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510(k) Data Aggregation

    K Number
    K223818
    Date Cleared
    2023-05-25

    (155 days)

    Product Code
    Regulation Number
    868.1760
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Vitalograph Ireland Ltd.

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

    The Model 9160 VitaloQUB is a whole-body plethysmograph device, when used with the Vitalograph Model 9100, is designed for lung function testing on adults and pediatrics, 6 years and older, by trained medical healthcare professionals in a variety of professional healthcare environments e.g., primary care, hospitals, and pharmaceutical research centers.

    Device Description

    The proposed Model 9160 VitaloQUB incorporates the cleared Model 9100 (K221030) with integrated LCD display and ComPAS2 software (K213872).

    The ComPAS2 software controls valves and reads unprocessed data from the sensors in the Model 9100 and from Model 9160. The ComPAS2 software then determines respiratory parameters including the 2 new parameters.

    The ComPAS2 software is unchanged from K213872. The Model 9160 and Model 9100 firmware does not determine any respiratory parameters.

    The Model 9160 is adding 2 additional parameters:

    • TVG – Thoracic Gas Volume
    • Raw Airway resistance
    AI/ML Overview

    The provided text describes the regulatory clearance for the VitaloQUB Model 9160, a whole-body plethysmograph device. However, it does not contain specific details on the acceptance criteria or a dedicated study report that demonstrates the device explicitly meets numerical acceptance criteria. The text focuses on establishing substantial equivalence to predicate devices.

    Here's an analysis based on the information available and what is missing:

    The submission states that "Performance testing demonstrated that the subject device met its acceptance criteria," and then lists the types of testing performed. However, it does not provide the specific numerical acceptance criteria or the reported device performance for these criteria.

    1. Table of acceptance criteria and the reported device performance:

    Parameter/Test TypeAcceptance CriteriaReported Device Performance
    Thoracic Gas Volume (VTG)Not explicitly stated in the provided textNot explicitly stated in the provided text
    Airway Resistance (Raw)Not explicitly stated in the provided textNot explicitly stated in the provided text
    FVC, SVC, MVV, CPF, RMS, SNIP, DLCO, MBN2, SBN2Not explicitly stated as specific acceptance criteria for the new device, but implied to meet predicate performanceNot explicitly stated as specific performance for the new device, but implied to meet predicate performance
    Flow accuracy± 2 % over range of -14 to + 14 L/sSubject Device: ± 2 % over range of - 14 to + 14 L/s (Stated in comparison table, implying performance matches requirement)
    Volume accuracy± 2.5 % or 0.050 LSubject Device: ± 2.5 % or 0.050 L (Stated in comparison table, implying performance matches requirement)
    CO Sensor Accuracy±1 % of full scaleSubject Device: ±1 % of full scale (Stated in comparison table, implying performance matches requirement)
    CO2 (NDIR) Sensor Accuracy±2.5 % of full scaleSubject Device: ±2.5 % of full scale (Stated in comparison table, implying performance matches requirement)
    CH4 Sensor Accuracy±2.5% of full scaleSubject Device: ±2.5% of full scale (Stated in comparison table, implying performance matches requirement)
    O2 Sensor Accuracy±0.2% of Full ScaleSubject Device: ±0.2% of Full Scale (Stated in comparison table, implying performance matches requirement)
    CO2 (N2 washout) Sensor Accuracy±0.1% of Full ScaleSubject Device: ±0.1% of Full Scale (Stated in comparison table, implying performance matches requirement)
    Compliance with Performance StandardsISO 23747:2015, ISO 26782:2009, ATS/ERS: 2002, 2005, 2013, 2017 and 2019Subject Device: Complies with these standards (Implied by inclusion in comparison table and statement of updated performance testing)
    Electrical SafetyES 60601-1Subject Device: Complies with ES 60601-1 (Implied by inclusion in comparison table and statement of updated performance testing)
    EMCIEC 60601-1-2Subject Device: Complies with IEC 60601-1-2 (Implied by inclusion in comparison table and statement of updated performance testing)
    Cleaning High-level disinfectionNot explicitly statedPerformance testing for cleaning/disinfection was completed (leveraged from predicate)
    SoftwareVerification and ValidationVerification and Validation completed
    BiocompatibilityNot explicitly statedBiocompatibility testing completed (leveraged from predicate)
    TransportationNot explicitly statedTransportation testing completed

    Missing Information: For VTG and Raw, while the document states performance testing was done, the specific acceptance criteria and the results demonstrating compliance are not provided. The accuracy values listed in the table are copied directly from the "Subject Model 9160" column, indicating that these are the device's inherent specifications, and the comparison section implies they are similar to or meet expectations based on the predicate.

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):

    This information is not provided in the document. The text mentions "Bench testing" but does not detail the sample sizes for any of the performance tests, nor does it specify if any clinical data with human subjects (and thus data provenance) was used for direct performance evaluation of VTG and Raw measurements. The comparison tables focus on technological characteristics and principle of operation similarities to predicates.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience):

    This information is not provided in the document. The device outputs objective physiological measurements, rather than interpretations requiring expert consensus as ground truth. If clinical studies were performed for the new parameters (VTG, Raw), the method of establishing ground truth would depend on the study design. However, the document provided does not detail such clinical studies or the involvement of experts in establishing ground truth.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

    This information is not provided in the document. Given the nature of the device (measuring physiological parameters rather than rendering diagnoses or classifications), an adjudication method for a test set as described is unlikely to be directly applicable in the same way as for image-based diagnostic AI. If human subject studies were conducted to compare measurements, adjudication of patient conditions might be relevant, but this is not detailed.

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:

    This is not applicable to this device. The VitaloQUB Model 9160 is a pulmonary function measurement device. It measures physiological parameters and does not involve "readers" or "AI assistance" in the diagnostic interpretation sense for which MRMC studies are typically performed. The device itself performs the measurements and calculations (via the ComPAS2 software), it does not assist human interpretation of complex data (like images) in a way that would be quantified by an MRMC study.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

    The device is inherently a standalone measurement system in terms of calculating the parameters. The ComPAS2 software, which is part of the system, outputs the respiratory parameters. This is the "algorithm only" performance. The document states: "The ComPAS2 software controls valves and reads unprocessed data from the sensors in the Model 9100 and from Model 9160. The ComPAS2 software then determines respiratory parameters...". The performance testing mentioned ("Bench testing", "ATS / ERS (2002, 2005, 2013, 2017 and 2019) Static condition") assesses the accuracy of these measurements directly from the device/software. Specific performance for VTG and Raw measurements would have been assessed in this standalone manner, but the numerical results are not provided.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

    For physiological measurement devices, the "ground truth" is typically established by physical standards, calibration gases, and established reference methods or simulated physiological conditions that adhere to recognized industry standards (e.g., ATS/ERS standards). The document mentions compliance with various ISO and ATS/ERS standards, which dictate the methods and accuracy requirements for such measurements. For example, gas concentrations for DLCO are compared against medical-grade gas mixes, and flow/volume against calibrated instruments.

    8. The sample size for the training set:

    This information is not provided. As the device is a measurement instrument incorporating software (ComPAS2) for calculations based on physical readings, it's not described as an AI/ML device that requires a "training set" in the conventional sense (e.g., for pattern recognition or classification). The software implements algorithms for physiological calculations rather than learning from data in a machine learning paradigm.

    9. How the ground truth for the training set was established:

    This information is not provided, and likely not applicable as the device is not described as an AI/ML system requiring a training set with ground truth in the context of machine learning. The algorithms are based on established physiological principles and equations.

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    K Number
    K221030
    Date Cleared
    2022-07-15

    (99 days)

    Product Code
    Regulation Number
    868.1890
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Vitalograph Ireland Ltd.

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

    The Model 9100 PFT/DICO is a pulmonary function testing device which uses Morgan Scientific's ComPAS2 software to measure subject respiratory parameters including FVC, SVC, MVV, CPF, RMS, SNIP, DLCO, MBN2 and SBN2.

    The device is PC-based and designed for lung function testing on adults and pediatrics, 6 years and older, in a variety of professional healthcare environments e.g., primary care, hospitals, pharmaceutical research centers and physicians' offices.

    The Model 9100 PFT/DICO is intended for the assessment of respiratory function through the measurement of dynamic lung volumes i.e., spirometry and other lung functions i.e., diffusing capacity.

    Device Description

    The Model 9100 PFT/DICO is composed of various sensors and valves with associated low level firmware. The firmware interfaces with the Morgan Scientific's ComPAS2 software (K213872) that resides on an on-board computer. The Model 9100 also provides for user input and present resulting data on an integral display.

    The ComPAS2 software controls valves and reads unprocessed data from the sensors in the Model 9100then determines respiratory parameters including FVC, SVC, MVV, CPF, RMS (MIP and MEP), SNIP, DLCO, MBN2 and SBN2. The Model 9100 PFT/DICO firmware does not determine any respiratory parameters.

    The ComPAS2 software uses flow and volume from the Vitalograph pneumotachograph spirometer to display the flow and volume information measured directly from patient effort. ComPAS2 also utilizes gas analyzer readings from the Model 9100 patient test benchmark to display dilution lung volume data and single / multi breath diffusion data measured directly from patient effort. This information is then provided in a report format.

    AI/ML Overview

    The provided text describes the regulatory clearance of the Vitalograph Model 9100 PFT/DICO, a pulmonary function testing device, and its substantial equivalence to a predicate device. However, it does not contain information about a study proving the device meets acceptance criteria related to a machine learning or AI model's performance.

    The document outlines performance testing conducted for the device's electrical, mechanical, and biocompatibility aspects, as well as software verification and validation. It explicitly states that the device uses "Morgan Scientific's ComPAS2 software to measure subject respiratory parameters," but there's no indication that this software includes an AI or machine learning component that would require a study with human-in-the-loop performance, expert ground truthing, or MRMC studies typically associated with AI/ML medical devices.

    Therefore, many of the requested details about acceptance criteria for an AI model's performance and associated study specifics (sample size for test/training, number of experts, adjudication, MRMC, standalone performance, ground truth type) cannot be extracted from this document.

    Instead, the document focuses on demonstrating substantial equivalence to a predicate device based on similar indications for use, technological characteristics, and principles of operation, supported by standard bench testing and software validation.

    Here's an attempt to answer the request based only on the provided text, highlighting the absence of AI/ML-specific details:

    Device: Vitalograph Model 9100 PFT/DICO

    Study Type: This document describes a 510(k) premarket notification for substantial equivalence, supported by bench testing, software verification/validation, and compliance with various standards. It is not an AI/ML performance study. The "study that proves the device meets the acceptance criteria" refers to the entire body of evidence submitted for 510(k) clearance, rather than a specific AI model's performance study.


    1. A table of acceptance criteria and the reported device performance

    The document defines performance specifications and states that testing supported the safety and performance, implying these specifications were met. The specific "acceptance criteria" for the overall device's performance are embedded in the compliance with standards and the "similar" comparisons to predicate/reference devices.

    Metric (as described in comparison table)Subject Device (Model 9100 PFT/DICO) PerformancePredicate/Reference Device Performance (if explicitly stated as acceptance criteria)Conclusion (based on comparison)
    Flow sensor Flow range± 14 L/sPredicate: ± 16 L/sSimilar (implicitly within acceptable range)
    Flow sensor Accuracy± 2.5% or 0.050 L (for flow)Predicate: Greater of ± 2% or 0.050 LSimilar in accuracy
    Volume accuracy± 2 % over range of -14 to + 14 L/sPredicate: Greater of ± 2% or 0.020 L/sSimilar in accuracy
    Flow resistance
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    K Number
    K212938
    Date Cleared
    2022-01-26

    (133 days)

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

    Vitalograph Ireland Ltd.

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

    The intended use of the Vitalograph Model 6000 Alpha is the simple assessment of respiratory function through the measurement of dynamic lung volumes i.e. spirometry. The device measures patient respiratory parameters including FVC, FEV1, FEV6, PEF, MVV and VC. The device is designed to be operated by medical professionals trained in respiratory and lung function testing on adults and pediatrics, 5 years and older, in a variety of professional healthcare environments, e.g. primary care, hospitals and occupational health centers.

    Device Description

    The Vitalograph Alpha Model 6000 is a desktop spirometer which measures the following lung function parameters FVC, FEV1, FEV6, PEF, MVV and VC in professional healthcare environments, e.g., primary care, hospitals and occupational health centers. It is externally powered from a Class II, IEC 60601-1 compliant medical power supply. It contains a rechargeable battery powered from the external supply. The device also contains an integral 4 inch thermal printer. The device has a USB port for connection to other devices and an SD card slot for backup of stored data. The device also has wired ethernet and Wi-Fi for connection to a hospital network. Its primary functions and technology are: - Spirometry measurements using single breath and multiple-breath testing techniques, the display and recording of measured lung volumes and flow rates (including FVC, FEV1, FEV6, PEF, MVV and VC) are identical to the predicate device - Record subject data - Storage of data and test results on unit for later printing or export to Spirotrac software which was cleared under 510(k) K201562. The Flowhead utilizes a Fleisch Pneumotachograph. The operating principle is identical to the predicate K200550 - User Interface navigation via touch screen display

    AI/ML Overview

    The provided text describes the regulatory clearance of the Vitalograph Model 6000 Alpha spirometer and details its comparison to a predicate device. It primarily focuses on the device's technical specifications, regulatory compliance, and non-clinical performance testing rather than a study proving the device meets acceptance criteria in the context of an AI/ML model for clinical decisions.

    Based on the provided document, here's an analysis of the acceptance criteria and study that proves the device meets them:

    This document is for a diagnostic spirometer, which is a physical medical device that measures lung function. It is not an AI/ML device for clinical decisions. Therefore, many of the typical "acceptance criteria" and "study types" associated with AI/ML devices (like MRMC studies, ground truth establishment by experts, adjudication, sample size for training sets, etc.) do not apply in this context.

    The "acceptance criteria" for a physical diagnostic device like a spirometer primarily revolve around its technical performance specifications, electrical safety, EMC, and compliance with relevant international standards.


    1. A table of acceptance criteria and the reported device performance:

    The document doesn't present a formal "acceptance criteria" table in the AI/ML sense. Instead, it provides a "Comparison of Subject and Predicate Devices" (Table 1) which implicitly serves as a comparison against established performance benchmarks and standards for spirometers. The performance data section further details the testing performed to demonstrate compliance.

    Here's an attempt to derive "acceptance criteria" from the Specifications reported in the comparison table and the Performance Data section:

    Acceptance Criteria (Derived from Standards/Predicate)Reported Device Performance (Vitalograph Model 6000 Alpha)
    Spirometry Measurement ParametersFVC, FEV1, FEV6, PEF, MVV, VC
    Back pressureLess than 0.1kPa/L/second @ 14L/s
    Volume detectionFlow integration sampling @ 100Hz
    Maximum displayed volume10L
    Volume accuracy± 2.5%
    Flow AccuracyFlow ± 10% or 0.3 L/s
    Max. flow rate± 16 L/s
    Min. flow rate± 0.02 L/s
    Operating temperature range10 – 40 °C
    BiocompatibilityAcceptable per ISO 10993-5, 10, 18, and ISO 18562-2, 3 (with toxicological risk assessment)
    Electrical SafetyComplies with AAMI ANSI ES 60601-1: 2005 + A1: 2012
    EMCComplies with IEC 60601-1-2:2014
    Software Level of ConcernModerate
    Performance Standards ComplianceATS/ERS (2019), ISO 23747, ISO 26782

    2. Sample sized used for the test set and the data provenance:

    • Test Set Sample Size: Not applicable in the context of patient data or clinical test sets for AI/ML validation. The testing described is bench testing using standardized methods and controlled inputs (e.g., flow/volume simulators, environmental chambers).
    • Data Provenance: Not applicable as it's not a data-driven AI/ML study. The "data" here comes from direct measurements by the device itself under test conditions.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    • Not applicable. Ground truth for device performance (e.g., whether a spirometer accurately measures volume) is established by calibration against known, traceable standards and instruments, not by human expert interpretation of results. The "ground truth" for spirometry measurements comes from the physical and engineering principles of the measurement itself and the standards against which it is calibrated and tested.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

    • Not applicable. Adjudication is a process used in studies where human interpretation or clinical judgment is involved, particularly for establishing a consensus "ground truth" from multiple readers. This is a technical device performance test, not a reader study.

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:

    • No. An MRMC study is relevant for AI/ML diagnostic aids where human readers interpret medical images or data. This is a fundamental diagnostic device, not an AI assistance tool for human readers.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

    • The device itself is a "standalone" diagnostic instrument. Its performance is evaluated intrinsically through bench testing against specified standards and its predicate, rather than being an "algorithm only" being evaluated for clinical decision support. Its core function is to measure parameters directly, not to provide an automated clinical interpretation that would fall under "algorithm only" performance in the AI/ML sense.

    7. The type of ground truth used:

    • The "ground truth" for the device's technical performance is based on established engineering standards and reference measurements, such as those defined by ATS/ERS (2019), ISO 23747, and ISO 26782. These standards specify how spirometers should measure flow and volume and define the acceptable accuracy limits. For electrical safety and EMC, the ground truth is compliance with the relevant IEC/AAMI standards.

    8. The sample size for the training set:

    • Not applicable. This device does not use machine learning, so there is no "training set."

    9. How the ground truth for the training set was established:

    • Not applicable. As there is no training set for machine learning.
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    K Number
    K201562
    Device Name
    Spirotrac
    Date Cleared
    2020-10-14

    (126 days)

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

    Vitalograph Ireland Ltd.

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

    The Vitalograph Spirotrac Model 7000 is a PC-based software application intended to be used as a spirometer or connect to compatible Vitalograph or third party devices to acquire, view, store and print the device output. The product is designed for use on adults and pediatrics, 5 years and older, in a variety of professional healthcare environments, e.g. primary care, hospitals and occupational health centers under the supervision of a healthcare provider.

    Device Description

    The Vitalograph Spirotrac Model 7000 provides a secure PC based medical device software application for creating, adding and recalling subjects and performing Spirometry testing on those subjects. Spirotrac will also link to compatible third party devices to read and display the output from these devices to allow the information to be retained with the subject.

    Spirotrac integrates and reads / displays information from compatible Pulse Oximetry devices, Blood Pressure and Weight measurements devices, and ECG test devices.

    Its primary functions are:

    Spirometry measurements using single breath and multiple-breath testing techniques, the display and recording of measured lung volumes and flow rates (including VC, FIVC, FVC) and its subdivisions. The unit also allows for the measurements of Inspiratory and Expiratory Flow rates (PEF, FEFx, etc.), indirect measures (e.g. MVV) and Pre-post testing (e.g. Challenge, work shift).

    Record subject demographic data as input.

    Interact with existing Vitalograph and compatible third party devices via standard PC communication methods for download of data for storage within the Spirotrac database.

    Navigation is allowed via the use of a standard PC keyboard and mouse or touchscreen.

    AI/ML Overview

    The Vitalograph Spirotrac Model 7000 is a PC-based software application intended to function as a spirometer or connect to compatible devices to acquire, view, store, and print device output. It is designed for use on adults and pediatrics (5 years and older) in professional healthcare settings.

    Here's an analysis of the acceptance criteria and the study that proves the device meets them:

    1. A table of acceptance criteria and the reported device performance

    The provided document does not explicitly list acceptance criteria in a table format with specific quantitative thresholds. Instead, it states that "Performance testing demonstrated that the subject device met its acceptance criteria" and details the standards and guidance documents followed. The acceptance criteria can be inferred from the compliance with these standards and regulatory guidance.

    The device's performance is reported as meeting the requirements of:

    • ATS/ERS (2005) waveform simulator testing
    • ISO 23747:2015 - Anaesthetic and respiratory equipment -- Peak expiratory flow meters
    • ISO 26782:2009 - Anaesthetic and respiratory equipment - Spirometers intended for the measurement of time forced expired volumes in humans.

    Inferred Acceptance Criteria & Reported Performance:

    Acceptance Criteria CategoryTarget / Standard (Inferred)Reported Device Performance
    Spirometry Measurement Accuracy & PerformanceCompliance with ATS/ERS (2005) waveform simulator testing standards for spirometry parameters (e.g., FVC, PEF, FEFx, VC, FIVC, etc.).
    Compliance with ISO 23747:2015 for Peak Expiratory Flow (PEF) measurements.
    Compliance with ISO 26782:2009 for spirometers measuring time forced expired volumes.
    Data displayed and limits set (user or default) must align with these performance standards."Performance testing demonstrated that the subject device met its acceptance criteria."
    "Note that this testing was performed to demonstrate that the data displayed along with any limits set by user or by default, are aligned with these performance standards."
    The device performs spirometry measurements using single breath and multiple-breath techniques, and displays/records measured lung volumes and flow rates.
    Software Verification & Validation (V&V)Compliance with "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices, May 2005" and "General Principles of Software Validation Guidance. January 2020.""Verification and Validation was performed following Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices, May 2005 and General Principles of Software Validation Guidance. January 2020."
    Interoperability & Data Handling (acquiring, viewing, storing, printing data from compatible Vitalograph or third-party devices, subject demographic data, network operation, data import/export, email export, database management)Functionality as described in the device description and comparison table, maintaining compatibility and data integrity.Demonstrated through "Same" comparisons with the predicate device across various functionalities (e.g., ECG waveforms, ABPM, Spot Oximetry, Subject Management, Report Printing, Trending Graphs, Predicted Value Equations, Population Group Management, Data Import/Export, Database Management).
    Operating System CompatibilitySupport for Windows 7, 8, and 10.Supports Windows 7, 8, and 10.
    Patient PopulationAdults and pediatrics 5 years and older.Designed for use on adults and pediatrics, 5 years and older.

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    The document describes non-clinical testing involving waveform simulator testing (ATS/ERS) and compliance with ISO standards (ISO 23747, ISO 26782). These are typically bench tests using standardized simulated waveforms, not patient data. Therefore, there is no sample size of human subjects mentioned for the test set, nor is there information on data provenance (country, retrospective/prospective), as the testing appears to be entirely technical/engineering in nature (software V&V, bench testing against standards).

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

    Since the testing involved bench testing against international standards and simulated waveforms, there were no human experts establishing ground truth in the typical sense of clinical interpretation. The "ground truth" for these tests is implicitly defined by the parameters and specifications of the ATS/ERS and ISO standards themselves.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    As the testing was non-clinical and involved compliance with technical standards and simulated waveforms, there was no adjudication method described or likely needed for human discrepancies. The performance was measured against predefined technical specifications.

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

    No MRMC comparative effectiveness study was done. The device is a diagnostic spirometer software, not an AI-assisted diagnostic tool that aids human readers in interpreting complex images or data. Its primary function is to acquire, display, store, and print spirometry data, and interface with existing medical devices. The document does not suggest any AI components that perform diagnostic interpretation requiring human-in-the-loop studies.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    The entire performance evaluation described is essentially a standalone (algorithm/software only) assessment against technical standards and simulator outputs. The V&V of the software itself and its ability to process and display data in compliance with ATS/ERS and ISO standards represents its "standalone performance."

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    The ground truth used for the performance testing was based on international technical standards and simulated waveforms:

    • ATS/ERS (2005) waveform simulator
    • ISO 23747:2015 specifications
    • ISO 26782:2009 specifications

    These standards define the expected correct output for various spirometry maneuvers and parameters.

    8. The sample size for the training set

    This device did not undergo a training phase in the context of machine learning or AI. It is a software application whose functionality is based on established algorithms for spirometry and data management. Therefore, there is no training set sample size described.

    9. How the ground truth for the training set was established

    As there was no training set in the context of machine learning, there is no information on how ground truth for a training set was established. The software's "knowledge" or "rules" are based on the implementation of well-established medical and engineering principles for spirometry and data processing, not on learning from a labeled dataset.

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    K Number
    K200550
    Date Cleared
    2020-07-27

    (146 days)

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

    Vitalograph Ireland Ltd.

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

    The Vitalograph Model 2120 In2itive eDiary device is a battery-operated spirometer which measures three basic patient respiratory parameters (FVC, MVV and VC). The Vitalograph Model 2120 In2itive eDiary is a handheld spirometer designed for lung function testing in a variety of environments such as hospital wards, health centres and private homes. It is intended for Adults and pediatrics, 5 years and older.

    The Vitalograph Model 2120 In2itive eDiary can be configured as a stand-alone spirometer or connected to a printer.

    Device Description

    The Vitalograph Model 2120 In2itive eDiary is a hand-held, battery-operated spirometer which measures the following lung function parameters FVC, MVV and VC in hospital, clinical and home settings.

    It can be configured as a standalone spirometer or connected to a printer. Its primary functions and technology are:

    • . Spirometry measurements using single breath and multiple-breath testing techniques, the
    • display and recording of measured lung volumes and flow rates (including FVC, VC, ● MVV) and other parameters which are subsets of these measured parameters.
    • . Record subject data. Storage of data and test results on unit for later printing or export to Spirotrac software
    • The Flowhead utilizes a Fleisch Pneumotachograph.
    • User Interface navigation via five buttons (Up, Down, Enter/Select, Cancel/Esc and . Power On/Off) or an optional touch screen.
    AI/ML Overview

    The Vitalograph Model 2120 In2itive eDiary is a diagnostic spirometer. The device's acceptance criteria and the study proving it meets these criteria are outlined below.

    1. Acceptance Criteria and Reported Device Performance:

    The acceptance criteria are established by various international standards for spirometry and medical device safety. The reported device performance is compared to these standards and the predicate device (Vitalograph Model 2120).

    FeatureAcceptance Criteria (Predicate / Standard)Reported Device Performance (Subject Device)Outcome
    Indications for UseMeasures FVC, MVV, VC for adults and pediatrics (5+ years) in various environments (hospital, health centers, private homes). Stand-alone or connected to printer.Measures FVC, MVV, VC for adults and pediatrics (5+ years) in various environments (hospital, health centers, private homes). Stand-alone or connected to printer.Identical
    Fundamental TechnologyFleisch Pneumotachograph type Flowhead connected to transducer, with signal-processing circuitry.Fleisch Pneumotachograph type Flowhead connected to transducer, with signal-processing circuitry.Same
    Parameters MeasuredFVC, MVV, VCFVC, MVV, VCSame
    Hand-heldYesYesSame
    Patient InterfaceFlowhead coneFlowhead coneSame
    CleaningUnit surface cleaning and 70% alcoholUnit surface cleaning and 70% alcoholSame
    Patient UseSingle Patient, multi-useSingle Patient, multi-use (implied, as cleaning is for multi-use)Same
    Back pressureLess than 0.1kPa/L/second @ 14L/sLess than 0.1kPa/L/second @ 14L/sIdentical
    Volume detectionFlow integration sampling @ 100HzFlow integration sampling @ 100HzIdentical
    Maximum displayed volume10L10LIdentical
    Volume accuracy+3% or 0.05L (ATS/ERS, ISO 23747, ISO 26782 standards)Yes (met standard)Identical
    Min. Volume0.01L0.01LIdentical
    Flow AccuracyFlow ±10% or 0.3 L/s, Max. flow rate ±16 L/s, Min. flow rate ±0.02 L/s (ATS/ERS, ISO 23747, ISO 26782 standards)Flow ±10% or 0.3 L/s, Max. flow rate ±16 L/s, Min. flow rate ±0.02 L/sIdentical
    LinearityBetter than ±3%Better than ±3%Identical
    Operating temperature10-40°C10-40°CIdentical
    Performance standardsATS/ERS (2005), ISO 23747, ISO 26782ATS/ERS (2005), ISO 23747, ISO 26782Identical
    Electrical Safety & EMCES 60601-1, IEC 60601-1-2ES 60601-1, IEC 60601-1-2, IEC 60601-1-11 (for home use)Similar (Added new standard for home use)
    Storage Temperature0-50°C0-50°CIdentical
    Storage Relative Humidity10%-95%10%-95%Identical
    CommunicationsUSB x 1 for connection to SpirotracUSB x 1 for connection to SpirotracIdentical
    BiocompatibilitySurface Contact, Skin / Mucosa, Limited Duration (predicate's materials)Surface Contact, Skin / Mucosa, Limited Duration (new material tested to ISO 10993-1, 5, 10, found non-cytotoxic, non-irritating, non-sensitizing)Identical patient contact, new material tested.
    Software Level of Concern-ModerateN/A

    2. Sample size used for the test set and the data provenance:

    The document does not explicitly state a 'sample size' in terms of patient data for the performance testing of the spirometer itself. The performance testing was primarily bench testing against established standards.

    The provenance is implied to be laboratory/bench testing data, not patient data in the context of clinical trials. There is no mention of country of origin for any data or whether it was retrospective or prospective, as it appears to be primarily device performance verification against standards.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    Not applicable. The ground truth for this device's performance is established by international technical standards (e.g., ATS/ERS, ISO 23747, ISO 26782) for spirometry, and electrical safety standards (e.g., IEC 60601 series). These are objective measurements performed on the device.

    4. Adjudication method for the test set:

    Not applicable. The performance testing involves objective measurements against predefined technical standards, not subjective interpretations requiring expert adjudication.

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:

    Not applicable. This device is a diagnostic spirometer, not an AI-assisted diagnostic imaging or interpretation tool that would involve "human readers" or AI assistance in that context. The device directly measures respiratory parameters.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

    The performance evaluation described is for the device as a standalone measuring instrument. This is implicitly how the "Bench Testing" for performance (peak flow, timed forced expired volume) was conducted against ISO standards. The product is a diagnostic spirometer that provides direct measurements, so its standalone performance is its primary function.

    7. The type of ground truth used:

    The ground truth used for performance validation is based on established international technical standards for spirometry (e.g., ATS/ERS, ISO 23747, ISO 26782) for parameters like volume accuracy, flow accuracy, and linearity, and electrical safety and EMC standards (e.g., IEC 60601 series). For biocompatibility, the ground truth is defined by ISO 10993 standards.

    8. The sample size for the training set:

    Not applicable. This device does not use machine learning or AI that would require a "training set" in the traditional sense. Its core functionality relies on physical measurement principles (Fleisch Pneumotachograph) and established algorithms for calculating spirometry parameters.

    9. How the ground truth for the training set was established:

    Not applicable, as no training set for machine learning was used.

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    K Number
    K160253
    Date Cleared
    2016-08-26

    (207 days)

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

    VITALOGRAPH (IRELAND) LTD.

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

    The device is a spirometer which measures patient respiratory parameters including FVC, FEV1, FEV6, PEF, MVV and VC. The Vitalograph micro is a handheld spirometer designed for lung function for use on adults and pediatrics, 5 years and older, in a variety of environments such as hospital wards, health centers and private homes under the supervision of a healthcare provider.

    Device Description

    Vitalograph Model 6300 micro is a handheld portable spirometer for performing Spirometry testing to aid in measuring the effect of lung disease on pulmonary function. The device may be used in hospital, healthcare facilities and homes under the supervision of a healthcare provider.

    The intended use of the 6300 micro is in the simple assessment of respiratory function through the measurement of dynamic lung volumes i.e. spirometry.

    The proposed device consists of a main body which incorporates an LCD, a touch panel, pressure transducer and flow circuitry as well as a detachable flow head. The device is used with a pulmonary function filter. Reports may be printed using the USB cable provided.

    Principles of Operation: The Vitalograph micro measures a subject's lung ventilation by using a flowhead containing a Fleisch Pneumotachograph capable of giving linear signals throughout the entire physiological range. During testing, the airflow through the flowhead produces a pressure differential. Internally this pressure is applied to a pressure transducer, which produces an electric signal. This signal is converted into digital form so that the unit can perform calculations and display the results.

    Primary functions are:

    • Interaction will be via the touch screen interface.
    • The model 6300 Compact performs spirometric measurements using the established fleisch Pneumotachograph, using single breath and multiple-breath testing techniques, to display and record lung volumes and flow rates (including FVC, FEV1, FEV6, PEF, MVV and VC) and their sub-divisions to aid in the measuring the effect of lung disease on pulmonary function
    • Record subject demographic data.
    • Produce printed reports to external printers.
    AI/ML Overview

    The provided text describes the Vitalograph Model 6300 micro, a diagnostic spirometer, and its substantial equivalence to predicate devices, rather than a clinical study establishing AI performance. Therefore, many of the requested elements for AI/ML device studies, such as sample size for test sets, data provenance, number of experts, adjudication methods, MRMC studies, standalone performance, and training set details, are not applicable.

    However, I can extract information related to the acceptance criteria (performance standards) and the study that proves the device meets these criteria in the context of this traditional medical device.

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria for the Vitalograph Model 6300 micro are primarily based on international performance standards for spirometers. The reported device performance indicates successful compliance with these standards.

    Acceptance Criteria (Standards Met)Reported Device Performance
    Performance Standards:
    ISO 26782: Spirometers for measurement of time forced expired volumes in humansSuccessfully passed
    ATS/ERS 2005: Standardisation of Lung Function TestingSuccessfully passed
    ISO 23747: Peak expiratory flow meters for assessment of pulmonary functionSuccessfully passed
    IEC/EN 60601 (EN 60601-1-1 and EN 60601-1-2)Successfully passed
    Mechanical/Environmental Standards:
    Drop test of packaged device from specified heightSatisfactory results
    Storage conditions testingSatisfactory results
    Operating temperature limits testingSatisfactory results
    Cleaning method validationSatisfactory results

    2. Sample Size Used for the Test Set and Data Provenance

    This is a non-clinical, bench testing study. Therefore, there is no "sample size" in the context of patient data. The testing involves the device itself undergoing various physical and performance evaluations against established standards. The data provenance is from non-clinical testing conducted by the manufacturer, Vitalograph Ireland Ltd., in Ireland.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts

    Not applicable for this type of non-clinical device testing. Ground truth is established by the international performance standards themselves, which are developed by expert consensus within their respective standardization bodies. The tests evaluate the device's adherence to these predefined criteria.

    4. Adjudication Method for the Test Set

    Not applicable. The tests are objective measurements against specified performance limits outlined in the standards. There is no human adjudication in the sense of reviewing results to establish ground truth for individual cases.

    5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

    Not applicable. This is not an AI/ML device, nor is it a comparative effectiveness study involving human readers.

    6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done

    Not applicable. This is a standalone medical device (spirometer) designed for direct measurement, not an algorithm. Its performance is measured as a standalone instrument.

    7. The type of ground truth used

    The ground truth for this device's performance claims is defined by the international and national performance standards (e.g., ISO 26782, ATS/ERS 2005, ISO 23747, IEC/EN 60601). The device's measurements are compared against the specifications and tolerances outlined in these standards.

    8. The sample size for the training set

    Not applicable. There is no "training set" as this is a traditional medical device, not an AI/ML algorithm.

    9. How the ground truth for the training set was established

    Not applicable.

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    K Number
    K142642
    Date Cleared
    2015-06-30

    (286 days)

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

    VITALOGRAPH(IRELAND) LTD.

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

    The Vitalograph Model 6600 COMPACT is intended for use by or on the order of a physician in a hospital or clinic setting. The product is designed for use on adults and paediatrics, 5 years and older. The device is intended to be used as a spirometer which measures patient respiratory parameters including FVC, FEV1, FEV6, PEF, MVV and VC or connected to compatible Vitalograph or third party devices to acquire, view, store and print the device output.

    Device Description

    Vitalograph Model 6600 Compact, running Vitalograph Model 7000 Spirotrac software, ref 510(k) K141546, shall provide a mains-powered desktop spirometer for creating, adding and recalling subjects and performing Spirometry testing on those subjects to aid in the measuring the effect of lung disease on pulmonary function. Model 6600 Compact will also, via the Spirotrac software, connect to compatible third party devices to read and display the output from these devices to allow the information to be retained with the subject. All connected compatible third party devices are those cleared via Model 7000 510(k) K141546. The intended use of the Compact is in the simple assessment of respiratory function through the measurement of dynamic lung volumes i.e. spirometry. Its primary functions are: 1. Interaction will be via the touch Screen interface. 2. Running the Spirotrac software, as cleared in K141546, The model 6600 Compact performs spirometric measurements using the established fleisch Pneumotachograph, using single breath and multiple-breath testing techniques, to display and record lung volumes and flow rates (including FVC, FEV1, FEV6, PEF, MVV and VC) and their sub-divisions to aid in the measuring the effect of lung disease on pulmonary function 3. Record subject demographic data. 4. Produce printed reports to external printers.

    AI/ML Overview

    This document describes a 510(k) premarket notification for the Vitalograph Model 6600 Compact, a diagnostic spirometer. The submission aims to demonstrate substantial equivalence to legally marketed predicate devices.

    Here's an analysis of the acceptance criteria and supporting studies based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document doesn't present a formal table of quantitative acceptance criteria with corresponding performance metrics like sensitivity, specificity, or accuracy, as might be seen for AI/ML devices. Instead, the acceptance criteria for this spirometer are based on adherence to established international performance and safety standards, and equivalency to predicate devices.

    Acceptance Criteria (Standards Adherence & Equivalency)Reported Device Performance
    Performance Standards:
    • ISO 26782 (Anaesthetic and respiratory equipment -- Spirometers intended for the measurement of time forced expired volumes in humans)
    • ATS/ERS 2005 (ATS/ERS Task Force: Standardisation of Lung Function Testing)
    • ISO 23747 (Anaesthetic and respiratory equipment -- Peak expiratory flow meters for the assessment of pulmonary function in spontaneously breathing humans)
    • EN13826:2003 (for PEF, now ISO 23747:2009)
    • EN ISO 26782:2009 | "All tests and validations demonstrated satisfactory results."
      "The Model 6600 Compact successfully passed the performance requirements of these tests." |
      | Safety Standards:
    • IEC / EN 60601 (inclusive of EN 60601-1-1 and EN 60601-1-2) | "Yes" (in comparison table) for Model 6600 and predicate Model 2120.
      "Yes, for connected compatible devices" for predicate Spirotrac Model 7000. (Implies Model 6600, using Spirotrac software, also meets this). |
      | Mechanical Shock Testing:
    • Drop test of packaged device (specified height, all corners/edges)
    • Random Vibration, Sinusoidal Vibration, and Bump Tests
    • Storage conditions testing
    • Operating temperature limits testing | "All tests and validations demonstrated satisfactory results."
      "Evidence of successful completion of tests and validations has been provided with this submission." |
      | Equivalence to Predicate Devices (Model 7000 Spirotrac, K141546 and Model 2120, K100687):
    • Identical user interface and software
    • Same indications for use (including pediatric population clarification)
    • Same operating principle and flow measurement principles
    • Same parameters calculation
    • Same method of use
    • Same performance (bench tested)
    • Same patient interface accessories
    • "No new issues of safety or effectiveness have been introduced" | The document asserts "The characteristics of the Model 6600 Compact are similar to those of the predicate devices listed." The detailed comparison table throughout pages 7-10 highlights these similarities. |

    2. Sample Size Used for the Test Set and Data Provenance:

    The document refers to "performance testing against international standards" (ISO 26782, ATS/ERS 2005, ISO 23747) and "Mechanical shock testing". However, it does not specify the sample size (e.g., number of spirometry maneuvers, number of devices tested for mechanical shock) used for these tests.
    The data provenance is internal testing performed by Vitalograph Ireland Ltd. It implies prospective testing conducted for regulatory submission, rather than retrospective analysis of patient data.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts:

    This information is not provided in the document. For a diagnostic spirometer, "ground truth" typically refers to accurately generated airflow and volume signals from a calibration syringe or a mechanical lung simulator, which are then compared to the device's measurements. The document mentions "bench tested against performance standards," suggesting such methods were used, but details on expert involvement in setting these "ground truths" or validating the testing methodology are absent.

    4. Adjudication Method for the Test Set:

    This information is not provided. Given that the testing involves adherence to objective performance standards for measuring physiological parameters (airflow, volume), typical "adjudication" in the sense of resolving discrepancies between human readers or algorithm outputs is not directly applicable. The device's measurements are compared against the known, controlled inputs from the test equipment.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, If So, What Was the Effect Size of How Much Human Readers Improve with AI vs. Without AI Assistance:

    A MRMC comparative effectiveness study is not applicable to this device. This is a standalone diagnostic spirometer, not an AI/ML-driven interpretive system that would assist human readers in, for example, image interpretation. The device's function is to objectively measure lung parameters, not to provide interpretations that human readers would then review or augment.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done:

    Yes, a standalone performance assessment was done. The entire submission focuses on the device's (Vitalograph Model 6600 Compact) ability to accurately measure respiratory parameters (FVC, FEV1, FEV6, PEF, MVV and VC) independently, against international performance standards described in point 1. The device itself performs the measurements; it's not described as having an AI algorithm requiring human interaction for its primary function.

    7. The Type of Ground Truth Used:

    The ground truth used for performance testing (bench testing) would have been precisely known, controlled flow and volume inputs generated by calibration equipment (e.g., a calibration syringe, flow generator, or mechanical lung simulator) that comply with the requirements of the mentioned ISO and ATS/ERS standards. This is an objective, physical ground truth.

    8. The Sample Size for the Training Set:

    This information is not applicable as the Vitalograph Model 6600 Compact is a hardware device based on established physical measurement principles (Fleisch Pneumotachograph) and software logic, not a machine learning or AI algorithm that typically requires a "training set." The software (Spirotrac Model 7000) was previously cleared (K141546), implying its development and validation occurred prior, but no training set for an AI model is mentioned for this device.

    9. How the Ground Truth for the Training Set Was Established:

    This information is not applicable for the same reason as point 8.

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    K Number
    K142812
    Date Cleared
    2015-06-29

    (273 days)

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

    VITALOGRAPH(IRELAND) LTD.

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

    The device is a spirometer which measures patient respiratory parameters including FVC, FEV1, FEV6, PEF, MVV and VC. The Vitalograph Pneumotrac is a desktop spirometer designed for lung function testing for use on adults and pediatrics, 5 years and older, in a variety of environments such as hospital wards, health centers and private homes under the supervision of a healthcare provider.

    Device Description

    The intended use of the Vitalograph Pneumotrac desktop spirometer, which connects to Vitalograph Model 7000 Spirotrac software, ref 510(k) K141546, shall provide a USB-powered desktop spirometer for creating, adding and recalling subjects and performing Spirometry testing on those subjects to aid in the measuring the effect of lung disease on pulmonary function. Spirometry is in the simple assessment of respiratory function through the measurement of dynamic lung volumes. Its primary functions are; 1. Standalone spirometric measures using single breath or multiple-breath testing techniques, display and record lung volumes and flow rates (including FVC, MVV, VC) and it's subdivisions, Display a single subject's demographic data entered by the user. 2. Produce reports In a clinical setting, the measurements obtained from a lung function test form part of the various findings of a physician in the detection, diagnosis and monitoring of chest diseases.

    AI/ML Overview

    The Vitalograph Model 6800 Pneumotrac is a diagnostic spirometer. The device was studied through validation bench testing against several international standards to demonstrate its performance.

    1. Table of Acceptance Criteria and Reported Device Performance:

    ParameterAcceptance CriteriaReported Device Performance
    Volume Range0-10 Liters (Predicate)0-10 Liters
    Max Flow Range0-16 Liters/second (Predicate)0-16 Liters/second
    Back Pressure
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    K Number
    K141546
    Date Cleared
    2014-09-03

    (85 days)

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

    VITALOGRAPH(IRELAND) LTD.

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

    The Vitalograph Model 7000 Spirotrac is intended for use by or on the order of a physician in a hospital or clinic setting. The product is designed for use on both adult and pediatric patients. The device is a PC based software application which is intended to be used as a spirometer or connect to compatible Vitalograph or third party devices to acquire, view, store and print the device output.

    Device Description

    Spirotrac shall provide a secure PC based medical device software application for creating, adding and recalling subjects and performing Spirometry testing on those subjects. Spirotrac will also link to compatible third party devices to read and display the output from these devices to allow the information to be retained with the subject. Spirotrac will integrate and read / display information from Pulse Oximetry devices, Blood Pressure and Weight measurements devices, and ECG test devices. Its primary functions are: 1. Spirometry measurements using single breath and multiple-breath testing techniques, the display and recording of measured lung volumes and flow rates (including VC, FIVC, FVC) and it's subdivisions, The unit also allows for the measurements of Inspiratory and Expiratory Flow rates (PEF, FEFx, etc), indirect measures (e.g. MVV) and Pre-post testing (e.g. Challenge, work shift). 2. Record subject demographic data as input. Interact with existing Vitalograph and compatible third party devices via standard PC communication methods for download of data for storage within the Spirotrac database. 3. Navigation is allowed via the use of a standard PC keyboard and mouse or touchscreen.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and study information for the Vitalograph Model 7000 Spirotrac, based on the provided text:

    Important Note: The provided document is a 510(k) summary, which focuses on demonstrating substantial equivalence to predicate devices, not typically a detailed clinical study report proving device performance against specific, pre-defined acceptance criteria in the same way a PMA or de novo submission might. Therefore, some information, especially regarding detailed sample sizes, expert qualifications, and specific "reported device performance" metrics against acceptance criteria (beyond general compliance checks), is not explicitly stated in this type of document.


    1. Table of Acceptance Criteria and Reported Device Performance

    The document states that the device underwent validation testing to ensure performance according to its specifications against current standards. The mentioned standards serve as the de-facto acceptance criteria. The "Reported Device Performance" is generally stated as "All tests and validations demonstrated satisfactory results." Specific numerical performance metrics against each standard are not provided in this summary.

    Acceptance Criterion (Standard)Reported Device Performance (as per document)
    ISO 26782: Anaesthetic and respiratory equipment -- Spirometers intended for the measurement of time forced expired volumes in humansSatisfactory results demonstrated
    ATS/ERS 2005: ATS/ERS Task Force: Standardisation of Lung Function TestingSatisfactory results demonstrated
    ISO 23747: Anaesthetic and respiratory equipment -- Peak expiratory flow meters for the assessment of pulmonary functionSatisfactory results demonstrated
    Integrity of information maintained during interface with compatible third-party devicesSatisfactory results demonstrated (validation on file for all devices)
    Successful download and storage of information from third-party devices within the Spirotrac databaseSatisfactory results demonstrated (validation on file for all devices)

    2. Sample Size Used for the Test Set and Data Provenance

    The document does not specify a sample size for any clinical test set. The validation appears to be primarily engineering and bench testing against international standards, rather than a clinical study with a patient cohort.

    • Sample Size (Test Set): Not specified.
    • Data Provenance: Not specified, but likely from laboratory testing and calibration rather than patient data from a specific country or retrospective/prospective study type, given it's a spirometer software.

    3. Number of Experts Used to Establish Ground Truth and Qualifications

    This information is not provided as the validation described is against established international technical standards for spirometry. There wasn't a ground truth established by human experts in the typical sense of a diagnostic imaging study.


    4. Adjudication Method for the Test Set

    Since the validation is described as performance testing against international standards, an "adjudication method" in the context of expert review for ground truth determination is not applicable or described. The standards themselves define the criteria for "correctness" or acceptable performance.


    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    An MRMC study was not mentioned or performed. The device is a spirometer software application; its performance is typically evaluated for measurement accuracy and consistency, rather than its impact on human reader interpretation.


    6. Standalone Performance Study (Algorithm Only)

    Yes, a standalone performance evaluation was done. The document explicitly states: "The Vitalograph Model 7000 Spirotrac underwent validation testing to ensure performance according to its specifications against current standards." This refers to the software's ability to accurately acquire, process, and display spirometry measurements as determined by the listed ISO and ATS/ERS standards.


    7. Type of Ground Truth Used for the Test Set

    The ground truth for the test set was defined by international technical standards and norms for spirometry (ISO 26782, ATS/ERS 2005, ISO 23747). This implies that the device's measurements were compared against established reference values or methods defined by these standards, likely using simulated lung functions or calibrated devices.


    8. Sample Size for the Training Set

    The document does not mention a training set size. This device is a spirometer software, and its primary function is measurement and data handling. While it might include algorithms for interpretation (e.g., predicted values, flagging out-of-range results), these are typically based on well-established physiological models and clinical guidelines, not necessarily a machine learning model that requires a "training set" in the modern AI sense.


    9. How the Ground Truth for the Training Set Was Established

    Since a "training set" in the machine learning sense is not mentioned, the method for establishing its ground truth is not applicable or described. The algorithms and computations within the spirometer software would be based on established physiological principles and clinical guidelines rather than learned from a labeled dataset.

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    K Number
    K110525
    Date Cleared
    2011-11-23

    (273 days)

    Product Code
    Regulation Number
    870.2800
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    VITALOGRAPH(IRELAND) LTD.

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

    The Model 7100 is a non-invasive battery operated device intended to acquire, record and store ambulatory cough sounds from patients for up to 24 hours. The device stores the data on a removable memory card for later playback, review, and analysis on a windows based PC.

    Device Description

    The Model 7100 is a non-invasive battery operated device intended to acquire, record and store ambulatory cough sounds from patients for up to 24 hours. The device stores the data on a removable memory card for later playback, review, and analysis of the cough sounds on a windows based PC.

    The recording of respiratory sounds to a sound file over the two channels for up to 24 hours is achieved by:
    a) The contact sensor channel, which records the data for later analysis.
    b) An air microphone channel. This is used to monitor and to ascertain the validity of the data obtained in the channel described in (a.) above. This can be achieved by listening, or otherwise determining, signals such as speech and other noises that will be ignored when examining channel (a) data.
    These two individual analogue signals are electronically conditioned and then digitally sampled. The sampled information data is then stored to a suitable internal memory module. The data will be transferred to the PC by removing the memory card from the VitaloJAK.

    AI/ML Overview

    The provided document, K110525 for the Vitalograph Model 7100 VitaloJAK, is a 510(k) summary for a medical device. As such, it describes the device's intended use and technological characteristics, and compares it to a predicate device to establish substantial equivalence. However, it does not contain the detailed study results, acceptance criteria, or performance metrics that would typically be presented in a dedicated clinical validation or performance study report.

    The document states: "Safety and effectiveness have been assured through the extensive testing in relation to IEC 60601 standards for electrical safety and EMC/EMI, as well as device specific performance testing. ... As with the predicate device the Vitalograph Model 7100 underwent validation testing to ensure performance according to its specifications. All tests demonstrated satisfactory results. Evidence of successful validation has been provided with this submission." This indicates that such testing was performed and submitted to the FDA, but the details are not included in this publicly available summary.

    Therefore, many of the requested details cannot be extracted from the provided text. Below is an attempt to address the points based only on the available information, with explicit statements where information is missing.


    Acceptance Criteria and Device Performance Study for Vitalograph Model 7100 VitaloJAK

    The provided 510(k) summary for the Vitalograph Model 7100 VitaloJAK does not explicitly state quantitative acceptance criteria or detailed device performance results in a comparative table format. Instead, it attests that "All tests demonstrated satisfactory results" and that "Evidence of successful validation has been provided with this submission." The focus of this 510(k) summary is on comparing the device's characteristics to a predicate device to establish substantial equivalence.

    1. Table of Acceptance Criteria and Reported Device Performance

    Performance Metric CategoryAcceptance CriteriaReported Device Performance
    Device FunctionalityThe device should accurately acquire, record, and store ambulatory cough sounds from patients for up to 24 hours via its two channels (contact sensor and air microphone). Data should be transferable to a PC for playback, review, and analysis."The Model 7100 is a non-invasive battery operated device intended to acquire, record and store ambulatory cough sounds from patients for up to 24 hours. The device stores the data on a removable memory card for later playback, review, and analysis of the cough sounds on a windows based PC."
    "The recording of respiratory sounds to a sound file over the two channels for up to 24 hours is achieved by: a) The contact sensor channel... b) An air microphone channel."
    "All tests demonstrated satisfactory results."
    Safety and EffectivenessCompliance with IEC 60601 standards for electrical safety and EMC/EMI. Device specific performance testing to ensure performance according to specifications."Safety and effectiveness have been assured through the extensive testing in relation to IEC 60601 standards for electrical safety and EMC/EMI, as well as device specific performance testing."
    "All tests demonstrated satisfactory results."
    Comparison to Predicate DeviceThe device's technological characteristics and performance should be similar to the predicate device (Karmelsonix Pulmotrack 5050 Wholter) without raising new questions of safety or effectiveness, specifically in its non-diagnostic function of data acquisition, recording, and storage."The characteristics of the Model 7100 is similar to those of the predicate device listed."
    "As with the predicate device the Vitalograph Model 7100 does not perform diagnosis."
    Accuracy of Cough Sound RecordingExplicit quantitative acceptance criteria for the accuracy of cough sound acquisition and recording are not provided in this summary. This would typically involve metrics such as signal-to-noise ratio, fidelity of sound capture, or consistency of recording over time.The summary extensively describes the technical characteristics for recording, including two separate channels (contact sensor and ambient microphone) and digital sampling. It states, "The air microphone channel is used to monitor and to ascertain the validity of the data obtained in the channel described in (a.) above." This suggests an internal validation mechanism, but no quantitative results are given.
    "All tests demonstrated satisfactory results."

    2. Sample Size and Data Provenance for the Test Set

    • Sample Size for Test Set: This information is not provided in the 510(k) summary.
    • Data Provenance (country of origin, retrospective/prospective): This information is not provided in the 510(k) summary. The document focuses on the technical characteristics and regulatory compliance, not on clinical study data.

    3. Number of Experts and Qualifications for Ground Truth Establishment (Test Set)

    • This information is not provided in the 510(k) summary. Since the device itself is not diagnostic and "The user identifies each incident of coughing," the role of experts in establishing a ground truth for device performance (beyond general technical specifications) is not detailed. If a study involved expert review of the recorded data, it is not mentioned here.

    4. Adjudication Method for the Test Set

    • This information is not provided in the 510(k) summary.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    • No evidence of an MRMC comparative effectiveness study is presented in this 510(k) summary. The device is explicitly stated to not perform diagnosis and requires a user to identify cough incidents. Therefore, a study comparing human readers with and without AI assistance would not be applicable to this device's stated function.

    6. Standalone Performance Study (Algorithm Only)

    • A standalone performance study (algorithm only) was not performed or is not detailed in this 510(k) summary for automated cough detection or analysis. The device's stated function is solely to "acquire, record and store ambulatory cough sounds," and for "later playback, review, and analysis of the cough sounds on a windows based PC" where "The user identifies each incident of coughing." The device itself does not contain an algorithm for automatic cough identification or diagnosis.

    7. Type of Ground Truth Used

    • The 510(k) summary does not mention a specific type of ground truth used to evaluate the device's core function of recording. The "validity of the data obtained" (from the contact sensor) is stated to be ascertained by the air microphone channel, but this refers to technical signal validity rather than a clinical ground truth for cough events. For the analysis phase, where the user identifies coughs, the ground truth would implicitly be human expert identification, but this is a post-recording step leveraging the user, not an automated function of the device that requires an inherent ground truth during device operation.

    8. Sample Size for the Training Set

    • This information is not applicable and not provided. The device is a data recorder, not an AI-driven diagnostic or analytical tool that requires a training set (in the machine learning sense). Its functionality is based on hardware and firmware for signal acquisition and storage.

    9. How the Ground Truth for the Training Set Was Established

    • This information is not applicable and not provided. As mentioned above, the device does not use a training set in the machine learning context.
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