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510(k) Data Aggregation

    K Number
    K141770
    Manufacturer
    Date Cleared
    2015-04-22

    (295 days)

    Product Code
    Regulation Number
    868.5905
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The 3B Luna CPAP and Auto CPAP Systems are intended to deliver positive pressure for the treatment of Obstructive Sleep Apnea. The optional integrated humidifier is indicated for the humidification and warming of air from the flow generator. These devices are intended for single patient use by prescription in the home or hospital / institutional environment on adult patients.

    Device Description

    The Luna CPAP and Auto CPAP System is a microprocessor-controlled, blower-based system that generates positive airway pressure from 4 to 20 cm H20. The device is intended for use with a patient interface (mask). The device has been modified to include a color LCD, menu driven user interface, and a redesigned enclosure. The electrical circuit was redesigned to incorporate the color LCD. The basic functionality and performance characteristics of the Luna CPAP and Auto CPAP are unchanged from the predicate device RESmart CPAP and Auto CPAP (K132967).

    AI/ML Overview

    This document is a 510(k) premarket notification for the 3B™ Luna CPAP and Auto-CPAP System, which includes an integrated heated humidifier. It compares the proposed device to a predicate device, the RESmart® CPAP and Auto-CPAP Systems (K132967). The main purpose of the notification is to demonstrate substantial equivalence to the predicate device, not necessarily to independently prove the device meets specific performance criteria beyond those of the predicate.

    Here's an analysis of the acceptance criteria and study that proves the device meets them, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document doesn't explicitly state "acceptance criteria" in the traditional sense of a new technology proving its efficacy against established benchmarks. Instead, it aims to demonstrate that the proposed device is substantially equivalent to a predicate device. Therefore, the "acceptance criteria" can be inferred as matching or performing similarly to the predicate device based on various technical specifications and non-clinical testing.

    Feature/Function/TestPredicate Device (K132967) PerformanceProposed Device (K141770) PerformanceAcceptance Criteria (Inferred from Substantial Equivalence)Outcome
    Therapy DeliveredCPAP, Auto CPAPCPAP, Auto CPAPSameMeets
    Operation Temperature5 to 30° C (41 to 86°F)5 to 35° C (41 to 95°F)Comparable (Proposed has wider range)Meets
    Storage/Transport Temperature-20 to 55° C-25 to 70° CComparable (Proposed has wider range)Meets
    Humidity≤ 80% Non-condensing15% to 93% Non-condensingComparable (Proposed has wider range)Meets
    Atmospheric Pressure86 to 106 kPa76 to 106 kPaComparable (Proposed has wider range)Meets
    Standards ComplianceIEC 60601-1, IEC 60601-1-2, ISO 8185IEC 60601-1, IEC60601-1-11, IEC 60601-1-2Complies with relevant safety and performance standardsMeets
    Mode of OperationContinuousContinuousSameMeets
    AC Power Consumption100-240VAC, 50/60Hz, 1.0A max100-240VAC, 50/60Hz, 2.0A maxComparable (Proposed has higher current draw)Meets
    SoftwareMicroprocessor controlledMicroprocessor controlledSameMeets
    System ContentsAir blower, pressure-flow monitoring, pressure controlling, user interface, heated humidifier, power cord, carrying case, user manual.Air blower, pressure-flow monitoring, pressure controlling, user interface, heated humidifier, power cord, carrying case, user manual.SameMeets
    Type of Protection Against Electric ShockClass II EquipmentClass II EquipmentSameMeets
    Degree of Protection Against Electric ShockType BF Vertical Applied PartType BF Vertical Applied PartSameMeets
    Degree of Protection Against Ingress of WaterIPX1-Drip-Proof, VerticalIP22Comparable (Both provide protection, with IP22 generally indicating protection against solid objects >12.5mm and direct sprays of water up to 15 degrees from the vertical, while IPX1 protects against vertically falling drops of water).Meets
    Pressure Range4-20 cmH2O (in 0.5 cmH2O increments)4-20 cmH2O (in 0.5 cmH2O increments)SameMeets
    Sound Pressure Level<30 dB, at 10 cmH2O<30 dB, at 10 cmH2OSameMeets
    HousingFlame retardant Engineering thermoplasticFlame retardant Engineering thermoplasticSameMeets
    Pressure Display Accuracy± 0.5 cmH2O± (0.5+4%) cmH2OComparable (Proposed slightly different notation, needs to meet or be within acceptable variance of predicate)Assumed Met
    Ramp (minutes)0-600-60SameMeets
    Mask off alertYesYesSameMeets
    Integrated HumidifierYesYesSameMeets
    Water Capacity (Humidifier)> 350 ml350 ml at recommended water levelSimilarMeets
    Heater Settings (Humidifier)1 to 5 (104 to 149 °F)1 to 5 (95 to 167 °F)Comparable (Proposed has wider range)Meets
    Pressure Drop with Humidifier< 0.5 cmH2O at 60 LPM flow< 0.4 cmH2O at 60 LPM flowBetter than predicateMeets
    Humidity Range (Humidifier)10 to 40 mg H2O/L>10mg/LComparable (Proposed specified as >10mg/L, implies it's within or exceeds the lower bound of predicate)Assumed Met
    Static and dynamic pressure accuracies4 to 20 cmH2O (± 1 cmH2O)4 to 20 cmH2O (± 1 cmH2O)SameMeets
    BiocompatibilityTested and passed in K132967No new testing, relies on predicateMaterials are identical, so previous testing is sufficientMeets
    Particulate matter and volatilesDemonstrated compliance in K132967No new testing, relies on predicateAssumed to be identical to predicateMeets

    Device Performance Evidence Summary: The study essentially asserts that the proposed device performs equivalently to the predicate device. The performance data presented is a side-by-side comparison of specifications for both devices, highlighting that the proposed device shares the same intended use, operating principle, technology, materials, and manufacturing process as the predicate, or has comparable or slightly improved characteristics.

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

    This document describes a premarket notification (510(k)) that relies heavily on bench testing and comparison to a predicate device, not clinical trials with human subjects.

    • Test Set: No independent human subject test set is described. The "test set" consists of bench performance tests comparing the proposed device to the predicate.
    • Sample Size: Not applicable in the context of human data. The sample size for non-clinical testing (e.g., number of devices tested for pressure accuracy) is not specified, but it's implied that sufficient units were tested to demonstrate performance.
    • Data Provenance: The document does not provide information about the country of origin for any human data (as there isn't any mentioned). The testing itself is non-clinical, likely conducted by the manufacturer (BMC Medical CO., LTD, CHINA). The study is retrospective in the sense that it refers to the performance and testing of the predicate device (K132967) for many aspects, and current bench testing for the proposed device.

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

    This type of information is not applicable to this 510(k) submission.

    • Ground Truth: The "ground truth" for this submission is established through engineering and performance specifications and compliance with international standards (e.g., ISO, IEC), rather than expert consensus on medical outcomes or pathology.
    • Experts: The document does not describe the involvement of medical experts to establish a "ground truth" for a test set. Engineering and regulatory specialists would be involved in designing and evaluating the bench tests.

    4. Adjudication Method for the Test Set

    This is not applicable. There is no "test set" in the sense of a set of cases requiring adjudication by multiple experts. The evaluation is based on objective measurements from bench testing against predefined engineering 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, an MRMC comparative effectiveness study was not done. This device is a CPAP/Auto-CPAP system for delivering positive pressure, not an AI-assisted diagnostic or interpretative tool that would involve human "readers" or AI assistance in a clinical setting.

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

    This question is not applicable as the device is not an algorithm that functions in a standalone diagnostic capacity. It is a medical device for therapeutic delivery of positive pressure.

    7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.)

    The "ground truth" used for this submission is based on:

    • Engineering Specifications and Performance Standards: Defined by international standards (ISO 17510-1:2007, IEC 60601 series) and the specifications of the predicate device.
    • Performance Bench Testing: Objective measurements conducted in a laboratory setting to verify that the device meets its design specifications (e.g., pressure accuracy, sound level, humidification, electrical safety).
    • Biocompatibility Testing: Conducted in the predicate device against ISO 10993 standards, and carried over due to identical materials.

    8. The Sample Size for the Training Set

    This is not applicable. The device is not based on machine learning or AI that requires a "training set" of data.

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

    This is not applicable as there is no training set for this device.

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