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510(k) Data Aggregation

    K Number
    K103058
    Date Cleared
    2011-11-10

    (392 days)

    Product Code
    Regulation Number
    870.1130
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Multifunction Keito devices are intended to be used by general public without prescription, operated with coins, to measure personal health parameters such as weight, estimation of body fat index, blood pressure, and pulse rate. Multifunction Keito can be installed in pharmacies or in other public sites. It is not a diagnostic device, and only offers data that users can consult with their personal physicians. The results are either printed on a ticket or saved on a card.

    Device Description

    The Multifunction Keito K6, K7 & K8 are intended for public use to measure height, weight, systolic and diastolic blood pressures, to calculate pulse rate and body mass, and to estimate the percentage of body fat by using a non-invasive bio impedance analyzer. The devices have 2 coin entries allowing the selection of two operation modes: partial or total cycle of measurements. Partial cycle measures weight, height, and estimation of body fat. Total cycle measures weight, height, blood pressure, pulse rate, and estimation of body fat.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and the studies that illustrate how the Keito K6, K7, and K8 multifunction devices meet these criteria, based on the provided text:

    Acceptance Criteria and Device Performance

    The provided document details the accuracy specifications of the Keito devices and presents comparative studies against predicate devices and observed/manual measurements to demonstrate substantial equivalence. The "acceptance criteria" here are implied by the comparison to established predicate devices and the accuracy claims.

    Table 1: Acceptance Criteria and Reported Device Performance

    ParameterAcceptance Criteria (from predicate/accuracy claim)Keito K7 Reported Performance (Mean Difference vs. Observers)Keito K5 Reported Performance (Mean Difference vs. Observers)Keito K8 Reported Performance (Error Medium vs. Tanita)
    Blood Pressure
    Systolic Accuracy1 mmHg (claimed)-0.6 mmHg (K7-Observers)1.0 mmHg (K5-Observers)N/A
    Diastolic Accuracy1 mmHg (claimed)0.4 mmHg (K7-Observers)-0.7 mmHg (K5-Observers)N/A
    Pulse AccuracyNot explicitly stated0.9 bpm (K7-Observer)-1.4 bpm (K5-Observer)N/A
    Weight100 g (claimed)N/AN/AN/A
    Height1 cm (claimed)N/AN/AN/A
    Body Fat0.1% (claimed)N/AN/A-0.4% (K8-Tanita TBF-300)

    Note: The "Acceptance Criteria" column is derived from the stated accuracy of the devices and their predicates. The "Reported Device Performance" comes directly from the study results presented in the tables for K7 Blood Pressure and K8 Body Fat. The overall conclusion for blood pressure is that K7 performance is "very similar" to K5, implying K7 meets K5's established performance. For Body Fat, the results are considered "safe and accurate as TANITA TBF-300."


    Study Details

    2. Sample Sizes and Data Provenance

    • Blood Pressure Measurement (Multifunction K7 Test Results):
      • Test Set Sample Size: 267 observations for Systolic, Diastolic, and Pulse measurements. 89 patients for Age, Wrist/Arm circumference, and Sex data.
      • Data Provenance: Not explicitly stated, but the submission is from a Spanish company (Aguiflail Ibérica, S.L., Barcelona, Spain), suggesting the study was likely conducted in Spain. The data is presented as a "clinical test," implying prospective collection for the purpose of this submission.
    • Body Fat Measurement (Keito K8 vs. TANITA TBF-300):
      • Test Set Sample Size: 177 observations.
      • Data Provenance: Not explicitly stated, but similar to the blood pressure study, it's likely from Spain and prospectively collected for this comparative study.

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

    • Blood Pressure Measurement: The study compares the Keito K7 (and K5) devices against "Observers."
      • Number of Experts: "Observer1" and "Observer2" are mentioned for inter-observer variability, and the device is compared against these "Observers." This implies at least two human observers.
      • Qualifications: The qualifications of these observers are not specified in the provided document. It is not mentioned if they are medical professionals like cardiologists or nurses, nor is their experience level given.
    • Body Fat Measurement: The Keito K8 is compared against the TANITA TBF-300 device. The ground truth for body fat is not established by human experts but by an established predicate device.

    4. Adjudication Method for the Test Set

    • Blood Pressure Measurement: For "Observer1 - Observer2" comparison, a simple comparison of their readings is used to assess inter-rater agreement. For "Keito K7 - Observers" (and K5), the device readings are compared directly against the readings of the human observers. No specific adjudication method (like 2+1 or 3+1 consensus) is described to resolve discrepancies between human observers or between the device and human observers. The "Mean Difference" and "SD of Differences" statistical metrics are used for comparison.
    • Body Fat Measurement: The Keito K8 device measurements are compared directly to the TANITA TBF-300 predicate device measurements. No human adjudication is involved as the predicate device serves as the reference.

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

    • No MRMC study evaluating human reader improvement with AI assistance was explicitly performed or detailed. The studies here are focused on demonstrating the standalone performance of the device (Keito K7/K8) in comparison to either human observers (for BP) or a predicate device (for Body Fat), not on how AI (or the device's algorithms) assists human readers. The Keito devices are intended for public self-use and are not diagnostic tools requiring human interpretation of their output.

    6. Standalone (Algorithm Only) Performance

    • Yes, standalone performance was assessed. The studies presented (7.1.1 and 7.1.2 for Blood Pressure, 7.2 for Body Fat) represent the standalone performance of the Keito K7, K5, and K8 devices, respectively. The data shows the device's measurements compared to a reference (human observers for BP, predicate device for Body Fat) without human intervention in the device's measurement process itself. The devices operate "without prescription" and provide results directly to the user.

    7. Type of Ground Truth Used

    • Blood Pressure Measurement: The ground truth for blood pressure and pulse rate is established by human observers (referred to as "Observer1" and "Observer2") directly measuring the same parameters. This effectively serves as a "clinical reference standard" in this context.
    • Body Fat Measurement: The ground truth for body fat percentage is established by a predicate device, the TANITA TBF-300. This is a comparative study where the predicate device acts as the reference standard.

    8. Sample Size for the Training Set

    • The document does not provide details on the sample size used for the training set for the algorithms within the Keito devices. The studies described are validation/testing studies for device performance. It states that the K6, K7, and K8 are an "evolution" of the K5 unit, implying that the underlying technology and software have a history of development, but the specifics of training data are not disclosed.

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

    • As the document does not specify a training set or its sample size, it also does not detail how the ground truth for any training set was established. We can infer that the original Keito K5, and presumably its predecessors or early development, would have been built and refined using data, likely compared against established measurement techniques or other reference devices, similar to the validation studies presented here. However, this is an inference and not explicitly stated in the provided text.
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    K Number
    K984083
    Date Cleared
    2000-01-18

    (428 days)

    Product Code
    Regulation Number
    870.1130
    Reference & Predicate Devices
    N/A
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Multifunction KEITO K5 is intended to be used by adults in order to measure height, weight, systolic and diastolic blood pressures, and to calculate pulse rate.

    Device Description

    The Multifunction KEITO K5 (K5) is designed to provide the user with measurements of blood pressure, height, and weight, as well as to calculate the Body Mass Index (BMI) and pulse rate. The user is prompted to select a measurement cycle, step onto the K5 platform, and wait momentarily while the measurements and calculations are performed. After the measurements have been taken, the K5 provides the user with the results. To operate the K5 the user inserts a coin into the coin slot, and steps onto the platform. The user has the option of selecting a partial measuring cycle or a complete cycle. In a partial cycle, weight and height measurements are taken and Body Mass Index calculations are performed in the partial cycle. In a complete cycle, weight, height, blood pressure, and pulse measurements are taken. Body Mass Index is calculated and the W.H.O. blood pressure recommendations are provided. The K5 prints out a ticket containing the results of the measurements and the recommended ranges for both BMI and blood pressure.

    AI/ML Overview

    Here's an analysis of the acceptance criteria and study information for the Multifunction KEITO K5, based on the provided document:

    1. Acceptance Criteria and Reported Device Performance

    Performance MetricAcceptance Criteria (Implicit)Reported Device Performance
    Blood Pressure AccuracyMet the acceptance requirements of German regulations (BGBI.IS.759, 771 and 1667) for clinical testing of blood pressure systems."The results were evaluated in accordance with the acceptance requirements of the regulation (BGBI.IS.759, 771 and 1667) and found to be acceptable."
    Height CompensationDeveloped a formula to compensate for user height during wrist cuff blood pressure measurements based on statistical methodologies."Based on the results, a formula was developed to compensate for user height during wrist cuff blood pressure measurements."

    2. Sample Size and Data Provenance for Test Set

    • Blood Pressure Accuracy Test:
      • Sample Size: Not explicitly stated, but the test compared the K5 to a manual sphygmomanometer.
      • Data Provenance: The testing was conducted by Physikalisch-Technische Bundesanstalt (a German national metrology institute), implying the data was collected in Germany. It is implied to be prospective testing for regulatory approval.
    • Height Compensation Test:
      • Sample Size: "multiple users of different heights, ages and sex." The exact number is not specified.
      • Data Provenance: Not explicitly stated, but likely conducted by the manufacturer or a third-party testing facility. It is implied to be prospective.

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

    • Blood Pressure Accuracy Test:
      • The "ground truth" was established by a manual sphygmomanometer, which is the gold standard for clinical blood pressure measurement.
      • The document does not specify the number or qualifications of clinicians/technicians operating the manual sphygmomanometer, but it's implied they were trained professionals given the regulatory context.
    • Height Compensation Test:
      • The ground truth for blood pressure measurements in this test would also be the manual sphygmomanometer.
      • No specific experts mentioned for validating the compensatory formula itself, beyond the statistical methodologies applied.

    4. Adjudication Method for the Test Set

    • No specific adjudication method (like 2+1, 3+1 consensus) is described.
    • For the blood pressure accuracy, the comparison was directly between the device and the manual sphygmomanometer, with results being "evaluated in accordance with the acceptance requirements of the regulation." This suggests a direct comparison against a standard rather than expert adjudication of AI outputs.

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

    • No MRMC comparative effectiveness study was mentioned. The device is a standalone measurement system, not an AI assisting human readers.

    6. Standalone Performance Study

    • Yes, a standalone performance study was done.
      • The pressure system of the Multifunction KEITO K5 was tested by Physikalisch-Technische Bundesanstalt to verify its accuracy against a manual sphygmomanometer.
      • Additional testing was conducted on the K5 to determine correct user height compensation.

    7. Type of Ground Truth Used (Test Set)

    • Blood Pressure Accuracy Test: Comparison against a gold standard (manual sphygmomanometer).
    • Height Compensation Test: Comparison against a gold standard (manual sphygmomanometer), along with objective measurements of height, age, and sex.

    8. Sample Size for the Training Set

    • The document does not explicitly describe a "training set" in the context of an AI/machine learning model. The K5 is described as a non-invasive blood pressure measurement system, not an AI-driven diagnostic or image analysis tool that would typically have a distinct training set.
    • The "formula was developed to compensate for user height" based on testing "multiple users of different heights, ages and sex." This process of developing the formula might be considered analogous to a training phase, but the sample size is not specified beyond "multiple users."

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

    • As above, the concept of a "training set" for an AI model isn't directly applicable here.
    • If we consider the development of the height compensation formula as an analogous process, the "ground truth" for developing this formula was established by using manual sphygmomanometer readings and objective user height measurements from "multiple users of different heights, ages and sex." The formula was then derived using "statistical methodologies" to correlate these measurements and compensate for variations.
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