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510(k) Data Aggregation

    K Number
    K241091
    Manufacturer
    Date Cleared
    2024-12-23

    (245 days)

    Product Code
    Regulation Number
    868.5665
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K203209, K122111

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

    The SIMEOX 200 airway clearance device is intended to promote airway clearance and to improve bronchial drainage by enhancing mobilization of bronchial secretions via high frequency oscillatory vibrations and intermittent negative pressure to the airway during exhalation. The device is intended to be prescribed for use in patients capable of independently generating cough.

    SIMEOX 200 is intended for use in the home, hospital, and other healthcare institutions by individuals weighing at least 23 Kg.

    Device Description

    The SIMEOX 200 Airway Clearance Device consists of a portable generator and a single patient use expiratory kit. The patient inhales from the ambient environment, naturally and independent of the device, and then exhales into the device mouthpiece. During the patient's exhalation, the SIMEOX 200 generates a pneumatic vibration throughout the airway. This vibration, applied at 6 Hz or 12 Hz via negative pressure pulses, disseminates throughout the bronchial tree in order to decrease mucus viscosity and increase secretion mobility. During or after therapy, the patient can clear the secretions by coughing independently.

    AI/ML Overview

    This document describes the FDA's 510(k) clearance for the SIMEOX 200 Airway Clearance Device. It primarily focuses on demonstrating substantial equivalence to predicate devices through technical specifications and non-clinical performance testing.

    The provided text does not contain information about acceptance criteria or a study proving the device meets those criteria in the context of human-in-the-loop performance, AI assistance, or expert-based ground truth establishment for diagnostic purposes.

    The document states:

    • "Performance verification testing was conducted on the bench with the SIMEOX 200 Airway Clearance Device to demonstrate the subject device performs to its pre-specified requirement specifications, which align with those of the predicate devices."
    • "The SIMEOX 200 device also went through comprehensive software verification and validation testing to confirm the device operates within specification."
    • "Testing demonstrated the SIMEOX 200 performed as intended and was safe and effective."
    • "A human factors validation study was conducted with simulated first-time use of the product in adult users and dyads of children with caregivers. The study concluded that the device is safe for its intended users."

    This indicates that the "acceptance criteria" and "study that proves the device meets the acceptance criteria" in this context refer to engineering and safety performance specifications, rather than clinical performance metrics typically associated with AI/diagnostic devices (like sensitivity, specificity, or reader improvement).

    Therefore, I cannot populate the requested table and study details as they are not present in the provided text. The document describes a medical device (Airway Clearance Device), not an AI or diagnostic device that would typically involve the type of acceptance criteria and studies you've outlined.

    The acceptance criteria implied are the device's ability to meet its pre-specified parameters (e.g., pressure range, oscillation frequencies) and demonstration of safety and effectiveness through bench testing, software validation, and human factors validation.

    Here's a summary of the information that is available, reframing it in the context of device performance rather than AI/diagnostic performance:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Implied from document)Reported Device Performance (from document)
    Technical Specifications:
    Exhalation Pressure (Negative)0 to -60 cm H2O. Stated as "nearly identical to that of SimplyClear and falls within a subset of the SimplyClear available negative pressure range."
    Inhalation Pressure (Positive)Atmospheric (0 cm H2O). Bench verification testing confirms operation within prespecified operating specifications for negative pressure delivery, consistent with predicate devices in exsufflation-only mode.
    Oscillation FrequenciesFixed Frequencies: 12 Hz (first 8 phases), 6 Hz (final 2 phases). Stated as "within the available frequencies during SimplyClear treatment."
    Power ModesStandard Mode (25%, 50%, 75%, 100% power) and ADAPT Mode (automatically regulated). Stated as "operating conditions are within the range available for the SimplyClear."
    Trigger SettingsManual Trigger or DETECT Trigger.
    Cycle Duration10 breaths (exhalations).
    Duration of TreatmentMax 10 cycles (100 exhalations) or 60 minutes, whichever occurs first.
    Safety and Effectiveness:
    BiocompatibilityExpiratory kit accessories not considered cytotoxic, sensitizing, or irritating; demonstrated biocompatible.
    Human FactorsDevice safe for intended users (adults, children with caregivers) in simulated first-time use.
    Software Verification & ValidationConfirmed device operates within specification.
    Cybersecurity, Wireless, EMC, Electrical,Comprehensive testing conducted.
    Mechanical, Thermal Safety
    Overall PerformanceBench testing confirms device complies with specifications, operates equivalently to predicates, is as safe, as effective, and performs as well as legally marketed predicate devices. "Performed as intended and was safe and effective."

    Regarding the other requested information, it is largely not applicable or not provided for this type of device and submission:

    2. Sample size used for the test set and the data provenance:
    * Test Set: Not explicitly stated in terms of a "test set" for performance metrics like sensitivity/specificity. Performance testing was "on the bench" and included software V&V and human factors simulation.
    * Data Provenance: Not applicable for this type of technical/safety validation. The human factors study involved "simulated first-time use," but details about participant numbers or demographic provenance are not provided.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
    * This is not relevant for this device's 510(k) submission, as it's not a diagnostic device requiring expert interpretation for ground truth.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
    * Not applicable.

    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, as this is not an AI-assisted diagnostic device.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
    * Not applicable, as this is not an AI/algorithm-driven device in the sense of image analysis or diagnostic prediction. Its "performance" is based on its physical and software operation parameters.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
    * "Ground truth" in this context refers to the pre-defined engineering specifications and safety standards (e.g., pressure measurements, frequency measurements against a calibrated standard, successful execution of software functions, successful completion of simulated tasks in human factors). It's not a clinical or diagnostic ground truth.

    8. The sample size for the training set:
    * Not applicable. This device does not use machine learning that requires a "training set."

    9. How the ground truth for the training set was established:
    * Not applicable.

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    K Number
    K140598
    Manufacturer
    Date Cleared
    2014-10-16

    (220 days)

    Product Code
    Regulation Number
    868.5905
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K002598, K072292, K121955, K122111

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

    The PEGASO A-COUGH PERC is designed for the use on patients unable to cough or clear secretions effectively due to reduced peak cough expiratory flow, resulting from high spinal cord injuries, neuromuscular deficits or severe fatigue associated with intrinsic lung disease. It may be used either with a facemask, mouthpiece, or an adapter to a patient's endotrached tube. For use in hospital, institutional setting, or home use given adequate training.

    For use on adult patients and pediatric patients 3 years old and up.

    The PEGASO A-COUGH is designed for the use on patients unable to cough or clear secretions effectively due to reduced peak cough expiratory flow, resulting from high spinal cord injuries, neuromuscular deficits or severe fatigue associated with intrinsic lung disease. It may be used either with a facemask, mouthpiece, or an adapter to a patient's endotracheal tube or tracheostomy tube. For use in hospital, institutional setting, or home use given adequate training.

    For use on adult patients and pediatric patients 3 years old and up.

    The PEGASO COUGH is designed for the use on patients unable to cough or clear secretions effectively due to reduced peak cough expiratory flow, resulting from high spinal cord injuries, neuromuscular deficits or severe fatigue associated with intrinsic lung disease. It may be used either with a facemask, mouthpiece, or an adapter to a patient's endotracheal tube. For use in hospital, institutional setting, or home use given adequate training.

    For use on adult patients and pediatric patients 3 years old and up.

    The Dima Italia Srl Pegaso Cough assists patients in clearing retained bronchopulmonary secretions by gradually applying a positive pressure to the airway, then rapidly shifting to a negative pressure. This rapid shift in pressure, via a facemask, mouthpiece or an endotracheal or tracheostomy tube, produces a high expiratory flow rate from the lungs, simulating a cough.

    Device Description

    The Dima Italia Srl Pegaso Cough is an electric device useful in clearing retained bronchopulmonary secretions. It acts a "cough" patient simulation, applying a positive air pressure to the airway, then rapidly shifting to a negative air pressure. At the end of this pressure shifting, the Pegaso Cough leaves the airways free, at zero pressure, for a pause time determined by operator.

    The Inspiratory Flow rising time can be selected on four levels: Peak, High, Medium, Low.

    This "Forced Insufflation" is destinated to patients with reduced coughing possibilities due to muscular dystrophy, myasthenia gravis, poliomyelitis respiratory muscles paralysis, such as spinal cord injury. Even patients with other diseases, such emphysema, cystic fibrosis, can be treated with Pegaso Cough.

    It can be used with a facemask or, with an adapter, to an endotracheal or tracheostomy tube.

    The Pegaso Cough is realized with a blower, used as pressure and flow generator, and a mechanical valve, commanding the sign and the air pressure intensity outing to the patient.

    The blower takes air from atmosphere, and compresses it in order to generate a positive or negative pressure. The pressure value is controlled by an electronic sensors.

    In order to reduce the risks of adverse reactions, an (optional) Masimo oximeter has been added.

    An optional flow sensor (trigger) has been added in order to synchronize the inspiration cycles to the first or all the inspiratory efforts of the patient.

    An optional high frequency oscillatory vibration (percussion mode) has been added in order to help to clear retained bronchopulmonary secretions.

    So, Pegaso Cough (without options), Pegaso A-Cough (with the trigger option), Pegaso A-Cough Perc (with trigger and percussion options) identification names will be used.

    Pegaso Cough, Pegaso A-Cough, Pegaso A-Cough Perc are equivalent devices.

    The Inspiratory/Expiratory cycles are determined by the blower rotation and the mechanical valve positioning. This valve is connected to a step-motor, whose position is detected through an optical sensor. The valve lets the positive flow go toward the patient and the negative flow toward the atmosphere or, instead, the positive flow to the atmosphere and the negative flow toward the patient.

    The working parameters are visualized on a colour TFT display and modified through a touch keyboard.

    AI/ML Overview

    The provided text describes the Pegaso Cough, Pegaso A-Cough, and Pegaso A-Cough Perc devices, which are noncontinuous ventilators. The submission is a 510(k) premarket notification for device modifications.

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

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly state formal acceptance criteria with specific thresholds for device performance. Instead, it details that various features and modifications were verified to meet product requirements/specifications or performed as intended. The "performance data" section focuses on testing methodologies and successful verification of features against design inputs and product specifications, rather than numerical performance metrics against pre-defined acceptance criteria.

    However, based on the Comparison of Device technological Characteristics to predicate device and Device Modification Testing Summary, we can infer some performance expectations and the results of the testing:

    Feature/CharacteristicAcceptance Criteria (Inferred from Predicate Equivalence & Product Requirements)Reported Device Performance
    Cough Assist FunctionalityEquivalent to predicate devices (Emerson Cough Assist K002598, Dima Italia Negavent DA-3 Plus Pegaso K072292, Philips Respironics CoughAssist T70 K121955) in clearing bronchopulmonary secretions."substantially equivalent" to predicate devices in secretion clearance functionality (Pegaso Cough, Pegaso A-Cough Perc). Performance verified through black-box performance testing and simulations of worst-case scenarios.
    Percussion FeatureSimilar to oscillatory vibrations of Philips Respironics SimplyClear (K12211) for mucus loosening and mobilization. Met product specifications."similar to the oscillatory vibrations of the Philips Respironics SimplyClear (K122111)." Verified to meet product specifications. Bench testing at extreme therapy settings executed, and waveforms on lung simulator were "as attended" (as expected). Note: Maximum percussion frequency is different from predicates (600cpm vs. 60-1200 bpm).
    User InterfaceDisplay functions, user controls, and informational messages perform as intended, including oximeter values. Proper data and expected therapy information displayed.Verified to meet product requirements. All display functions, user controls, and informational messages performed as intended, including oximeter values. Verified to ensure it displayed proper data and expected therapy information.
    EasyStart/AutoSyncOperate across the range of patient cases. Triggering performance functions as designed.Verified to meet product specifications with each defined patient case simulation. Operation and triggering performance verified to operate across the range of patient cases. Principles are similar to Philips Respironics CoughAssist T70 K121955 Cough-Trak feature.
    Data ManagementStore therapy data in internal memory and allow for data download to PC, meeting product specifications for EEPROM and download.Verified to meet product specifications for internal EEPROM and for downloading from a PC. All memory functions performed as intended.
    Oximetry ConnectionProper visualization of SpO2, Pulse rate, Perfusion Index; proper alarm activation; compliance with ISO 9919:2009.Tested for proper values visualization and proper alarm activation. All exception messages verified with bench testing and a clinical dynamic simulator. Complies with ISO 9919:2009.
    Case (Structure & Materials)Comply with product requirements (e.g., IEC 60601-1, ISO 10993-1, ISO 9919).Structure and materials tested to verify compliance to product requirements. Passed IEC 60601-1, ISO 10993-1, ISO 9919 tests. Third-party test reports cited.
    Electrical Safety ClassComply with product requirements (e.g., IEC 60601-1, IEC 60601-1-2).Tested to verify compliance with product requirements. Passed IEC 60601-1, IEC 60601-1-2. Third-party test reports cited.

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

    The document does not specify a separate "test set" in the context of patient data or clinical trials. The performance data discussed is based on non-clinical bench testing, black-box testing, white-box testing, software unit testing, code reviews, and simulations.

    • Sample Size: Not applicable in the traditional sense of patient samples. The testing involved various worst-case scenario inputs and simulations. For the oximeter verification, a "Clinical Dynamic Simulator Validation Report" was run.
    • Data Provenance: The data is generated from bench testing methodologies, simulating use environments and inputs for the device itself. It's retrospective in the sense that it evaluates the device's adherence to pre-defined specifications after manufacturing/design. No country of origin for patient data is mentioned as this was not a clinical study involving patients.

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

    Not applicable. This was a non-clinical, bench-testing focused evaluation. There were no "experts" establishing clinical ground truth for a patient test set, nor were patient outcomes involved. The ground truth for the engineering tests was the device's design specifications and regulatory standards.

    4. Adjudication Method for the Test Set

    Not applicable. No "adjudication method" in the context of expert review or consensus for patient data was performed. The verification activities (bench testing, code reviews, etc.) served as the method to determine if the device met its design inputs and relevant standards.

    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 study was done. This device is a noncontinuous ventilator used for secretion clearance, not an AI-assisted diagnostic or imaging device that would typically involve human "readers." The submission focuses on the safety and effectiveness of the device itself and its modifications, demonstrating substantial equivalence to predicates through engineering and performance testing.

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

    Yes, the testing described is primarily standalone device performance. The "device modification testing summary" and "non-clinical testing" sections detail evaluations of the device's various features (User Interface, AutoSync/EasyStart, Oscillations, Data Management, Oximetry Connection, Case, Electrical Safety) independent of human operators, ensuring the device functions according to specifications. While "AutoSync" and "EasyStart" relate to patient inspiratory effort, the testing of these features focuses on the device's ability to detect and respond to that effort, not on human-in-the-loop performance.

    7. The Type of Ground Truth Used (Expert Consensus, Pathology, Outcomes Data, etc.)

    The ground truth used for these non-clinical tests was the product design specifications, engineering requirements, and recognized international standards (e.g., ISO 14971, ISO 10993-1, IEC 60601-1, ISO 9919, IEC 62304). For the oximeter, a "Clinical Dynamic Simulator Validation Report" by Masimo was used, implying that the simulator's output served as the ground truth for oximetry values.

    8. The Sample Size for the Training Set

    Not applicable. This device does not employ machine learning or AI that would require a "training set" in the computational sense. The device's operation is based on programmed logic and physical mechanisms.

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

    Not applicable, as there was no training set for an AI/ML algorithm.

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    K Number
    K140605
    Manufacturer
    Date Cleared
    2014-10-03

    (207 days)

    Product Code
    Regulation Number
    868.5905
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    Philips Respironics CoughAssist T70 K121955, Respironics SimplyClear Percussor K122111

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

    The MINI PEGASO A-COUGH PERC is designed for the use on patients unable to cough or clear secretions effectively due to reduced peak cough expiratory flow, resulting from high spinal cord injuries, neuromuscular deficits or severe fatigue associated with intrinsic lung disease. It may be used either with a facemask, mouthpiece, or an adapter to a patient's endotracheal tube or tracheostomy tube. For use in hospital, institutional setting, or home use given adequate training. For use on adult patients and pediatric patients 3 years old and up.

    The MINI PEGASO A-COUGH is designed for the use on patients unable to cough or clear secretions effectively due to reduced peak cough expiratory flow, resulting from high spinal cord injuries, neuromuscular deficits or severe fatigue associated with intrinsic lung disease. It may be used either with a facemask, mouthpiece, or an adapter to a patient's endotracheal tube. For use in hospital, institutional setting, or home use given adequate training. For use on adult patients and pediatric patients 3 years old and up.

    The MINI PEGASO COUGH is designed for the use on patients unable to cough or clear secretions effectively due to reduced peak cough expiratory flow, resulting from high spinal cord injuries, neuromuscular deficits or severe fatigue associated with intrinsic lung disease. It may be used either with a facemask, mouthpiece, or an adapter to a patient's endotracheal tube. For use in hospital, institutional setting, or home use given adequate training. For use on adult patients and pediatric patients 3 years old and up.

    Device Description

    The Dima Italia Srl Mini Pegaso Cough is an electric device useful in clearing retained bronchopulmonary secretions. It acts a "cough" patient simulation, applying a positive air pressure to the airway, then rapidly shifting to a negative air pressure. At the end of this pressure shifting, the Mini Pegaso Cough leaves the airways free, at zero pressure, for a pause time determined by operator. The Inspiratory Flow rising time can be selected on four levels: Peak, High, Medium, Low. This "Forced Insufflation" is destinated to patients with reduced coughing possibilities due to muscular dystrophy, myasthenia gravis, poliomyelitis respiratory muscles paralysis, such as spinal cord injury. Even patients with other diseases, such emphysema, cystic fibrosis, can be treated with Mini Pegaso Cough. It can be used with a facemask or, with an adapter, to an endotracheal or tracheostomy tube. The Mini Pegaso Cough is realized with a blower, used as pressure and flow generator, and a mechanical valve, commanding the sign and the air pressure intensity outing to the patient. The blower takes air from atmosphere, and compresses it in order to generate a positive or negative pressure. The pressure value is controlled by an electronic sensors. In order to reduce the risks of adverse reactions, an (optional) Masimo oximeter has been added. An optional flow sensor (trigger) has been added in order to synchronize the inspiration cycles to the first or all the inspiratory efforts of the patient. An optional high frequency oscillatory vibration (percussion mode) has been added in order to help to clear retained bronchopulmonary secretions. So, Mini Pegaso Cough (without options), Mini Pegaso A-Cough (with the trigger option), Mini Pegaso A-Cough Perc (with trigger and percussion options) identification names will be used. Mini Pegaso Cough, Mini Pegaso A-Cough, Mini Pegaso A-Cough Perc are equivalent devices. The Inspiratory/Expiratory cycles are determined by the blower rotation and the mechanical valve positioning. This valve is connected to a step-motor, whose position is detected through an optical sensor. The valve lets the positive flow go toward the patient and the negative flow toward the atmosphere or, instead, the positive flow to the atmosphere and the negative flow toward the patient. The working parameters are visualized on a colour TFT display and modified through a touch keyboard.

    AI/ML Overview

    This document describes the Dima Italia Srl Mini Pegaso Cough, Mini Pegaso A-Cough, and Mini Pegaso A-Cough Perc devices, which are secretion clearance devices. The information provided is primarily focused on demonstrating substantial equivalence to existing predicate devices for FDA 510(k) clearance.

    Here's an analysis of the provided text in relation to your request:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly present a table of acceptance criteria with corresponding performance metrics like a typical clinical study would. Instead, it describes "product requirements" and various types of testing to verify that the device meets "specifications." The closest it comes to a direct comparison of performance is in the "Technological Characteristics" table (pages 11-12) which compares the Mini Pegaso Cough's specifications to those of predicate devices.

    Interpretation for Acceptance Criteria: The "acceptance criteria" here are implicitly the device's design input specifications and its ability to achieve performance comparable to predicate devices within those defined parameters.

    Reported Device Performance (Excerpted from "Technological Characteristics" and "Performance Data" sections):

    Acceptance Criteria (Implied from Device Specifications)Reported Device Performance (Mini Pegaso Cough K140605)
    Patient PopulationAdult or pediatric patient unable to cough or clear secretions effectively
    Delivery TypeNon Invasive or Invasive
    Modes of OperationManual and Auto
    Inhalation Pressure0 to 50 cmH2O (differs from some predicates with up to 70 cmH2O)
    Exhalation Pressure0 to -50 cmH2O (differs from some predicates with up to -70 cmH2O)
    Inhale FlowLow, medium, High, Peak
    Pause Time0 to 9.9 seconds
    Phases of Therapy CycleInsufflation, Exsufflation, Pause
    Safety ProtocolsDynamic Flow and Pressure control, Manufacturer Software Calibration, Sensor malfunction detection
    Percussion Frequency (if Percussion option present)50 to 600 bpm (differs from one predicate with up to 1200 bpm)
    Remote Data AccessInternal memory stores therapies data, RS232/USB adapter transmits to a PC
    User Interface and Display ParametersVerified to meet product requirements; displays proper data and therapy information, including oximeter values and alarms.
    AutoSync/EasyStart PerformanceVerified to meet product specifications across defined patient case simulations; operation and triggering performance verified.
    Oscillations (percussion) PerformanceVerified to meet product specifications; bench testing at extreme therapy settings executed, waveforms on lung simulator as attended.
    Data Management PerformanceVerified to meet product specifications for internal EEprom and PC downloading.
    Oximetry Connection PerformanceTested to verify pulse oximetry data performs as intended; proper values visualization and alarms tested; exception messages verified with bench and clinical dynamic simulator.
    Device Case ComplianceTested according to IEC 60601-1, ISO 10993-1, ISO 9919. Passed.
    Electrical Safety Class ComplianceTested according to IEC 60601-1, IEC 60601-1-2. Passed.
    Standards ComplianceDesigned and tested according to ISO 14971, ISO 10993-1, IEC 60601-1, IEC 60601-1-2, IEC 60601-1-6, ISO 9919, IEC 62304.

    Study Proving Acceptance Criteria:
    The document states that the devices were proven to meet these criteria through non-clinical testing, specifically:

    • Bench testing: including black-box and white-box testing.
    • Software unit testing.
    • Hardware unit testing (for SpO2 introduction).
    • Code reviews.
    • Clinical Dynamic Simulator Validation Report (specifically for oximeter verification, run by Masimo).

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

    • Test Set Sample Size: The document does not specify a numerical sample size for the test set. It refers to "patient case simulations" for AutoSync/EasyStart verification and "extreme therapy settings" for percussion testing, suggesting a range of conditions were tested on a bench/simulator, but no number of individual "cases" or "samples" is given.
    • Data Provenance: The data provenance is from non-clinical bench testing and simulations, conducted by the manufacturer, Dima Italia Srl, and Masimo for oximeter verification. It is not patient data; therefore, there is no country of origin or retrospective/prospective designation in the human health context.

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

    • Number of Experts: This information is not provided in the document.
    • Qualifications of Experts: This information is not provided in the document.

    Given that the testing involved non-clinical bench testing and simulations, the "ground truth" would be established by the expected outputs/measurements based on the device's design specifications and engineering principles, rather than expert clinical consensus on actual patient data.

    4. Adjudication Method for the Test Set

    The document does not describe any adjudication method like 2+1 or 3+1, which are typically used for disagreements among human experts evaluating clinical data. Since the testing was non-clinical and primarily bench-based, such a method would not be applicable. Device performance was assessed against predefined technical specifications.

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

    No, an MRMC comparative effectiveness study was not done. The document explicitly states that "non-clinical tests" were used for validation, and only mentions a "clinical dynamic simulator" for pulse oximetry. There is no mention of human readers, clinical cases, or AI assistance for human readers.

    6. Standalone (i.e., algorithm only without human-in-the-loop performance) Study

    This question is not directly applicable in the context of this device. The Mini Pegaso Cough is a medical device, not an AI algorithm. Its "standalone" performance refers to its ability to operate according to its specifications during bench testing, which was done (e.g., "black-box performance testing," "white-box testing"). The device's operation is essentially "algorithm only" in the sense that it functions based on its programmed logic and hardware, without requiring human intervention for its core function during a therapy cycle, though it is human-operated.

    7. Type of Ground Truth Used

    The ground truth used was primarily engineering specifications and expected physical measurements/outputs based on the device's design. This includes:

    • Expected pressure values (e.g., 0 to 50 cmH2O).
    • Expected flow characteristics (Low, medium, High, Peak).
    • Correct operation of modes (Manual, Auto).
    • Accurate display of therapy parameters.
    • Correct triggering performance for AutoSync/EasyStart.
    • Accurate percussion frequency and waveform on a lung simulator.
    • Proper data management functionality.
    • Accurate pulse oximetry data visualization and alarm activation as verified by a clinical dynamic simulator.
    • Compliance with various electrical safety, biocompatibility, and risk management international standards (e.g., IEC 60601-1, ISO 10993-1, ISO 9919).

    8. Sample Size for the Training Set

    This information is not applicable and not provided. This device is a hardware-based medical device with integrated software, not an AI/machine learning algorithm that requires a "training set" in the conventional sense. The software development process likely involved various levels of testing and verification, but not "training" using a specific dataset like an AI model.

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

    This information is not applicable and not provided for the same reasons mentioned in point 8.

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