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510(k) Data Aggregation

    K Number
    K230278
    Device Name
    Babyroo TN300
    Date Cleared
    2023-05-30

    (118 days)

    Product Code
    Regulation Number
    880.5130
    Reference & Predicate Devices
    Predicate For
    Why did this record match?
    Reference Devices :

    K182859

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

    The Babyroo TN300 is an open care radiant warmer that provides a controlled source of heat and regulation of skin temperature for neonates and infants. The optional integrated resuscitation module provides emergency respiratory support administered by clinicians and includes the functionality of suction. Additionally, the device provides weighing (optional) of neonates and infants. The device is designed for use with a body weight up to 10 kg (22 lb).

    The device is indicated for thermoregulation, skin temperature regulation, weighing (optional), and resuscitation (optional) of neonates and infants.

    Device Description

    The Babyroo TN300 is an open care infant radiant warmer that provides controlled source heat and skin temperature display for use with neonates and infants. The device can be configured for either labor and delivery or the newborn intensive care unit (NICU) and can be used for intra hospital transfer. Warming therapy is interrupted during intra hospital transfer and patient is not supplied with heat.

    The Babyroo TN300 device is offered with a fixed height or adjustable height trolley configuration and provides two heat sources for infant warming: a radiant warmer and an optional heating plate with conductive gel mattress. The device's bed can be tilted up to 15° in Trendelenburg and reverse Trendelenburg directions and the design of the device is intended to facilitate uniform heat distribution over the entire mattress surface across the range of bed tilt angulation. An optional removable canopy is available for intra-hospital transfer.

    Infant warming is facilitated via three (3) available thermoregulation modes:

    • Manual mode
    • Skin temperature mode
    • Kangaroo mode

    The Babyroo TN300 is available with an optional Resuscitation module. The optional Resuscitation module is pneumatic powered, can be connected to central gas supplies or gas cylinders and provides emergency resuscitation and suction to the patient. The optional Resuscitation module includes adjustment for gas flow, peak inspiratory pressure, O2 concentration, and suction functionality and is available in three (3) variants:

    • Resuscitation module with gas mixer and AutoBreath®.
    • Resuscitation module with gas mixer.
    • Resuscitation with O2 only.

    The optional AutoBreath® function facilitates pneumatically-driven, automatic respiratory rate and positive end-expiratory pressure control.

    The Babyroo TN300 can be configured to include an optional integrated electronic scale, as well as, optional heated gel mattress, optional integrated single or dual storage drawers, optional gas cylinder holders, and optional x-ray tray.

    The Babyroo TN300 device has an expected service life of 10 years.

    AI/ML Overview

    The provided text is a 510(k) summary for the Dräger Babyroo TN300 infant radiant warmer. It details the device's indications for use, its comparison to a predicate device, and the non-clinical performance testing conducted to demonstrate substantial equivalence.

    Here's an analysis of the provided information regarding acceptance criteria and the study that proves the device meets them:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not present a formal table of acceptance criteria with corresponding reported device performance values in a single, clear format as typically expected for specific performance metrics (e.g., a specific temperature range, with a specific accuracy requirement, and the measured accuracy).

    Instead, the "7. Substantial Equivalence Comparison and Discussion" section (pages 6-7) serves as the de-facto presentation of performance characteristics and how they compare to the predicate device. For the characteristics where the proposed device differs, the "Comment" column often implies the acceptance criteria (i.e., that the performance meets safety and effectiveness requirements, even if different from the predicate).

    Here's a partial reconstruction of a table based on the provided comparison, focusing on performance-related aspects and inferring acceptance criteria where possible:

    Performance CharacteristicAcceptance Criteria (Inferred/Stated)Reported Device Performance (Babyroo TN300)Study that Proves Acceptance (Implied from text)
    Body Weight IndicationUp to 10 kg (22 lb)Up to 10 kg (22 lb)Stated as identical to predicate, and established in contraindications.
    Irradiance (30% power)10 mW/cm²10 mW/cm²Implied successful non-clinical performance testing against this specified value.
    Irradiance (60% power)Not specified for predicate, accepted for proposed device.18 mW/cm²Implied successful non-clinical performance testing.
    Irradiance (100% power)Not specified for predicate, accepted for proposed device.32 mW/cm²Implied successful non-clinical performance testing.
    Pre-warm ProcedureSame power sequence (100%, 60%, 30%) as predicate, with specified durations and alarms.100% for 3 min ("Pre"), 60% for 11.5 min ("Pre"), 30% ("30") until clinician sets value. Alarms at 14 min and shut off at 15 min if above 30%.Implied successful non-clinical performance testing.
    Skin Temperature ModeSet value control in 0.1 °C (0.1 °F) steps, range 34°C to 37°C, extended 37.1°C to 38°C.Same as predicate.Implied successful non-clinical performance testing.
    Kangaroo Warming ModeAdequate warming by parent's body heat, device maintains 30% radiant warmer power, continuous patient temperature monitoring.Patient warmed by parent's body heat; device switches to manual mode with 30% radiant warmer power; continuous patient temperature monitoring.Verification of requirements relating to Kangaroo mode included in support of substantial equivalence (i.e., non-clinical performance testing).
    Skin Temperature Measurement RangeInclusive of predicate (18°C to 43°C).13°C to 43°C (55.4°F to 109.4°F)Implied successful non-clinical performance testing.
    Skin Temperature Measurement AccuracyComparable safety and effectiveness to predicate's ± 0.2°C display accuracy.Overall Accuracy: ± 0.3°C (0.54°F)Verification testing included in support of substantial equivalence (i.e., non-clinical performance testing).
    Skin Temperature Display Resolution0.1°0.1°Implied successful non-clinical performance testing.
    Primary Patient Outlet Adjustable Airway Pressure LimitDoes not exceed predicate (50 cmH2O), typical < 30 cm H2O, allows for 30-40 cm H2O for spontaneous ventilation.0 cmH2O to 40 cmH2OImplied successful non-clinical performance testing against safety and effectiveness.
    Primary Patient Outlet Fixed Airway Pressure Limit50 cmH2O ± 10%50 cmH2O ± 10%Implied successful non-clinical performance testing.
    Primary Patient Outlet Flow Control Range0 L/min to 15 L/min0 L/min to 15 L/minImplied successful non-clinical performance testing.
    Auxiliary Supply Pressure LimitDoes not exceed predicate (160 cmH2O).75 cmH2O ± 10%Implied successful non-clinical performance testing against safety and effectiveness.
    Blender Module Adjustable O2 Concentration21% to 100%21% to 100%Implied successful non-clinical performance testing.
    I:E Ratio (AutoBreath®)Non-adjustable, fixed internally at 1:2 nominal (1:1.6 to 1:2.4)Non-adjustable, fixed internally at 1:2 nominal (1:1.6 to 1:2.4)Implied successful non-clinical performance testing.
    Adjustable PEEP (AutoBreath®)< 2 cmH2O (at 5 L/min), ≤ 4 cmH2O (at 10 L/min), > 14 cmH2O (at 15 L/min)Same as predicate.Implied successful non-clinical performance testing.
    Suction Circuit Adjustable Suction Pressure0 kPa to 20 kPa (0 mmHg to 150 mmHg)0 kPa to 20 kPa (0 mmHg to 150 mmHg)Implied successful non-clinical performance testing.
    Suction Circuit Maximum Flow Rate< 20 L/min< 20 L/minImplied successful non-clinical performance testing.
    AutoThermo SW PackageSafety and effectiveness not affected, requirements verified.Allows "Tolerate cooling" and "warm-up" functions.Verification of requirements relating to AutoThermo function included in support of substantial equivalence (non-clinical performance testing).
    Bed-tiltSafety and effectiveness maintained up to 15° for continuous tilt.Continuous ± 15° from horizontal. Tactile detents at 0° and ± 10°.Testing included to verify requirements of the bed-tilt specifications of the proposed device (non-clinical performance testing).

    Study that Proves Acceptance Criteria:

    The primary study proving the device meets the acceptance criteria is non-clinical performance testing conducted according to recognized international consensus standards. The document explicitly states:

    • "The subject Babyroo TN300 was tested in accordance with applicable standards, guidance, and internal design requirements, including performance testing, functional/operation testing, biocompatibility, human factors, risk analysis and verification of risk control measures. Testing included accessories and optional components. The results of the non-clinical performance testing support substantial equivalence." (Page 12)
    • "The performance test data were provided to support substantial equivalence included:" followed by a list of IEC and ISO standards (pages 12-13).

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

    The document details non-clinical performance testing. For non-clinical (laboratory/bench) testing of medical devices, the "sample size" typically refers to the number of devices or components tested. The document does not specify the sample size (number of devices/components) used for the non-clinical performance tests.

    Data Provenance: This is non-clinical performance testing, so there is no patient data provenance information like country of origin or retrospective/prospective status. The testing was conducted internally or by testing facilities on physical devices/components.

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

    This information is not applicable as the studies were non-clinical performance tests. Ground truth in this context would be defined by the technical specifications and standards (e.g., a thermometer should read within X tolerance, a ventilator should deliver Y pressure). The "experts" would be the engineers and technicians conducting and verifying the tests against these established standards.

    4. Adjudication Method (e.g., 2+1, 3+1, none) for the Test Set

    This information is not applicable as the studies were non-clinical performance tests. Adjudication methods like 2+1 are typically used in clinical studies for endpoint assessment or expert review of clinical images/data.

    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

    This information is not applicable. The Babyroo TN300 is an infant radiant warmer with optional resuscitation and weighing modules. It is a hardware device with software, but it does not involve "human readers" or AI assistance in interpreting diagnostic data, which is the context for MRMC studies.

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

    This information is not applicable. The Babyroo TN300 is a physical medical device, not an image analysis algorithm or AI software for diagnosis that would have standalone performance. Its software controls the device functions.

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

    For the non-clinical performance testing, the "ground truth" or acceptance criteria are defined by:

    • International Consensus Standards: A long list of IEC and ISO standards is provided (pages 5, 12-13), which set specific performance, safety, and essential performance requirements.
    • Internal Design Requirements: The document states testing was against "internal design requirements," meaning the manufacturer's own specifications for the device.
    • Predicate Device Performance: For characteristics where the proposed device is equivalent to the predicate, the predicate's established performance serves as a benchmark for equivalence.

    8. The sample size for the training set

    This information is not applicable. This is a hardware medical device with controlling software, not a machine learning model that requires a distinct "training set" of data. The software development process follows IEC 62304.

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

    This information is not applicable as there is no "training set" in the context of this device. Ground truth for the device's functional performance refers to compliance with established engineering specifications and international standards, rather than labels on a dataset for machine learning.

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