The BioHarness is a physiological monitoring telemetry device intended for monitoring of adults in the home, workplace and alternate care settings. The device consists of a chest strap and an electronics module that attaches to the strap. The device stores and transmits vital sign data including heart rate, respiration rate, thoracic skin temperature, body orientation and activity. The BioHarness collects and transmits measurements captured during both sedentary as well as rigorous activity for Heart Rate, Skin Temperature, Posture and Activity. Breathing rate values are accurately transmitted only during sedentary periods. The BioHarness is indicated for use as a general patient monitor to provide physiological information as part of an occupational welfare monitoring system, and for general research and performance measurement purposes.
Device Story
BioHarness is a wearable ambulatory physiological monitor consisting of a chest strap with conductive fabric electrodes and a capacitive thoracic expansion sensor, plus a battery-powered electronics module. It captures heart electrical activity, thoracic movement, skin temperature (via infrared sensor), and triaxial acceleration. Data is processed via an internal microcontroller to derive heart rate, respiration rate, posture, and activity level (Vector Magnitude Units). The device stores data internally and transmits via Bluetooth to a PC for display in third-party applications or provided software. Used in home, workplace, or research settings; operated by the patient or researcher. Provides real-time vital sign monitoring and alerts for threshold breaches. Benefits include remote physiological tracking during sedentary or rigorous activity, aiding in occupational welfare and performance research.
Clinical Evidence
Bench testing only. Performance validated against ANSI/AAMI ES60601-1 (electrical safety), ANSI/AAMI EC13 (heart rate metering), and ASTM E1965 (infrared thermometry). Functionality verified through iterative development testing and simulated field trials.
Technological Characteristics
Wearable chest strap with conductive lycra fabric electrodes and capacitive thoracic expansion sensor. Electronics module includes triaxial accelerometer (Analog Devices ADXL330), infrared thermometer, and Bluetooth radio. Powered by internal rechargeable lithium polymer battery. Connectivity: Bluetooth to PC. Software: Microcontroller-based proprietary digital filtering and signal analysis. Standards: ANSI/AAMI ES60601-1, ANSI/AAMI EC13, ASTM E1965, ISO 10993-1.
Indications for Use
Indicated for adult patient monitoring in home, workplace, and alternate care settings. Provides physiological data including heart rate, respiration rate (sedentary only), thoracic skin temperature, body orientation, and activity level. Not indicated for use as an ECG monitor.
Regulatory Classification
Identification
The arrhythmia detector and alarm device monitors an electrocardiogram and is designed to produce a visible or audible signal or alarm when atrial or ventricular arrhythmia, such as premature contraction or ventricular fibrillation, occurs.
Special Controls
*Classification.* Class II (special controls). The guidance document entitled “Class II Special Controls Guidance Document: Arrhythmia Detector and Alarm” will serve as the special control. See § 870.1 for the availability of this guidance document.
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K1000 40
Traditional 510(k)
# Premarketing Notification
# Traditional 510(k) Submission
DEC - 3 2010
| Submission date: | December 31, 2009 |
|------------------------------------|-----------------------------------------------------------------------------------------------|
| Submitter | Zephyr Technology Corporation<br>1 Annapolis Street<br>Suite 200<br>Annapolis, Maryland 21401 |
| Contact Person: | Code Cubitt<br>Chief Operating Officer |
| Telephone: | +1 (443) 569 3603 |
| Fax: | +1 (443) 926 9402 |
| Common Name: | Ambulatory Patient Monitor |
| Trade Name: | BioHarness |
| Classification Name: | 21CFR 870 1025 |
| Establishment Registration Number: | |
| Product code: | MHX |
| Device Class: | Class II |
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### GENERAL INFORMATION 1
This document contains the Premarket Notification for Zephyr Technology Corporation's BioHarness product. The BioHarness is an ambulatory patient monitor and provides remote vital signs monitoring for subjects in healthcare, occupational and home settings.
Zephyr's recommended classification for the BioHarness is as a class II medical device under regulation 21 CFR 870.1025 with product code MHX. The BioHarness product is a new medical device based on a legacy non-medical product already marketed by Zephyr. The intended use and technological characteristics of the BioHarness are the same as that of an existing legally marketed medical device manufactured by Hidalgo Ltd, the Equivital EQ-10 Vital Signs Physiological Monitor (K061993).
Zephyr Technology Corporation is a developer and manufacturer of real-time monitoring solutions for defense, emergency responder, training and research markets. Based in Annapolis, Maryland, Zephyr leverages a world class team of engineers, scientists, physiologists and business experts. Local universities and government labs augment Zephyr's internal development in specialized areas such as materials science, garment and textile design, sports science, physiological monitoring and software / web applications. Zephyr Technology Ltd, a wholly-owned R&D subsidiary of Zephyr Technology Corporation, is located in Auckland, New Zealand.
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Zephyr Technology
### 2 PROPOSED LABELLING
#### 2.1 User Documentation
The user manual is available. "Zephyr Technology BioHarness Bluetooth User Manual"
Images of labels on the device are shown below.
Image /page/2/Picture/6 description: The image shows two different views of a small, dark-colored electronic device. The left side of the image shows the top of the device, which has a power button symbol in the center. The right side of the image shows the bottom of the device, which has a label with some text and symbols on it, as well as some screws and other components. The device has a rounded, triangular shape.
Image /page/2/Picture/7 description: The image shows a product label with regulatory information. The label includes the serial number "ZBH001366", and states that the product contains a transmitter module. It also lists the FCC ID as "QOQWT12" and the IC ID as "5123A-BGTWT12A". The label also features the CE marking and a crossed-out wheeled bin symbol, along with the text "ZEPHYR BIOHARNESS BT".
Front and rear view of BioHarness device
Rear label
#### 2.2 Carton Label
The BioHarness ships in a package 25.5cm x 16.5cm. The figures below show the package labelling.
Image /page/2/Picture/12 description: The image shows the Zephyr BioHarness product. The product name "Zephyr BioHarness" is displayed in a stylized font on the left side of the image. To the right of the text, there is a picture of the BioHarness device, which appears to be a wearable sensor. The image is labeled as "Figure 3.2.1 - BioHarness Carton Top".
Figure 3.2.1 – BioHarness Carton Top
Image /page/2/Picture/14 description: The image shows two panels side by side. The left panel shows a Zephyr BioHarness product with a person running in the background. The right panel shows a Zephyr BioHarness Quick Start Guide. The text in the image is difficult to read due to the image quality.
Figure 3.2.2 – BioHarness Carton Front
Figure 3.2.3 - BioHarness Carton Rear
Zephyr BioHarness
FCC CE & 2
Figure 3.2.4 – BioHarness Carton Bottom
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4/12
### 3 SUBSTANTIAL EQUIVALENCE
The BioHarness and the Hidalgo Equivital EQ-10 Vital Signs Physiological Monitor are each ambulatory physiological monitoring devices capable of storing and transmitting multiple physiological parameters. Each of these devices is composed of two main components, a chest strap and a battery-powered electronics module. Both chest straps are used to sense heart electrical activity, thoracic movement and skin temp.
The physiological monitoring device presented in this 510(k) submission (BioHarness) is substantially equivalent to the physiological monitor marketed as the Hidalgo Equivital EQ-10 Vital Signs Physiological Monitor (K061993). Additional predicate devices include:
| Respironics | Actiheart | K052489 |
|-----------------------|---------------------|---------|
| VivoMetrics | LifeShirt Real Time | K043604 |
| GMP Wireless Medicine | LifeSync | K030795 |
A summary of similarities and differences between BioHarness and predicate devices are presented in the table below.
| Function | BioHarness | Predicate 1 | Predicate 2 |
|------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Heart Rate | A single-ended amplifier<br>senses heart electrical activity<br>through a chest strap with<br>conductive fabric electrodes.<br>The device filters and converts<br>signal to digital form. The<br>output is a digital value that<br>corresponds to heart beats per<br>minute. | Hidalgo Equivital EQ-10<br>K061993<br>Heart rate is derived<br>from ECG sensed<br>through a chest belt. A<br>secondary<br>measurement of R<br>wave is also available. | Respironics Actiheart<br>K052489<br>A differential amplifier<br>senses and amplifies ECG<br>through electrodes. The<br>output is a digital value<br>that corresponds to heart<br>beats per minute. |
| Respiration Rate | Respiration rate is inferred<br>from thoracic movement<br>sensed by a chest strap<br>containing a proprietary<br>capacitive sensor. The<br>thoracic movement waveform<br>is amplified, digitized and<br>analyzed to determine<br>respiration rate. | Hidalgo Equivital EQ-10<br>K061993<br>Respiratory breathing<br>frequency is inferred<br>from thoracic cavity<br>movement sensed by a<br>chest belt containing an<br>expansion sensor. | VivoMetrics LifeShirt Real<br>Time K043604<br>Respiratory rate is derived<br>from signals sensed via<br>torso vest with embedded<br>respiratory inductive<br>plethysmography bands. |
| Skin Temperature | Measurement of skin<br>temperature on the chest is<br>performed with an integrated<br>infrared thermometer. | Hidalgo Equivital EQ-10<br>K061993<br>Skin surface<br>temperature. | |
| Activity/Body<br>Orientation | The signal from an internal tri-<br>axis accelerometer is digitized<br>and analyzed using proprietary<br>algorithms to determine<br>activity and body orientation. | Hidalgo Equivital EQ-10<br>K061993<br>Activity and motion<br>detection using a tri-<br>axis accelerometer. | Respironics Actiheart<br>K052489<br>The signal from an internal<br>tri-axis accelerometer is<br>used to detect motion. |
| Bluetooth<br>Telemetry | An internal Bluetooth<br>communications module is<br>used to transmit digital<br>physiological data | Hidalgo Equivital EQ-10<br>K061993<br>Transmission of ECG<br>data over Bluetooth | GMP Wireless Medicine<br>LifeSync K030795<br>Transmission of ECG data<br>over Bluetooth link |
### Table 5.1: Comparison To Predicate
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,
### 510(K) EXECUTIVE SUMMARY 4
| 1. | Submitter: | Zephyr Technology Corporation<br>1 Annapolis Street<br>Suite 200<br>Annapolis, Maryland 21401 |
|----|-----------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 2. | Contact Person: | Code Cubitt<br>Chief Operating Officer<br>Telephone: +1 (443) 569 3603<br>Fax: +1 (443) 926 9402 |
| 3. | Date submitted: | December 31, 2009 |
| 4. | Trade Name: | BioHarness |
| 5. | Common Name: | Ambulatory Patient Monitor |
| 6. | Classification Name: | 21CFR 870 1025<br>Product code: MHX |
| 7. | Predicate Device | Hidalgo Equivital EQ-10 (K061993)<br>VivoMetrics LifeShirt Real Time (K043604)<br>Respironics Actiheart (K052489)<br>GMP Wireless Medicine LifeSync K030795 |
| 8. | Substantial<br>Equivalence<br>Statement | The Zephyr Technology BioHarness is substantially equivalent in<br>intended use to the Hidalgo Equivital EQ-10. The intended use and<br>application of the proposed device are substantially equivalent to<br>the legally marketed predicate device currently on the market. |
| 9. | Device description | The BioHarness is a compact physiological monitor that consists of<br>two components:<br>1. A chest strap with conductive fabric skin electrodes and a thoracic<br>expansion sensor.<br>2. A battery-powered electronics module that attaches to the chest<br>strap. |
ﺎ
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The device provides both storage and real-time transmission of the user's Heart Rate and Respiration Rate. The device uses heart electrical activity signals and respiratory breathing frequency inferred from thoracic movement to derive the Heart Rate and Respiration Rate.
The device also provides the following physiological measures:
- . An indication of the user's activity level based on acceleration measured by an internal triaxial accelerometer.
- . Body orientation
- . Thoracic skin temperature.
- . Alerts if physiological conditions exceed predefined thresholds.
An accessory cradle is provided to recharge the internal battery and transfer internally stored data to a computer.
The transmitted data provided by the device over Bluetooth may be integrated into third party monitoring applications.
- 10. Intended use The BioHarness is a physiological monitoring telemetry device intended for monitoring of adults in the home, workplace and alternate care settings. The device consists of a chest strap and an electronics module that attaches to the strap. The device stores and transmits vital sign data including heart rate, respiration rate, thoracic skin temperature, body orientation and activity.
The BioHarness collects and transmits measurements captured during both sedentary as well as rigorous activity for Heart Rate, Skin Temperature, Posture and Activity. Breathing rate values are accurately transmitted only during sedentary periods.
The BioHarness is indicated for use as a general patient monitor to provide physiological information as part of an occupational welfare monitoring system, and for general research and performance measurement purposes.
### ਹੈ ਹੈ. Technological characteristics
Substantial equivalence has been measured by review and comparison of performance data for the following. The technological characteristics compare to the following predicates:
| Function | Predicate 1 | Predicate 2 |
|------------------|------------------------------------|-----------------------------------------------|
| Heart Rate | Hidalgo Equivital EQ-10<br>K061993 | Respironics<br>Actiheart<br>K052489 |
| Respiration Rate | Hidalgo Equivital EQ-10<br>K061993 | VivoMetrics<br>LifeShirt Real<br>Time K043604 |
6/12
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| Skin Temperature | Hidalgo Equivital EQ-10<br>K061993 | |
|------------------------------|------------------------------------|-------------------------------------------------|
| Activity/Body<br>Orientation | Hidalgo Equivital EQ-10<br>K061993 | Respironics<br>Actiheart<br>K052489 |
| Bluetooth<br>Telemetry | Hidalgo Equivital EQ-10<br>K061993 | GMP Wireless<br>Medicine<br>LifeSync<br>K030795 |
12. Performance data Performance measurement and review to the applicable sections of the following standards has been conducted and successfully demonstrated as recommended by available guidance from the agency:
> ANSI/AAMI ES60601-1:2005, Medical electrical equipment - Part 1: General requirements for basic safety and essential performance.
ANSI/AAMI/IEC 60601-1-2:2007, Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic Compatibility -Requirements and tests.
ANSI/AAMI/ISO 10993-1:2003, Biological evaluation of medical devices - Part 1: Evaluation and testing.
ANSI/AAMI EC13:2002/(R) 2007, Cardiac monitors, heart rate meters, and alarms. The device provides function as a heart rate meter, but is not indicated for use as an ECG monitor.
ASTM E1965 - 98(2009) Standard Specification for Infrared Thermometers for Intermittent Determination of Patient Temperature.
Reviews and tests have also been carried out for general functionality and performance of the BioHarness.
Software has been developed using a structured software development process which meets the requirements of IEC 60601-1-4:1996/(R)2005, Medical electrical equipment - Part 1: General requirements for safety. 4. Collateral Standard: Programmable electrical medical systems.
#### 14. Conclusion
This pre-market notification has shown the substantial equivalence of the BioHarness to the identified predicates, by comparison to the descriptive material and performance testing of the device.
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### 5 DESCRIPTION OF DEVICE
The BioHarness is a compact physiological monitor that consists of two components:
- 1. A chest strap with conductive fabric skin electrodes and a thoracic expansion sensor.
- 2. A battery-powered electronics module that attaches to the chest strap.
The device provides both storage and real-time transmission of the user's Heart Rate, Resoiration Rate, Temperature, Posture and Activity Level. The device uses heart electrical activity signals and respiratory breathing frequency inferred from thoracic movement to derive the Heart Rate and Respiration Rate respectively.
An accessory cradle is provided to recharge the internal battery and transfer internally stored data to a computer.
The transmitted data provided by the device over Bluetooth may be integrated into third party monitoring applications. A simple software utility that displays vital sign data is provided. Users may transmit vital sign data from the BioHarness to the application on a PC via Bluetooth using the Bluetooth adapter.
The figures below show the BioHarness and accessories.
Image /page/7/Picture/10 description: The image shows two views of a Zephyr Bioharness device. The left side shows the front of the device, which has a power button and an LED window. The right side shows the back of the device, which has an IR sensor, strap attachment studs, and a cradle interface. The OCR text also shows the CE marking and the name of the manufacturer, Zephyr Bioharness.
Figure 7.1 - BioHarness, external front and rear views
Image /page/7/Picture/12 description: The image shows two views of a Zephyr BioHarness. The left side of the image shows the BioHarness with the Zephyr BioHarness logo and velcro. The right side of the image shows the BioHarness with conductive fabric sensors.
Figure 7.2 - BioHarness strap, front and rear views
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### б TECHNOLOGICAL CHARACTERISTICS
The technological characteristics of the BioHarness are described in the following sections.
#### 6.1 General Functionality
The BioHarness stores and transmits physiological data including heart rate, respiration rate, thoracic skin temperature, body orientation and activity level. The digital data are derived from physiological signals acquired from the user through the chest strap for heart rate and respiration rate. An infrared sensor is used to measure skin temperature on the user's chest. The user's activity and body orientation are derived from accelerometry signals from an internal triaxial accelerometer. Data may be transmitted over Bluetooth to a computer. The BioHarness has an internal rechargeable lithium polymer battery.
## A. Heart Rate
The BioHarness monitors electrical signals produced by the heart through a chest strap with conductive fabric skin electrodes and derives heart rate based on proprietary analysis of the QRS complex. The BioHarness is not an ECG monitor and provides no analysis capability in cases of abnormal QRS complex. The chest strap uses conductive lycra fabric to form a sensor, measuring electrical activity in the V4 lead position (fifth intercostals space in the midclavicular). A single-ended ECG circuit is used to detect QRS complexes. The circuit incorporates ESD protection, both passive and active filtering and an ADC to convert the signal to a digital representation. Proprietary digital filtering and signal analysis is performed on the signal with a microcontroller circuit to derive heart rate.
## B. Respiration Rate
The BioHarness monitors thoracic movement (chest expansion and contraction) through a chest strap containing a proprietary capacitive sensor is composed of layers of conductive fabric, · foam and flexible mylar (dielectric). The sensor capacitance is driven with a low-level 500kHz PWM signal. Thoracic expansion and contraction cause changes in capacitance which in turn result in changes in impedance causing the amplitude of the drive signal to vary. The BioHarness respiration circuit detects, filters and amplifies this change in amplitude to produce a varying voltage signal that represents thoracic movement. The signal is passed to an ADC and proprietary digital filtering and signal analysis is performed with a microcontroller circuit to derive respiration rate is inferred by thoracic movement measured via the capacitive sensor and circuit.
## C. Skin Temperature
The BioHarness uses an infrared thermometer to perform non-contact temperature measurements on user's chests. The infrared thermometer is mounted internal to the device, but has a viewing window that faces the user's chest. The Hidalgo uses a thermistor in the sensor module near an ECG electrode to measure skin temperature. Both sensors provide similar accuracy in temperature measurement.
## D. Body Orientation
The BioHarness measures body orientation by proprietary analysis of acceleration values output by an internal precision triaxial accelerometer and provides a measure of user posture (upright, supine) in degrees from vertical. The Hidalgo device calculates body orientation using three orthogonal accelerometer channels.
## E. Activity
The BioHarness measures activity level by proprietary analysis of acceleration values output by an internal precision triaxial accelerometer (Analog Devices ADXL330 3-axis +/-3 g iMEMS) and provides activity level in Vector Magnitude Units (VMU). The Hidalgo device calculates activity using three orthogonal accelerometer channels.
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### 6.2 Basic Safety and Essential Performance
The BioHarness meets the relevant requirements of ANSI/AAMI ES60601-1:2005, Medical electrical equipment - Part 1: General requirements for basic safety and essential performance.
## 1. Electrical Safety
A review of ANSI/AAMI ES60601-1:2005 has been conducted with respect to electrical hazards, with specific attention given to the relevant subclauses in clauses 8, 13 and 4. The risks associated with electrical hazards were assessed in accordance with Zephyr's risk management procedure. The subclauses relevant for Zephyr's device are discussed below.
## 2. Mechanical Safety
A review of ANSI/AAMI ES60601-1:2005 has been conducted with respect to mechanical hazards, with specific attention given to the relevant subclauses in clauses 9, 13 and 4. The risks associated with mechanical hazards were assessed in accordance with Zephyr's risk management procedure. The subclauses relevant for Zephyr's device are discussed below.
## 3. Radiation Hazards
A review of ANSI/AAMI ES60601-1:2005 has been conducted with respect to radiation hazards, with specific attention given to the relevant subclauses in clauses 10, 13 and 4. The risks associated with these hazards were assessed in accordance with Zephyr's risk management procedure. The subclauses relevant for Zephyr's device are discussed below.
## 4. Temperature and Other Safety Concerns
A review of ANSI/AAMI ES60601-1:2005 has been conducted with respect to excessive temperatures and other hazards, with specific attention given to the relevant subclauses in clauses 11, 13 and 4. The risks associated with these hazards were assessed in accordance with Zephyr's risk management procedure.
## 5. Accuracy of Controls and Protection Against Hazardous Outputs
A review of ANSI/AAMI ES60601-1:2005 has been conducted with respect to accuracy of controls and instruments and protection against hazardous outputs, with specific attention given to the relevant subclauses in clauses 12, 13 and 4. The risks associated with these hazards were assessed in accordance with Zephyr's risk management procedure
## 6. Hazardous Situations and Fault Conditions
A review of ANSI/AAMI ES60601-1:2005 has been conducted with respect to hazardous situations and fault conditions, with specific attention given to the relevant subclauses in clauses 13 and 4. The risks associated with these hazards were assessed in accordance with Zephyr's risk management procedure.
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## 7. Construction of ME Equipment
A review of ANSI/AAMI ES60601-1:2005 has been conducted with respect to construction of ME Equipment, with specific attention given to the relevant subclauses in clauses 15, 13 and 4. The risks associated with these hazards were assessed in accordance with Zephyr's risk management procedure.
## 8. Electromagnetic Compatibility
The BioHarness has been tested and shown to be compliant with electromagnetic compatibility requirements in the US (FCC) and the EU (R&TTE Directive).
The BioHarness complies with FCC Part 15 Subparts A and B as a Class B Unintentional Radiator (using methods described in ANSI C63.4 – 2003). The BioHarness also complies with the essential requirements of the R&TTE Directive. The BioHarness complies with EN 301 489-17 V1.2.1 (2002-08) when tested in accordance with EN 301-489-1 V1.6.1 (2005-09).
The AC Adapter complies with the requirements of the electrical safety standard AS/NZS 60950.1:2003 + A1 + A2 + A3.
## 9. Biocompatibility
The BioHarness meets the relevant requirements of ANSI/AAMI/ISO 10993-1:2003, Biological evaluation of medical devices - Part 1: Evaluation and testing.
## 10. Cardiac monitoring
The BioHarness meets the relevant requirement for heart rate metering in ANSI/AAMI EC13:2002/(R) 2007, Cardiac monitors, heart rate meters, and alarms.
## 11. Infrared Thermometry
The BioHarness meets the relevant requirements of ASTM E1965 - 98(2009), Standard Specification for Infrared Thermometers for Intermittent Determination of Patient Temperature.
## 12. Software
The BioHarness software has been developed using a structured software lifecycle which meets the requirements of IEC 60601-1-4:1996/(R)2005, Medical electrical equipment - Part 1: General requirements for safety. 4. Collateral Standard: Programmable electrical medical systems.
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### PERFORMANCE DATA 7
Reviews and tests have been carried out for general functionality and performance of the BioHarness.
Additional performance measurement and review to the applicable sections of the following standards has been undertaken and successfully demonstrated as recommended by available guidance from the agency:
ANSI/AAMI ES60601-1.2005, Medical electrical equipment - Part 1: General requirements for basic safety and essential performance
ANSI/AAMI/IEC 60601-1-2:2007, Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic Compatibility - Requirements and tests
ANSI/AAMI/ISO 10993-1:2003, Biological evaluation of medical devices - Part 1: Evaluation and testing
ANSI/AAMI EC13:2002/(R) 2007, Cardiac monitors, heart rate meters, and alarms
ASTM E1965 - 98(2009) Standard Specification for Infrared Thermometers for Intermittent Determination of Patient Temperature
The BioHarness software has been developed using a structured software lifecycle which meets the requirements of IEC 60601-1-4:1996/(R)2005, Medical electrical equipment - Part 1: General requirements for safety. 4. Collateral Standard: Programmable electrical medical systems
#### 7.1 General Functionality
General functionality of the BioHarness has been reviewed and tested iteratively throughout the development cycle. Devices and accessories are also tested as part of the production process.
Development testing of BioHarness functionality has occurred at the bench level and under simulated field conditions (i.e. field trials).
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Image /page/12/Picture/1 description: The image shows the logo for the Department of Health & Human Services USA. The logo consists of a stylized eagle with three lines forming its body and wings. The eagle is facing to the right. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" is arranged in a circular fashion around the eagle.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
Zephyr Technology Corporation c/o Mr. Code Cubitt Chief Operating Officer 1 Annapolis Street, Suite 200 Annapolis, MD 21401
DEC - 3 2010
Re: K100040
Trade/Device Name: BioHarness Regulation Numbe r: 21 CFR 870.1025 Regulation Name: Arrhythmia Detector and Alarm (Including ST-Segment Measurement and Alarm) Regulatory Class: Class II (two) Product Code: MHX Dated: Undated Received: December 1, 2010
Dear Mr. Cubitt:
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 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.
:
.
{13}------------------------------------------------
Page 2 - Mr. Code Cubitt
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); medical device reporting of medical device-related adverse events) (21 CFR 803); 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.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
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 (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours,
Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
{14}------------------------------------------------
## ZEPHYR TECHNOLOGY BIOHARNESS
## INDICATIONS FOR USE STATEMENT
510(k)Number (If Known):
K10047
Device Name:
### BioHarness
Indications for Use:
The BioHarness is a physiological monitoring telemetry device intended for monitoring of adults in the home, workplace and alternate care settings. The device consists of a chest strap and an electronics module that attaches to the strap. The device stores and transmits vital sign data including heart rate, respiration rate, thoracic skin temperature, body orientation and activity.
The BioHarness collects and transmits measurements captured during both sedentary as well as rigorous activity for Heart Rate, Skin Temperature, Posture and Activity. Breathing rate values are accurately transmitted only during sedentary periods.
The BioHarness is indicated for use as a general patient monitor to provide physiological information as part of an occupational welfare monitoring system, and for general research and performance measurement purposes.
Prescription Use (Part 21 CFR 801 Subpart D) < √> AND/OR
Over-The-Counter-Use (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE – CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence by CDRH, Office of Device Evaluation (ODE)
(Division Sign-Off)
Division of Cardiovascular Devices
| 510(k) Number | K100040 |
|---------------|---------|
|---------------|---------|
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.