CLINICAL OXYGEN DOSE RECORDER (CODR), MODEL 300-CR
K082853 · Inspired Technologies, Inc. · MNR · Mar 23, 2009 · Anesthesiology
Device Facts
Record ID
K082853
Device Name
CLINICAL OXYGEN DOSE RECORDER (CODR), MODEL 300-CR
Applicant
Inspired Technologies, Inc.
Product Code
MNR · Anesthesiology
Decision Date
Mar 23, 2009
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 868.2375
Device Class
Class 2
Indications for Use
The Clinical Oxygen Dose Recorder (CODR) Model 300-CR records heart rate and oxygen saturation data provided by a Pulse oximeter; flow and pressure data from the oxygen delivery system; and measures breath rate and inhale/exhale ratio (1:E ratio) by monitoring the flow in the oxygen delivery tubing. Data is presented to enable the clinician to view the effects of the oxygen device's delivery performance on a patient in different ambulatory settings, i.e., rest and exercise. It is not to be used as a diagnostic tool. The CODR is intended to be used by trained clinicians in the hospital, clinical or home care environments. For the patient population the CODR will have the same indications for use as the oxygen source to which it is attached.
Device Story
CODR Model 300-CR is a portable, battery-powered data gathering system; functions as an adjunct to pulse oximetry and oxygen delivery systems. Inputs: heart rate/SpO2 from external pulse oximeter; flow/pressure data from oxygen delivery tubing via nasal cannula. Device tracks breath rate and I:E ratio. Data recorded to SD card; displayed via PC software. Used by clinicians in hospital, clinical, or home environments to evaluate oxygen delivery performance during patient rest and exercise. Output allows clinicians to visualize device performance; not for diagnostic use. Benefits include objective monitoring of oxygen therapy efficacy in ambulatory settings.
Clinical Evidence
Bench testing only. Performance and verification/validation testing conducted using various pulse oximeters and oxygen source systems. Tests included data measurement accuracy, data transmission/collection accuracy, EMC/EMI, and mechanical/environmental testing. No clinical study data provided.
Technological Characteristics
Portable, battery-powered (4 AA batteries) interface module (6"x4"x2"). Connects to oxygen source and pulse oximeter. Uses nasal cannula for flow/pressure sensing. Data storage via SD card. PC-based display software. No alarms. Class II device.
Indications for Use
Indicated for patients requiring oxygen therapy, matching the population of the specific oxygen source used. Used by clinicians in hospital, clinical, or home settings to monitor oxygen delivery performance during rest and exercise.
Regulatory Classification
Identification
A breathing (ventilatory) frequency monitor is a device intended to measure or monitor a patient's respiratory rate. The device may provide an audible or visible alarm when the respiratory rate, averaged over time, is outside operator settable alarm limits. This device does not include the apnea monitor classified in § 868.2377.
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## Non-Confidential Summary of Safety and Effectiveness Page 1 of 4 19-Dec-08
MAR 2 3 2009
| Inspired Technologies, Inc.<br>1061 Main Street - #24<br>N. Huntingdon, PA 15642 | Tel - 724-861-5510<br>Fax - 724-861-5530 |
|----------------------------------------------------------------------------------|---------------------------------------------------------|
| Official Contact: | Rick Confer - Director RA/QA |
| Proprietary or Trade Name: | CODR Model 300-CR |
| Usual Name: | breathing frequency monitor |
| Classification Name: | breathing frequency monitor<br>MNR - 868.2375 |
| Predicate Devices: | K051313 - Salter BiNAPS<br>K061996 - EB Neuro - Sandman |
### Device Description:
The Inspired Technologies Clinical Oxygen Dose Recorder (CODR) Model 300 CR is a portable data gathering and information display system which is intended to be used as an adjunct to commercially available pulse oximetry and oxygen delivery systems to enable the clinician to record and view the gathered data together.
The CODR records heart rate and oxygen saturation data provided by a cleared Pulse Oximetry system, flow and pressure data from the oxygen delivery system, and tracks breath rate and inhale/exhale ratio (I:E ratio) by monitoring the flow in the oxygen delivery tubing. The CODR displays this data in real time to enable the clinician to view the effects of the oxygen device's delivery performance on a patient as they rest and exercise. It is not to be used as a diagnostic tool. The CODR is intended to be used by trained clinicians in the hospital, clinical or home care environments.
The CODR consists of two components; (1) an interface module and (2) PC based data display software.
- 1. The interface module is a portable, battery powered module which is in line with Oxygen Source and is used to connect various oxygen sources, including LOX portables, standard oxygen cylinders, and oxygen concentrators. Standard, commercially available, single or dual lumen nasal cannula can be used with the interface module. The CODR interface module also has capability of connecting a Pulse Oximeter. The interface module is designed to be worn by the patient during evaluation of the system. It is approximately 6" X 4" X 2" deep and contains the pressure and flow sensors, a connector for the pulse oximeter, and a Secure Digital (SD) card slot for use in data recording. The interface module is powered by four AA batteries. Either alkaline or rechargeable batteries can be used.
- The PC based data display software 2.
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## Non-Confidential Summary of Safety and Effectiveness Page 2 of 4 19-Dec-08
## Indications for Use:
The Clinical Oxygen Dose Recorder (CODR) Model 300-CR records heart rate and oxygen saturation data provided by a Pulse oximeter; flow and pressure data from the oxygen delivery system; and measures breath rate and inhale/exhale ratio (1:E ratio) by monitoring the flow in the oxygen delivery tubing. Data is presented to enable the clinician to view the effects of the oxygen device's delivery performance on a patient in different ambulatory settings, i.e., rest and exercise. It is not to be used as a diagnostic tool.
The CODR is intended to be used by trained clinicians in the hospital, clinical or home care environments.
For the patient population the CODR will have the same indications for use as the oxygen source to which it is attached.
## Patient Population:
For the patient population the CODR will have the same indications for use as the oxygen source to which it is attached.
Environment of Use: Hospital, clinical or home care
Contraindications: None
### Performance testing to support substantial equivalence:
Performance and verification / validation testing was performed with various pulse oximeters and oxygen source systems. These tests included:
- Accuracy of data measured .
- . Data transmission / collection accuracy
- EMC / EMI ●
- Mechanical and environmental testing .
In all cases the CODR meet the specified performance criteria and was found to be substantially equivalence to the predicates.
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K082853 CODR
# Non-Confidential Summary of Safety and Effectiveness
| Features | Proposed Device<br>CODR | Predicate -EB Neuro Sandman<br>K061996 | Predicate - Salter BINAPS<br>K051313 |
|--------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Indications for<br>use | The Clinical Oxygen Dose Recorder (CODR) Model<br>300-CR records heart rate and oxygen saturation data<br>provided by a Pulse oximeter; flow and pressure data<br>from the oxygen delivery system; and measures breath<br>rate and inhale/exhale ratio (I:E ratio) by monitoring the<br>flow in the oxygen delivery tubing. Data is presented to<br>enable the clinician to view the effects of the oxygen<br>device's delivery performance on a patient in different<br>ambulatory settings, i.e., rest and exercise. It is not to be<br>used as a diagnostic tool. | Intended to collect physiological data to<br>be used in PSG and sleep disorder<br>studies. | Is an accessory intended for use with<br>PSG equipment during sleep disorder<br>studies for the purpose of detecting and<br>amplifying breathing signals and<br>detection of snoring of a sleeping patient |
| Environment of<br>Use | Hospital, health care facilities, home care | Hospital, health care facilities, home care | Hospital, health care facilities, home care |
| Patient<br>Population | For the patient population the CODR will have the same<br>indications for use as the oxygen source to which it is<br>attached. | Pediatric to adults | Not specified |
| Contraindications | None | None | None |
| Software driven<br>Components | Yes<br>Interface module - collects data<br>Data display software<br>Sensors<br>Nasal cannula to patient<br>Oxygen tubing from oxygen source<br>Pulse Oximeter | Yes<br>Interface module - collects data<br>Recorder unit<br>Sensors | Yes<br>Interface module<br>Nasal cannula |
| Prescriptive<br>Communication<br>interface | Yes<br>Physiological data from pulse oximeter and sensors<br>Measures parameters from the oxygen source | Yes<br>Physiological data from pulse oximeter<br>and sensors | Yes<br>Physiological data from pulse oximeter<br>and sensors |
| Features | Proposed Device<br>CODR | Predicate -EB Neuro Sandman<br>K061996 | Predicate - Salter BiNAPS<br>K051313 |
| Data recording | SD card and PC file | Internal flash chip | Not specified |
| Configuration | Wearable | Wearable | Not specified |
| Power | Battery | Battery | Battery |
| Sensors | Commercially available | Commercially available | Not specified |
| Patient interface | Nasal cannula | Electrodes | Nasal cannula |
| Data recorded | SpO2 | SpO2 | Flow |
| | Flow | Flow | Pressure |
| | Pressure | Pressure | Breathe rate |
| | Breathe rate | Breathe rate | |
| | I:E ratio | | |
| Connects to | Cleared pulse oximeter | Cleared pulse oximeter | Not specified |
| Alarms | None | None | None |
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082853 CODR
# on-Confidential Summary of Safety and Effectivenes
# ifferences Between Other Legally Marketed Predicate Devices
The proposed device is viewed as substantially equivalent to the predicate devices, K051313 and K06199
There are no significant differences that affect the safety or effectiveness of the intended device as compared to the predicate devi
Page S1,246
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# DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/4/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle with its wings spread, and the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular pattern around the eagle. The eagle is black, and the text is also black. The logo is simple and recognizable.
## Public Health Service
MAR 2 3 2009
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Inspired Technologies, Incorporated C/o Mr. Paul Dryden President ProMedic, Incorporated 24301 Woodsage Drive Bonita Springs, Florida 34134
Re: K082853
> Trade/Device Name: Clinical Oxygen Dose Recorder (CODR) Model 300-CR Regulation Number: 21 CFR 868.2375 Regulation Name: Breathing Frequency Monitor Regulatory Class: II Product Code: MNR Dated: February 24, 2009 Received: February 26, 2009
Dear Mr. Dryden:
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. Dryden
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.
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 (240) 276-0120. 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 240-276-3474. For questions regarding the reporting of device adverse events (Medical Device Reporting (MDR)), please contact the Division of Surveillance Systems at 240-276-3464. You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely yours,
Syate Y. Michael Ows.
Ginette Y. Michaud, M.D. Acting Director Division of Anesthesiology, General Hospital, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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## Indications for Use Statement
Page 1 of 1
# 510(k) Number:
K082853
Device Name:
Clinical Oxygen Dose Recorder (CODR) Model 300-CR
Indications for Use:
The Clinical Oxygen Dose Recorder (CODR) Model 300-CR records heart rate and oxygen saturation data provided by a Pulse oximeter; flow and pressure data from the oxygen delivery system; and measures breath rate and inhale/exhale ratio (1:E ratio) by monitoring the flow in the oxygen delivery tubing. Data is presented to enable the clinician to view the effects of the oxygen device's delivery performance on a patient in different ambulatory settings, i.e., rest and exercise. It is not to be used as a diagnostic tool.
The CODR is intended to be used by trained clinicians in the hospital, clinical or home care environments.
For the patient population the CODR will have the same indications for use as the oxygen source to which it is attached.
Prescription Use XX (Part 21 CFR 801 Subpart D)
or
Over-the-counter use (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Allian
(Division Sign-Off) Division of Anesthesiology, General Hospital Infection Control, Dental Devices
510(k) Number.
Page S1.242
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.