with pediativ and adult patients 4 years of age or older. The device is designed to be used by pulmonologists, general practitioners, nurses, respiratory therapists, laboratory technologists, medical researchers and similarly trained personnel in hospitals, clinics, and private physician offices.

    Device Description

    The tremoflo C2 Airwave Oscillometry System (tremoflo C2) is a portable lung function testing device that implements methods known per the Forced Oscillation Technique (FOT), or oscillometry, to assess lung function in humans. The Forced Oscillation Technique (FOT) is a non-invasive test that provides a full report of lung mechanics per the FOT. In general, the FOT usually consists of superimposing given external multi-frequency sinusoidal excitation small pressure waves (1-3 cmH₂O peak) onto the normal breathing of the patient through the device and then deriving the mechanical properties from the patient's mouth pressure and airflow response while breathing. The main outcome reported by FOT is the mechanical impedance of the respiratory system which is the complex ratio between pressure and airflow at the given excitation frequencies.

    The main tremoflo C2 Unit is a lightweight handheld device. It contains electronics, pressure and flow sensors, and the actuator providing the forced oscillations. The tremoflo software is a complete standalone software package for patient management, testing, result analysis, and presentation.

    During use the operator holds the handheld device using the ergonomic handle while the patient is seated, wearing a standard nose clip and with hands on cheeks. To perform the test, the patient then breathes quietly through the device into a standard single use Pulmonary Function Testing (PFT) filter connected at the front of the C2 Unit via the PFT filter interface. The tremoflo C2 is not intended to be used as a stand-alone diagnostic device.

    AI/ML Overview

    The provided text describes the Thorsys tremoflo C2 Airwave Oscillometry System and its substantial equivalence to a predicate device (tremoFlo C100 Airwave Oscillometry System) as determined by the FDA. The document outlines changes made to the device and provides performance data to support its claims.

    Here's an analysis of the acceptance criteria and study information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document doesn't present a formal table of "acceptance criteria" against "reported device performance" in the typical sense of numerical thresholds for clinical endpoints. Instead, it focuses on demonstrating equivalence to a predicate device, primarily through technical specifications and verification/validation testing against established standards and recommendations.

    However, based on the "Performance Data" section and the comparison table, we can infer some criteria and reported performance:

    Acceptance Criterion (Inferred from testing)Reported Device Performance (tremoflo C2)
    Fundamental Scientific TechnologyIdentical to C100 (Forced Oscillation Technique and Pneumotach per ERS FOT recommendations)
    Pneumotach Flow RangeIdentical to C100 (± 2.5 L/s)
    Flow ResolutionIdentical to C100 (±1.4 ml/s)
    Flow LinearityIdentical to C100 (± 2% up to 1.0 L/s)
    Common Mode Rejection Ratio (CMRR)Identical to C100 (Dynamic software compensation signal processing)
    Device Load to PatientModified: 1.1 ± 5% cmH2O.s/L at 1 L/s (C100: 1.0 ± 5% cmH2O.s/L at 1 L/s). Discussion: Small difference, within potential variation of bacterial/viral filters, does not raise different questions of safety and effectiveness.
    Volume RangeIdentical to C100 (+3 Liters)
    Volume AccuracyIdentical to C100 (
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    K Number
    K170185
    Date Cleared
    2017-09-12

    (232 days)

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

    THORASYS Thoracic Medical Systems, Inc.

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

    The tremoFlo C-100 Airwave Oscillometry System is intended to measure respiratory system impedance using the Forced Oscillation Technique (FOT). tremoFlo C-100 Airwave Oscillometry System is intended for use with pediatric and adult patients 4 years of age or older. The device is designed to be used by pulmonologists, general practitioners, nurses, respiratory therapists, laboratory technologists, medical researchers and similarly trained personnel in hospitals, clinics, and private physician offices.

    Device Description

    The tremoFlo C-100 Airwave Oscillometry System (AOS) is a portable lung function testing device that implements methods known per the Forced Oscillation Technique (FOT) to assess lung function in humans. The Forced Oscillation Technique (FOT) is a non-invasive test that requires minimal patient effort and cooperation and provides a full report of lung mechanics per the FOT. In general, the FOT usually consists of superimposing given external multi-frequency sinusoidal excitation small pressure waves (1-3 cmH2O peak to peak) onto the normal breathing of the patient through the device and then deriving the mechanical properties from the patient's mouth pressure and airflow response while breathing. The main outcome reported by FOT is the mechanical impedance of the respiratory system which is the complex ratio between pressure and airflow at the given excitation frequencies.

    The tremoFlo C-100 Unit is a lightweight handheld device connected to a cradle unit. The handheld unit contains electronics, pressure and flow sensors, and the actuator providing the forced oscillations which is connected to the cradle unit via a custom cable. The tremoFlo software is a complete stand-alone software package for patient management, testing, and result analysis and presentation.

    AI/ML Overview

    The provided text describes the Tremoflo C-100 Airwave Oscillometry System, a medical device used to measure respiratory system impedance. Here's a breakdown of the acceptance criteria and the study information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly state formal "acceptance criteria" in a table format with corresponding "reported device performance." However, it presents a Predicate Product Comparison table that lists various technical features and specifications of the Tremoflo C-100 and compares them to its predicate device, the Resmon PRO FULL. The "Comparison" column in this table effectively acts as an assessment against benchmarked performance (the predicate device) or relevant standards (ERS FOT recommendations).

    Below is a summary derived from the provided comparison, highlighting what could be interpreted as acceptance criteria based on equivalence or standards, and the TremoFlo's reported performance against these.

    Table: Derived Acceptance Criteria and Reported Device Performance

    Feature/SpecificationAcceptance Criteria (Derived or Standard)TremoFlo C-100 Reported Performance
    Indications for UseEquivalent to Predicate: Measure respiratory system impedance using FOT for pediatric and adult patients (4+ years), used by trained personnel.Identical to predicate.
    Fundamental Scientific TechnologyEquivalent to Predicate: Forced Oscillation Technique and Pneumotach per ERS FOT recommendations.Identical to predicate.
    Pneumotach Flow RangeSufficient for FOT measurements (Predicate: ± 2 L/s).± 2.5 L/s (Increased flow range compared to predicate).
    Flow ResolutionSufficient for FOT measurements (Predicate: ± 4.6 mL/s).± 1.4 ml/s (Slightly better than predicate).
    Flow LinearityWithin ranges to provide equivalent performance per bench testing (Predicate: ± 2% up to 1.5 L/s).± 2% up to 1.0 L/s (Differences are small and still within ranges to provide equivalent performances in both devices per bench testing).
    Common Mode Rejection Ratio (CMRR)Provide accurate and reproducible results equivalent to predicate (>60dB over entire range of forcing frequencies).Alternate dynamic software compensation (Provided accurate and reproducible results equivalent to those provided by the predicate based on performance testing).
    Device Load to Patient
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