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510(k) Data Aggregation

    K Number
    K170185
    Date Cleared
    2017-09-12

    (232 days)

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

    K111587

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

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

    Device Description

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

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

    AI/ML Overview

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

    1. Table of Acceptance Criteria and Reported Device Performance

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

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

    Table: Derived Acceptance Criteria and Reported Device Performance

    Feature/SpecificationAcceptance Criteria (Derived or Standard)TremoFlo C-100 Reported Performance
    Indications for UseEquivalent to Predicate: Measure respiratory system impedance using FOT for pediatric and adult patients (4+ years), used by trained personnel.Identical to predicate.
    Fundamental Scientific TechnologyEquivalent to Predicate: Forced Oscillation Technique and Pneumotach per ERS FOT recommendations.Identical to predicate.
    Pneumotach Flow RangeSufficient for FOT measurements (Predicate: ± 2 L/s).± 2.5 L/s (Increased flow range compared to predicate).
    Flow ResolutionSufficient for FOT measurements (Predicate: ± 4.6 mL/s).± 1.4 ml/s (Slightly better than predicate).
    Flow LinearityWithin ranges to provide equivalent performance per bench testing (Predicate: ± 2% up to 1.5 L/s).± 2% up to 1.0 L/s (Differences are small and still within ranges to provide equivalent performances in both devices per bench testing).
    Common Mode Rejection Ratio (CMRR)Provide accurate and reproducible results equivalent to predicate (>60dB over entire range of forcing frequencies).Alternate dynamic software compensation (Provided accurate and reproducible results equivalent to those provided by the predicate based on performance testing).
    Device Load to Patient<1 cmH2O at 1L/s (Predicate).1.0 ± 5% cmH2O.s/L at 1 L/s (Difference in resistance to flow is small and within potential variation of resistance for bacterial/viral filters).
    Volume RangeSufficient for FOT measurements (Predicate: ± 2 Liters).±3 Liters (Increased volume range).
    Volume AccuracyEqual to or better than predicate (<3.5% or 0.050 L).<3.0% or 0.050 L (whichever is greater) (Slightly greater volume accuracy).
    Mouth Pressure LinearityWithin ERS FOT Recommendation of 2% up to 5 cmH2O (Predicate: ±0.050% of full scale up to 2.5 cm H2O).2% of full Scale up to 5 cm H2O (Differences are small and still within ranges to provide equivalent performances per bench testing and meeting ERS FOT Recommendation).
    Mouth Pressure ResolutionEqual to or better than predicate (0.015 cmH2O).0.0053 cmH2O (0.0039 mmHg) (Better resolution).
    Mouth Pressure RangeSufficient for FOT measurements (Predicate: ± 2.5 cmH2O).± 10 cmH2O (Increased Mouth Pressure Range).
    Effective Device Dead SpaceEquivalent to predicate (35 ml).35 ml (Equivalent).
    Test Signal/Frequency RangeSinusoidal signal at specific frequencies, within medium frequency range per ERS FOT Recommendation (Predicate: 5-37Hz).Sinusoidal signal at specific frequencies, between 5-41Hz (Slightly increased user selectable frequency range; still within medium frequency range per ERS FOT).
    Pseudo-Random Noise StimulusFrequency range sufficient for FOT (Predicate: 5-37 Hz).5-37 Hz, 7-41 Hz (Offers a slightly increased frequency range).
    Multi-Frequency Stimulus AccuracyAccuracy equivalent to predicate as per performance bench testing; frequencies within medium range per ERS FOT Recommendation.Accuracy equivalent to predicate as per performance bench testing (Offers a slightly increased frequency range, 5-11-19, 5 to 37 and 7 to 41 Hz). Frequencies still within medium frequency range per ERS FOT Recommendation.
    Calculated Impedance ParametersIdentical parameters to predicate; substantially equivalent performance per bench testing.Identical parameters to predicate, with additional AX and R5-R20 (Performances were substantially equivalent as per bench testing).
    Calculated Breathing Pattern ParametersIdentical parameters to predicate; substantially equivalent performance per bench testing.Identical parameters to predicate (Substantially equivalent performances as per bench testing).
    Electrical Safety & EMCCompliant with ES60601-1:2005 +A2012 (IEC60601-1, Edition 3.1) and IEC 60601-1-2:2007.Compliant as per standards (Equivalent).
    BiocompatibilityAcceptable VOC, Carbon Monoxide, Carbon Dioxide, Ozone and particulate matter levels from breathing pathways per ISO 10993-1 and FDA Guidance.Testing performed to verify acceptable levels consistent with indirect patient contact (Equivalent).
    Cleaning/DisinfectionValidated with labelled cleaning and low-level disinfection method per FDA guidance.Validated as per FDA guidance (Equivalent).

    Study Proving Device Meets Acceptance Criteria:
    The document states that no clinical study was conducted. Instead, the device met the acceptance criteria through a series of non-clinical performance data and bench testing. The primary method for demonstrating performance against criteria was by showing substantial equivalence to a legally marketed predicate device (Resmon PRO FULL), supported by adherence to relevant international standards and guidelines (e.g., ERS FOT recommendations, ISO, IEC).

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

    • Sample Size for Test Set:
      • The document mentions "Reproducibility and Repeatability 3 units were tested with repeated measurements," indicating a sample size of 3 physical device units for this specific test.
      • For other bench tests, the sample size is not explicitly stated in terms of number of devices or number of test cases/simulations, but it generally refers to laboratory testing.
    • Data Provenance:
      • All data presented is from non-clinical bench testing and internal validation.
      • The testing was conducted by Thorasys Thoracic Medical Systems, Inc. (The company developing the device) and was reviewed for the 510(k) submission.
      • It is retrospective in the sense that it's laboratory validation performed prior to submission, rather than prospective clinical trials.
      • The country of origin of the data is implicitly Canada, where Thorasys Thoracic Medical Systems, Inc. is located.

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

    • Number of Experts: Not applicable. The ground truth for the non-clinical bench testing involved physical measurements against known standards or comparison with a predicate device. It did not involve human experts establishing ground truth for diagnostic interpretation.
    • Qualifications of Experts: Not applicable.

    4. Adjudication Method for the Test Set

    • Adjudication Method: Not applicable. Since no human expert-based ground truth was established, there was no need for an adjudication method. The testing involved objective measurements and comparisons to engineering specifications, established standards, or the predicate device's performance.

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

    • MRMC Study: No, a multi-reader multi-case (MRMC) comparative effectiveness study was not done. The study explicitly states: "No clinical study was conducted."

    6. Standalone Performance Study (Algorithm Only)

    • Standalone Study: Yes, a "standalone" or "algorithm-only" performance was conducted in the sense that the device's inherent measurement capabilities and "impedance and breathing pattern parameters" were assessed through bench testing. This refers to the device's technical specifications and how accurately it measures physical properties, irrespective of human interpretation in a clinical context. The performance data section lists:
      • "Device measurement performance –testing to compare the performance specifications (impedance and breathing pattern parameters) between the predicate and the tremoFlo device."
      • "Reproducibility and Repeatability 3 units were tested with repeated measurements and the results demonstrated consistency between the different devices and for multiple measurements with variations < 2.5%."
      • The comparisons in the "Predicate Product Comparison" table also reflect standalone performance.

    7. Type of Ground Truth Used

    • Type of Ground Truth: The ground truth for the non-clinical testing was based on:
      • Engineering specifications and known physical standards: For measurements like flow range, resolution, linearity, pressure, volume, etc.
      • Performance of a legally marketed predicate device (Resmon PRO FULL): The Tremoflo C-100's features and performance were directly compared to the predicate to demonstrate substantial equivalence.
      • International standards and guidelines: Such as the European Respiratory Society (ERS) FOT recommendations (Oostveen et al., Eur Respir J 2003), AAMI ES60601-1, IEC 60601-1-2, ISO 10993-1, and FDA guidance documents for biocompatibility, cleaning/disinfection, and software validation.

    8. Sample Size for the Training Set

    • Sample Size for Training Set: Not applicable. This device is a measurement system and not an AI/Machine Learning algorithm that requires a "training set" in the conventional sense. Its function is based on physical principles (Forced Oscillation Technique) rather than learning from data.

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

    • Ground Truth for Training Set: Not applicable, as no training set was used for an AI/ML model.
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