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510(k) Data Aggregation

    K Number
    K202837
    Device Name
    GoSpiro
    Date Cleared
    2020-12-04

    (70 days)

    Product Code
    Regulation Number
    868.1840
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    GoSpiro

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

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

    Device Description

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

    The GoSpiro spirometer transmits real-time lung function data to computers, tablets or smartphones over a Bluetooth connection for tele-healthcare applications. The GoSpiro performs full flow-volume loops including inspiratory and expiratory data. The internal program performs all of the calculations for measurements to meet American Thoracic Society and European Respiratory Society requirements. It has built-in quality control measurements and transmits indices of measurement quality including time to peak flow, back-extrapolated volume, total expiratory time, and end-expiratory flow detection.

    It is used with the GoSpiro App display and communications software on a smartphone or tablet.

    The GoSpiro is powered by an internal rechargeable Lithium battery and is charged via its USB charging station connected to a USB power source. The device complies with ES 60601-1, IEC 60601-1-2, and IEC 60601-1-11.

    The fundamental technology to measure flow is a vertical turbine volume sensor. The turbine transducer measures expired air directly at B.T.P.S. (body temperature and pressure with saturated water vapor) thus avoiding the requirement for temperature correction on exhalation. An electronic temperature sensor on the device PCB measures atmospheric temperature, thus enabling correction of inspired volumes and flows. This transducer is insensitive to the effects of condensation and temperature and avoids the need for individual calibration prior to performing a test.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for the GoSpiro® device, which is a diagnostic spirometer. The primary change introduced in this submission (K202837) is the ability to clean, disinfect, and reuse the turbine for multi-patient, multi-use, as opposed to the predicate device (K163249) where the turbine had to be replaced if no filter was used.

    Here's an analysis of the provided information concerning acceptance criteria and studies:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly present a table of acceptance criteria with corresponding performance results for all device functionalities. However, it implicitly uses the predicate device's specifications as the standard for equivalence. The key performance parameters related to spirometry and their stated values are:

    Acceptance Criteria (Implied from Predicate)Reported Device Performance (GoSpiro®)
    Flow Range: ±14 l/sFlow Range: ±14 l/s
    Flow Accuracy: ±5% or 200 mL/sFlow Accuracy: ±5% or 200 mL/s
    Flow Resistance: 137 Pascals (Pa) per Liter per second, measured at 14 Liters per second (Lps)Flow Resistance: 137 Pascals (Pa) per Liter per second, measured at 14 Liters per second (Lps)
    Volume Range: 0-8 litersVolume Range: 0-8 liters
    Volume Accuracy: ±3% of reading, or 0.05 liters, whichever is greaterVolume Accuracy: ±3% of reading, or 0.05 liters, whichever is greater
    Compliance with ATS Spirometry guidelinesComplies with ATS Spirometry guidelines
    Compliance with AAMI ANSI ES 60601-1, IEC 60601-1-2, IEC 60601-1-11Complies with AAMI ANSI ES 60601-1, IEC 60601-1-2, IEC 60601-1-11
    Water Ingress Protection: IP22Water Ingress Protection: IP22
    Biocompatibility: Externally communicating (Indirect), Tissue and Surface Contact, Mucosa, limited exposureSimilar patient contact and identical materials (Biocompatibility evaluated per ISO 10993-1)
    Cleaning of mouthport (predicate)Cleaning of mouthport (Same mouthport); Cleaning and disinfection of Turbine (Proposed)

    The primary acceptance criterion that needed separate validation for the proposed device was the effectiveness of turbine cleaning and disinfection. The document states: "The validation testing has been performed demonstrating that the turbine may be cleaned, disinfected and reused." This implies that the acceptance criteria for cleaning and disinfection (e.g., reduction of microbial load, retention of device functionality, no adverse material degradation) were met, though the specific quantitative criteria are not detailed in this excerpt.

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

    The document mentions "High level disinfection validation", "Post-disinfecting performance", and "Post-disinfecting biocompatibility" as types of performance testing.

    • Sample Size: The document does not specify the sample size used for these validation tests (e.g., number of turbines subjected to disinfection, number of cycles tested, or number of biological or performance tests).
    • Data Provenance: The document does not specify the country of origin of the data or whether the studies were retrospective or prospective.

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

    This information is not provided in the excerpt. The studies mentioned (disinfection, performance, biocompatibility) are laboratory/engineering tests, not clinical studies that typically involve expert interpretation for ground truth.

    4. Adjudication Method for the Test Set

    This information is not applicable and therefore not provided. The studies described are validation tests (e.g., disinfection efficacy, material properties, device function) rather than clinical evaluations requiring expert adjudication of results.

    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

    An MRMC study is not applicable as the GoSpiro® is a diagnostic spirometer for measuring lung function, not an AI-assisted diagnostic tool that relies on human readers interpreting images or data with and without AI. It directly measures physiological parameters.

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

    This concept is not applicable in the context of the GoSpiro® device. It is a physical medical device that measures spirometry parameters. Its "performance" is determined by the accuracy and precision of its physical measurements, not by an algorithm's standalone diagnostic capability in the absence of human interaction (beyond the user performing the spirometry maneuver). The device and its internal program perform calculations to meet ATS/ERS requirements, and its accuracy targets are detailed above.

    7. The Type of Ground Truth Used

    For the core spirometry measurements (Flow, Volume, Accuracy, Resistance), the ground truth is implicitly based on established physical and physiological standards and measurement principles (e.g., traceable reference spirometers or calibrated flow/volume sources). For the specific validation related to the new submission:

    • Cleaning and Disinfection Validation: The ground truth would likely be established through standard microbiological testing methods (e.g., reduction of specified microorganisms to acceptable levels) and material compatibility assessments according to recognized standards (e.g., AAMI TIR12, ISO 17664, or specific FDA guidance).
    • Post-disinfecting performance: The ground truth would be that the device, after disinfection, continues to meet its specified flow/volume accuracy and resistance criteria.
    • Post-disinfecting biocompatibility: The ground truth would be that the materials, after disinfection, remain biocompatible as per ISO 10993-1.

    8. The Sample Size for the Training Set

    This information is not applicable as the GoSpiro® is a physical measurement device and its underlying technology (bidirectional turbine) and internal program for calculations are not described as based on machine learning or AI models requiring a "training set" in the conventional sense. The "internal program" would be developed based on physics and engineering principles, not statistical learning from data.

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

    This information is not applicable for the reasons stated in point 8.

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    K Number
    K163249
    Device Name
    GoSpiro
    Date Cleared
    2017-03-24

    (126 days)

    Product Code
    Regulation Number
    868.1840
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    GoSpiro

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

    The GoSpiro® is intended to be used by adults and children over 5 years old in physician's offices, clinics and home settings to conduct basic lung function and spirometry testing. It is a single-patient use device.

    Device Description

    The GoSpiro is intended to be used by adults and children over 5 years old in physician's offices, clinics and home settings to conduct basic lung function and spirometry testing. It is a single-patient, use device.

    The GoSpiro spirometer transmits real-time lung function data to computers, tablets or smartphones over a Bluetooth connection for tele-healthcare applications. The GoSpiro performs full flow-volume loops including inspiratory and expiratory data. The internal program performs all of the calculations for measurements to meet American Thoracic Society and European Respiratory Society requirements. It has built-in quality control measurements and transmits indices of measurement quality including time to peak flow, back-extrapolated volume, total expiratory time, and end-expiratory flow detection.

    It is used with the GoSpiro App display and communications software on a smartphone or tablet.

    The GoSpiro is powered by an internal rechargeable Lithium battery and is charged via its USB charging station connected to a USB power source. The device complies with ES 60601-1, IEC 60601-1-2, and IEC 60601-1-11.

    The fundamental technology to measure flow is a vertical turbine volume sensor. The turbine transducer measures expired air directly at B.T.P.S. (body temperature and pressure with saturated water vapor) thus avoiding the requirement for temperature correction on exhalation. An electronic temperature sensor on the device PCB measures atmospheric temperature, thus enabling correction of inspired volumes and flows. This transducer is insensitive to the effects of condensation and avoids the need for individual calibration prior to performing a test.

    AI/ML Overview

    The Monitored Therapeutics, Inc. GoSpiro® is a diagnostic spirometer intended for use by adults and children over 5 years old in physician's offices, clinics, and home settings for basic lung function and spirometry testing. It is a single-patient use device.

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

    1. Table of Acceptance Criteria and Reported Device Performance

    The provided document details various performance tests and compliance with established standards, but it does not explicitly list quantitative acceptance criteria for each spirometry parameter (e.g., FVC, FEV1) with specific numerical ranges. Instead, it states that "The GoSpiro passed the acceptance criteria for all the listed testing requirements and specifications." and "The performance and specifications demonstrate that the devices meet the ATS 2005 requirements for pulmonary function testing." This implies that the acceptance criteria are adherence to the ATS 2005 guidelines for spirometry, and the device met these.

    However, the document does provide specific performance metrics in the comparison tables, which can be interpreted as demonstrating the device's capabilities relative to its predicates and standards.

    Acceptance Criteria (Implied by ATS 2005 and Predicate Comparison)Reported Device Performance
    Flow/Volume Accuracy±5% or 200 mL/s
    Volume Accuracy±3% of reading, or 0.05 liters, whichever is greater
    Flow Range+14 l/s
    Volume Range0-8 liters
    Flow Resistance137 Pascals (Pa) per Liter per second, measured at 14 Liters per second (Lps)
    Operating Conditions (Temperature)17 to 35°C
    Operating Conditions (Humidity)30%RH to 75%RH
    Compliance with ATS Spirometry GuidelinesYes
    Compliance with Safety StandardsAAMI ANSI ES 60601-1, IEC 60601-1-2, IEC 60601-1-11
    BiocompatibilityPassed ISO 10993-1, including cytotoxicity, irritation, sensitization, VOC, CO, CO2, Ozone, and PM25 testing
    Environmental RequirementsPassed
    Modes of Operation (Functional)Passed
    ATS/ERS waveform simulator testingPassed
    High Altitude PerformancePassed
    Possible Cough Detection (Functional)Passed
    Durability turbine life testPassed
    Mechanical RequirementsPassed
    Electrical Requirements (Battery Safety, Wireless Coexistence, Bluetooth Module)Passed (IEC 62133) and documented
    PCB and Electrical Circuitry RequirementsPassed
    Packaging and Shipping RequirementsPassed
    Hardware VerificationPassed
    Labeling RequirementsPassed
    Manufacturing RequirementsPassed
    Safety RequirementsPassed
    Cleaning and Shelf-lifePassed
    Software and System Verification and ValidationPassed (IEC 62304)
    Human Factors studyPassed

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

    The document states that "ATS / ERS waveform simulator testing" was performed and passed. However, it does not specify the sample size (number of waveforms or individuals) used for this test set. The data provenance is also not explicitly stated in terms of country of origin or whether it was retrospective or prospective, as this was likely a bench/simulator test rather than a clinical study with human subjects.

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

    This information is not provided in the document because the testing appears to be primarily technical/bench validation against established spirometry standards (ATS/ERS waveform simulator testing) rather than a clinical study requiring expert ground truth for diagnostic accuracy.

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

    An adjudication method is not applicable or not described in the provided text, as the testing was focused on the device's technical performance against a simulator and compliance with standards, not on interpreting images or clinical outcomes that would require adjudicators.

    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 multi-reader multi-case (MRMC) comparative effectiveness study is not applicable to this device. The GoSpiro is a diagnostic spirometer that measures lung function, not an AI-powered diagnostic system requiring human interpretation comparison.

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

    The performance testing described ("ATS / ERS waveform simulator testing") represents a standalone evaluation of the algorithm's accuracy at measuring flow, volume, and time against a known standard. Although not explicitly called an "algorithm-only" study, the nature of testing against a simulator implies measuring the device's output independently. The document states that the device performed all calculations to meet ATS/ERS requirements and included quality control measurements and indices of measurement quality.

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

    The ground truth for the device's performance appears to be established by ATS/ERS waveform simulator testing. This refers to a standardized set of flow-volume and volume-time curves designed to test spirometer accuracy against known, ideal physiological breathing patterns. These simulators provide a "gold standard" input against which the device's measurements are compared.

    8. The sample size for the training set

    This refers to a software or AI model's training data. The document does not mention a training set as the device is a hardware spirometer with embedded firmware/software for calculations, not a machine learning or AI model that undergoes a separate training phase with a distinct dataset.

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

    As there is no mention of a "training set" for an AI model, this information is not applicable in the provided text. The device's functionality relies on established physiological principles and engineering specifications, validated against standardized simulator inputs.

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