K083874 · Respironics Inc., Sleep & Home Respiratory Group · MNR · Jan 26, 2009 · Anesthesiology
Device Facts
Record ID
K083874
Device Name
GALAXY
Applicant
Respironics Inc., Sleep & Home Respiratory Group
Product Code
MNR · Anesthesiology
Decision Date
Jan 26, 2009
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 868.2375
Device Class
Class 2
Attributes
Pediatric, 3rd-Party Reviewed
Indications for Use
The Galaxy is a physiological data recorder intended to collect and record data from multiple physiological channels. It is intended for use by or on the order of a physician. The Galaxy is intended for use in a supervised (hospital) or unsupervised (home) environment.
Device Story
Galaxy is a wearable physiological data recorder; collects signals including EEG, EOG, EMG, ECG, nasal/oral airflow, snore, thoracic/abdominal effort, body position, and pulse oximetry (SpO2, pulse rate, plethysmograph). Device stores data on removable SD card; no onboard data management or analysis. Used in hospital or home settings; operated by clinicians or patients. Data transferred to PC for analysis via cleared host software. Provides raw data storage to assist clinicians in sleep disorder studies; does not provide real-time alarms or automated apnea monitoring.
Clinical Evidence
Bench testing only. Verification testing confirmed device functionality met acceptance criteria. Safety verified via IEC 60601-1 and IEC 60601-1-2 testing. Risk Traceability Matrix used to mitigate identified hazards.
Technological Characteristics
Wearable, battery-powered data recorder. Stores data on removable SD card. Inputs: EEG, EOG, EMG, ECG, respiratory effort, airflow, snore, body position, pulse oximetry. 20-channel capacity. No onboard analysis, alarms, or calibration checks. Safety standards: IEC 60601-1, IEC 60601-1-2.
Indications for Use
Indicated for collection and recording of physiological data from multiple channels in pediatric through adult populations. Used in supervised hospital or unsupervised home environments under physician order. Not for life-supporting equipment or automated apnea monitoring.
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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# TAB 5
K083874
page 1 of 4
JAN 2 6 2009
# 510(K) SUMMARY
Date of Submission
Official Contact
Image /page/0/Picture/5 description: The image shows the word "RESPIRONICS" in bold, black letters. Above the word, there are three curved lines that are also in black. The lines appear to be a stylized design element, possibly representing airflow or breathing.
19 November 2008 Manufacturing Facility Address Respironics, Inc. 1001 Murry Ridge Lane Murrysville, PA 15668 Andrew P. Zeltwanger Manager, Regulatory Affairs Respironics, Inc. 1740 Golden Mile Highway Monroeville, PA 15146 Phone: 724-387-7442 Fax: 724-387-7490 Andrew.Zeltwanger@Respironics.com
- Proprietary Name Galaxy
Common/Usual Name Ventilatory Effort Recorder
Device Classification Name Ventilatory Effort Recorder
Classification Reference 21 CFR 868.2375
Classification
Product Code
Predicate Devices
Appropriate Classification Panel
MNR
EB Neuro, S.p.A. Sandman Pocket (K061996)
Class II
Anesthesiology
Reason for submission New device
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page 2 of 4
Galaxy
# Substantial Equivalence
This premarket notification submission demonstrates that the Respironics, Inc. Galaxy data recorder is substantially equivalent to the EB Neuro, S.p.A. Sandman Pocket (K061996).
The functionality of the design of the device was verified through verification testing. All tests met the required acceptance criteria. The safety of the design was assured by the completion of IEC 60601-1 and IEC 60601-1-2 testing. The Risk Traceability Matrix provided in the Risk Assessment assured that all hazards identified by the risk assessment are successfully mitigated.
## Intended Use
The Galaxy is a physiological data recorder intended to collect and record data from multiple physiological channels. It is intended for use by or on the order of a physician. The Galaxy is intended for use in a supervised (hospital) or unsupervised (home) environment.
## Device Description
The Galaxy is a wearable data recorder that collects and stores physiological signals. The role of the Galaxy is only to record the data. The following physiological signals may be collected and stored by the Galaxy device:
- 트 EEG, EOG, EMG, ECG
- 트 Nasal/oral Airflow
- l Snore
- I Thoracic and Abdominal Effort
- 회 Body Position
- B Pulse Oximetry, including:
- Oxygen Saturation (SpO2) o
- Pulse Rate o
- Plethysmograph o
The recorded data is stored on a secure digital (SD) card and may be passed on to a PC for analysis and reporting of the data by a cleared host software application. The Galaxy data recorder is not in any way involved in the data management performed by the host.
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Galaxy
page 3 of 4
# Technological Characteristics / Predicate Device Comparison
Like the Sandman Pocket predicate device, the Galaxy is intended to collect physiological signals from various points on the patient's body and to record those signals. Refer to Table 5-1 for a comparison of the Galaxy to the identified predicate device.
| Characteristic | EB Neuro, S.p.A.<br>Sandman Pocket<br>(K061996) | Respironics<br>Galaxy Data Recorder |
|------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Intended Use | Intended for use in collecting and<br>recording physiological data to be<br>used in polysomnography and<br>sleep disorder studies. The device<br>is intended for pediatric through<br>adult patient populations, and can<br>be used in either home or hospital<br>environments.<br><br>The Sandman Pocket is not<br>intended for use as life supporting<br>equipment, such as a vital sign<br>monitoring in an intensive care<br>unit. The device does not produce<br>alarms and is not intended as an<br>automated apnea monitor.<br><br>The Sandman Pocket is only to be<br>used under the direction or<br>supervision of a physician,<br>technologist or clinician. | The Galaxy is a physiological data<br>recorder intended to collect and<br>record data from multiple<br>physiological channels. It is<br>intended for use by or on the order<br>of a physician. The Galaxy is<br>intended for use in a supervised<br>(hospital) or unsupervised (home)<br>environment. |
| Environment of Use | Home or Hospital | Same as K061996 |
| FDA Device Class | Class II | Same as K061996 |
| FDA Product Code | MNR | Same as K061996 |
| FDA Device Type | Ventilatory Effort Recorder | Same as K061996 |
| FDA Regulation Number | 21 CFR 868.2375 | Same as K061996 |
| Simultaneous Patient<br>Recording Capability | 1 patient per unit | Same as K061996 |
| Configuration | Wearable | Same as K061996 |
| Portability | Portable | Same as K061996 |
| Data Input Types | Respiratory, ECG, Neurological | Same as K061996 |
| Maximum Number of<br>Channels | 22 | 20 |
| Characteristic | EB Neuro, S.p.A.<br>Sandman Pocket<br>(K061996) | Respironics<br>Galaxy Data Recorder |
| Channel Types Recorded | EEG<br>EOG<br>EMG<br>ECG<br>Respiratory Efforts (abdominal and<br>thoracic)<br>Airflow<br>Snore<br>Body Position<br>Oxygen Saturation<br>Pulse Rate<br>Plethysmograph | Same as K061996 |
| Pressure Therapy Device<br>Input Channel | Stores data from Nellcor Puritan<br>Bennett pressure therapy devices<br>and can be used to transmit data<br>streams from the pressure therapy<br>device to a PC. | Stores data from Respironics<br>pressure therapy devices. |
| Patient Event Marker<br>(PEM) | Yes | Same as K061996 |
| Sensors | FDA cleared sensors | FDA cleared sensors |
| Electrode Impedance<br>Check | Yes | No |
| Calibration Check | Yes | No |
| Memory | Recording stored on internal<br>NAND flash chip | Recording stored on removable<br>secure digital (SD) Card |
| Amount of Memory<br>Required for a Typical 8<br>Hour Study | 28 MB | 230 MB |
| Power | Battery powered or USB powered | Battery powered |
| Data Transfer for Analysis<br>and Report Generation | Data must be transferred. Data<br>analysis and reporting is not<br>performed by the data recorder | Same as K061996 |
### Table 5-1: Galaxy Data Recorder Comparison to Predicate Device
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Traditional 510(k) Tab 5 – 510(k) summary
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Galax
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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 is a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" around the perimeter. Inside the circle is an abstract image of an eagle.
Public Health Service
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Respironics, Incorporated C/O Mr Ned Devine Responsible Third Party Official Underwriters Laboratories, Incorporated 333 Pfingsten Road Northbrook, Illinors 60062
JAN 2 6 2009
Re K083874 Trade/Device Name Galaxy Regulation Number 21 CFR 868 2375 Regulation Name Breathing Frequency Monitor Regulatory Class II Product Code MNR Dated January 13, 2009 Received January 15, 2009
Dear Mr Devine
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 Devine
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 vours.
Anthony Oration for
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
Enclosures
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#### Indications for Use
510(k) Number (if known):
Device Name: Galaxy
Indications for Use:
The Galaxy is a physiological data recorder intended to collect and record data from multiple physiological channels. It is intended for use by or on the order of a physician. The Galaxy is intended for use in a supervised (hospital) or unsupervised (home) environment.
Prescription Use Over-The-Counter Use 1 resemption OSE
(Part 21 CFR 801 Subpart D) AND/OR (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)
Signature
(Division Sign-Off) Division of Anesthesiology, General Hospital Infection Control, Dental Devices
510(k) Number: k083874
Page
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.