ZEGRA POSTURE TRAINER

K081540 · Peter Fischer · LZW · Feb 20, 2009 · PM

Device Facts

• Record ID: K081540
• Device Name: ZEGRA POSTURE TRAINER
• Applicant: Peter Fischer
• Product Code: LZW · PM
• Decision Date: Feb 20, 2009
• Decision: SESE
• Submission Type: Traditional
• Device Class: Class U

Intended Use

The intended use of the ZEGRA Posture Trainer is a postural reminder for people who have the habit of slumped posture, who wish to be reminded of their posture whenever they slump beyond a predetermined limit, and who have the ability to correct their posture, The ZEGRA Posture Trainer's feedback helps to reduce slumped posture within this population. The intended use is for Prescription Use and Over-The-Counter Use.

Device Story

ZEGRA Posture Trainer is a wearable device for posture correction; worn on chest via belt or bra. Device contains a mechanical sensor in a plastic housing that detects spinal curvature/slumping. Upon activation, a microprocessor records current posture as a threshold; device vibrates when user slumps beyond this limit. User can select immediate or delayed feedback. Device is battery-powered; no external connectivity. Used by patients to receive tactile reminders to correct posture; helps reduce slumped posture habits.

Clinical Evidence

No clinical data provided; bench testing only.

Technological Characteristics

Plastic housing; mechanical sensor for spinal curvature; microprocessor-based control; battery-powered; vibratory feedback actuator; wearable form factor (belt/bra attachment).

Indications for Use

Indicated for individuals with a habit of slumped posture who possess the physical ability to correct their posture and desire a reminder when slumping beyond a predetermined limit.

Predicate Devices

• SPINE TUNER POSTURE TRAINER (K951244)

Submission Summary (Full Text)

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K081540

# Revised 510(k) Summary

FEB 20 2009

Type:

#### Traditional

Submitter:

Peter Fischer Christophstr. 2 D72072 Tuebingen Germany Tel: [phone] Fax: [phone] E-mail: [e-mail]

Contact person:

Peter Fischer Tel: [phone] E-mail: [e-mail]

Preparation date:

Trade name:

Common name:

Classification name:

Class:

Product code:

Panel:

Physical Medicine

January 23rd, 2009

Posture trainer

unclassified

LZW

ZEGRA Posture Trainer

Monitor, Spine Curvature

Substantial equivalence:

Device Classification Name - Monitor, Spine Curvature 510(k) Number - K951244 Device Name - SPINE TUNER POSTURE TRAINER Applicant - Dan Kline, 1816 West Cliff Ct, Carlsbad, CA 92008 Contact - Dan Kline Classification Product Code - LZW Date Received - 03/13/1995 Decision Date - 06/26/1995 Decision - Substantially Equivalent (SE) Classification Advisory Committee - Physical Medicine Review Advisory Committee - Physical Medicine Statements/Summary/Purged Status - Statement Only Type - Traditional

Reviewed By Third Party - No

The submitter was informed by FDA staff, that the predicate device "SPINE TUNER posture trainer" is an unclassified pre-amendments device. Thus he expects that the Classification Advisory Committee "Physical Medicine" will classify the substantially equal "ZEGRA posture trainer" in the same way.

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#### K081540

Device description:

The ZEGRA Posture Trainer is worn and looks just like the predicate posture trainer by the name of SPINE TUNER (510k Number: K951244). It is strapped around the chest with a belt or a bra. All electronic components sit in a little plastic case. The case contains a part that is moved when the user slumps. This movement is picked up by a sensor within the case. When the ZEGRA Posture Trainer is switched on, a microprocessor records the current posture as posture threshold. Thereafter, the ZEGRA Posture Trainer will vibrate whenever this threshold posture is reached or surpassed by slumping too much. The user has a choice of immediate feedback or feedback with a few seconds delay. The ZEGRA Posture Trainer has no cables and no options for connecting with other devices. It is exclusively battery powered.

The intended use of the ZEGRA Posture Trainer is a postural reminder for people who have the habit of slumped posture, who wish to be reminded of their posture whenever they slump beyond a predetermined limit, and who have the ability to correct their posture. The ZEGRA Posture Trainer's feedback helps to reduce slumped posture within this population.

Substantial equivalence:

Intended use:

A sensor and feedback unit encased in a plastic housing. The housing being attached to the body via a belt or bra. The sensor being sensitive to spinal curvature. A vibratory feedback signal whenever and as long as the spine is flexed beyond a predetermined limit.

Battery power as the only energy source.

A target population that wants to improve its posture and has the ability to do so.

Main difference to predicate:

Main difference to predicate: The ZEGRA posture trainer has a choice of immediate and delayed feedback, while the predicate device only offers immediate feedback.

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### DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized eagle with outstretched wings, symbolizing protection and care. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular pattern around the eagle, indicating the department's name and national affiliation. The logo is simple and iconic, representing the department's mission to protect the health of all Americans.

#### Public Health Service

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

Peter Fischer % Christophstr. 2 Mr. Peter Fischer D72072 Tuebingen Germany

FEB 2 0 2009

Re: K081540 Trade Name: ZEGRA Posture Trainer Regulatory Class: Unclassified Product Code: LZW Dated: January 23, 2009 Received: February 3, 2009

Dear Mr. Fisher:

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 may 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.

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 forth 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.

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## Page 2 - Mr. Peter Fischer

Enclosure

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), please contact the Center for Devices and Radiological Health's (CDRH's) Office of Compliance at [phone]. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding postmarket surveillance, please contact CDRH's Office of Surveillance and Biometric's (OSB's) Division of Postmarket Surveillance at [phone]. For questions regarding the reporting of device adverse events (Medical Device Reporting (MDR)); please contact the Division of Surveillance Systems at [phone]. You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at toll-free number [phone] or [phone] or Internet address http://www.fda.gov/cdrh/industry/support/index.html.

· Sincerely yours,

Mark N Mulhearn

Mark N. Melkerson Director Division of General, Restorative and Neurological Devices . Office of Device Evaluation Center for Devices and Radiological Health

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. 's

## Indications for Use

.

510(k) Number (if known): K081540´¨

Device Name: ZEGRA Posture Trainer

Indications For Use:

The intended use of the ZEGRA Posture Trainer is a postural reminder for people who have the habit of slumped posture, who wish to be reminded of their posture whenever they slump beyond a predetermined limit, and who have the ability to correct their posture, The ZEGRA Posture Trainer's feedback helps to reduce slumped posture within this population.

The intended use is for Prescription Use and Over-The-Counter Use.

| Prescription Use<br>(Part 21 CFR 801 Subpart D) | <span style="text-align:center;">AND/OR</span> | Over-The-Counter Use<br>(21 CFR 801 Subpart C) |
|-------------------------------------------------|------------------------------------------------|------------------------------------------------|
| <div style="text-align:center;">☑</div> | | <div style="text-align:center;">☑</div> |

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

(Division Sign-Off)

Division of General, Restorative, and Neurological Devices

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