K013489 · Pds Healthcare Products, Inc. · BZH · Nov 29, 2001 · Anesthesiology
Device Facts
Record ID
K013489
Device Name
KP + LFM
Applicant
Pds Healthcare Products, Inc.
Product Code
BZH · Anesthesiology
Decision Date
Nov 29, 2001
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 868.1860
Device Class
Class 2
Indications for Use
For personal monitoring of expiratory-breath function at home under direction of a physician. It measures, logs, and reports events related to respiration and the spirometric values of peak expiratory flow (P.EF), zone and percent of PEF compared to a reference value, timed forced expiratory volumes over 1 second (FEV1) and 6 seconds (FEV6), and the ration of FEV1/FEV6.
Device Story
Hand-held, battery-powered electronic flow meter; measures expiratory breath flow; single-user; mouthpiece removable for cleaning. Device integrates breath flow over 6 seconds to calculate FEV6; computes FEV1/FEV6 ratio; stores up to 64 test sessions. Used at home by patients under physician direction. Data communicated via infrared port to PC using optional cradle and software. PC software allows diary log expansion, uploading of reference values, and alarm settings. Healthcare providers use reported spirometric values to monitor respiratory function and clinical status.
Clinical Evidence
No clinical testing performed. Device is identical to predicate; added features are enhancements of existing functionality. Bench testing to American Thoracic Society (ATS) standards performed using an automatic waveform generator.
Technological Characteristics
Hand-held electronic flow meter; 120 x 70 x 20 mm; reflective LCD display; infrared optical data port. Powered by two 1.5V silver-oxide batteries. Memory capacity: 64 test sessions. Meets American Thoracic Society (ATS) 1994 standards for spirometry monitoring devices.
Indications for Use
Indicated for personal monitoring of expiratory-breath function at home under physician direction. Measures PEF, FEV1, FEV6, and FEV1/FEV6 ratio.
Regulatory Classification
Identification
A peak-flow meter for spirometry is a device used to measure a patient's maximum ventilatory flow rate.
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Date
# 510(k) Summary -- KP+ LFM Flow Meter for Spirometry
Submitter:
| Company: | PDS Healthcare Products, Inc.<br>908 Main Street, Louisville, Colorado 80027<br>303 666 6340, 303 666 6380 Fax |
|----------|----------------------------------------------------------------------------------------------------------------|
| Contact: | Jim Lewis, Regulatory Associate |
19 October 2001 Prepared:
Device Name:
| Trade: | KP+ LFM |
|-----------------|-------------------------------------------------|
| Common: | Flow meter for spirometry |
| Classification: | Peakflow meter for spirometry [21 CFR 868.1860] |
Predicate Device:
| Trade Name: | KoKo Peak KP+ |
|----------------|-------------------------------|
| 510(k) Number: | K010009 |
| Manufacturer: | PDS Healthcare Products, Inc. |
Description of Device:
KP+ LFM is a model variation of the KoKo Peak KP and KP+ peak flow meters. The KoKo Peak KP+, complete with data-communication accessory and dedicated PC display software, was cleared for over-the-counter sale in 510(k) notification K010009. The LFM is identical to its predicate device-the KP+-physically, technologically, and logically.
This new variation extends some KP+ features-namely, an additional timed flow measurement and extended electronic features. These variations make the LFM a prescription device, rather than an over-the-counter one, like its predicate.
All KP flow meters are personal, electronic, flow meters for measuring the rate at which a person blows through them. Approximately 5x2x1 inches in size, the devices are batterypowered, hand-held, single-user instruments with a mouthpiece removable for cleaning. The meter has a custom liquid-crystal display, one-button operation, and an infrared data port for communicating to a serial port of a PC through an optional data-communication link.
Selecting between the models is done during manufacture by simply setting appropriate flags in the device's memory. This selection can be done during initial calibration at the factory, only. The model is then designated by packaging and labeling.
LFM features include
- Performing all KoKo Peak KP+ features and functions
- Measuring six-second forced expiratory volume (FEV6) by continuing to integrate the ● breath flow measurement over a 6-s period and displaying the value after a test session
- . Displaying the FEV1/FEV6 ratio on meter's front panel after a test session
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- Enabling diary logs to be expanded to up to 16 entries from the 5 entries . preprogrammed into the KP+
- Enabling options for uploading diary ranges, zone ranges, reference PEF, data-clear . command, and alarm-clock settings directly to meter's memory from a PC
Indications for Use:
For personal monitoring of expiratory-breath function at home under direction of a physician. It measures, logs, and reports events related to respiration and the spirometric values of peak expiratory flow (P.EF), zone and percent of PEF compared to a reference value, timed forced expiratory volumes over 1 second (FEV1) and 6 seconds (FEV6), and the ration of FEV1/FEV6.
Summary of Technological Characteristics:
There are no technological differences between the LFM and its predicate device.
Summary of Non-Clinical Performance Data:
Since LFM and its predicate, KP+, are physically identical, they meet the same standards for safety of medical electrical equipment.
Both KP+ LFM and its predicate device meet or exceed each aspect of American Thoracic Society standard for spirometry' as it relates to monitoring devices. Testing to ATS standard was performed successfully in-house using industry-recognized automatic waveform generator built specifically for that purpose.
#### Summary of Clinical Performance Data:
Since the device is identical to its predicate device and the added features are simply enhancements or extensions of features already available on the predicate device, no clinical testing was necessary or performed.
#### Technical Specifications:
#### Meter
| • Dimensions: | 120 x 70 x 20 mm |
|--------------------------|-------------------------------------|
| • Weight: | 85 g |
| • Operating Temperature: | 10 to 38 °C |
| • Operating Humidity: | 0 to 100 %RH, non-condensing |
| • Storage Temperature: | -20 to 60 °C |
| • Display: | Reflective liquid crystal, 21x40 mm |
| • Power: | Two 1.5-volt silver-oxide batteries |
| • Battery Symbol: | Low battery |
| • Battery Life: | 1 year (3 test sessions per day) |
| • Memory Capacity: | 64 test sessions (FIFO overflow) |
| • Data port: | Infrared optical |
<sup>1</sup> American Thoracic Society. Standardization of spirometry: 1994 update. Am J Respir Crit Care Med 152:1107-36, 1995.
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90 x 60 x 40 mm
10 to 38 °C
-40 to 70 °C
Infrared optical
serial port available
1 year
50 g (without batteries)
0 to 100 %RH, non-condensing
Four AAA alkaline batteries
#### Data cradle
- Dimensions: ●
- Weight: ●
- Operating Temperature: ●
- Operating Humidity: ●
- Storage Temperature: .
- Power: .
- Battery Life: .
- Meter data port: .
- PC data port: .
- Computer requirement: .
#### PC software
- Computer requirements: ● Accessories:
Operating system: Memory: Processor speed: Disk capacity:
- Program size: .
- Physical media: .
SVGA monitor and graphic card, or better, CD-ROM drive Windows 95, 98, or NT 32 MB of RAM Pentium 120 MHz or faster processor 500 MB of available space 33.2 MB CD
3-conductor wire to RS232 9-pin connector
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Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" arranged around the perimeter. Inside the circle is a stylized graphic of three human profiles facing to the right, with flowing lines beneath them, possibly representing water or movement.
Food and Drug Àdministration 9200 Corporate Boulevard Rockville MD 20850
## NOV 2 9 2001
Mr. Jim Lewis PDS Healthcare Products, Inc. 908 Main Street Louisville, CO 80027
Re: K013489 KP+ LFM Regulation Number: 868.1860 Regulation Name: Peak Flow Meter Regulatory Class: Class II (two) Product Code: BZH Dated: October 19, 2001 Received: October 22, 2001
#### Dear Mr. Lewis:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
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#### Page 2 - Mr. Jim Lewis
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); good manufacturing practice requirements as set Of It in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 21 CFR Part 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4646. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html
Sincerely yours,
Salih Tilah
James E. Dillard III Director Division of Cardiovascular and Respiratory Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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510(k) Number (if known): k013489
KP+ LFM __ Device Name: _________________________________________________________________________________________________________________________________________________________________
Indications for Use:
For personal monitoring of expiratory-breath function at home under direction of a physician. It r or personal monitoring or expiration and the spirometric values of peak measures, flow (PEF), zone and percent of PEF compared to a reference value, timed forced expiratory now (r Lr ); 2010 and person) on the eseconds (FEV6), and the ratio of FEV1/FEV6.
### (PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Division of Cardiovascular & Respiratory Devices
510(k) Number K013489
(Optional Format 3-10-98)
- PRESCRIPTION USE
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.