SPM-300 is intended for use as a diagnostic tool by trained operators in healthcare facilities. It provides the following functions: - Acquire pulmonary function data. - Input patient data. - Use Host device to - View, store and print captured data. - Analyze captured data; display and print analysis results. - Retain captured data and analysis results for up to 120 patients. - Transfer retained data to a PC.
Device Story
SPM-300 is a pulmonary function monitoring system comprising a spirometry data acquisition unit (handle and disposable mouthpiece) and a host device (Cardio7 or CardioTouch3000). The device uses a symmetric pivot tube to measure differential air pressure, which is converted to air flow using Bernoulli's principle. The host device provides data analysis, management, display, and user interface functions. It is operated by trained clinicians in healthcare facilities. The system displays flow/volume and volume/time curves and calculates pulmonary parameters (FVC, SVC, MVV). Data is stored locally (up to 120 tests) and can be transferred to a PC. The device assists clinicians in diagnosing pulmonary conditions by providing standardized lung function measurements, aiding in clinical decision-making regarding respiratory health.
Clinical Evidence
Bench testing only. The device demonstrated compliance with American Thoracic Society (ATS) standards for measuring FVC, FEV1, MVV, and PEF accuracy and repeatability. Electrical safety and EMI testing were performed per IEC 60601-1 and 60601-1-2. Biocompatibility testing for the disposable mouthpiece was conducted per ISO 10993 (cytotoxicity, skin sensitization, oral mucosa irritation) with passing results.
Technological Characteristics
Diagnostic spirometer; symmetric pivot tube sensor; differential pressure measurement principle; disposable mouthpiece (ISO 10993 compliant); AC or battery power; RS-232 connectivity to host device; PC data transfer; complies with ATS standards for spirometry; IEC 60601-1/1-2 electrical safety/EMI compliance.
Indications for Use
Indicated for prescription-only diagnostic spirometry testing of adult and pediatric patients in general practice, specialty physician, and hospital settings.
Regulatory Classification
Identification
A diagnostic spirometer is a device used in pulmonary function testing to measure the volume of gas moving in or out of a patient's lungs.
Benson Medical Instruments' CCS-200 Spirometer (K123896)
Submission Summary (Full Text)
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K130322-NOV 15 2013
# 1. 510(k) Summary - Basic Information
| 1.1 Submitter | |
|------------------------|-------------------------------------------------------------------------------------------------------------------|
| Submitter:<br>Address: | Bionet Co., LTD<br>#1101, 11F E&C Dream Tower III, 197-33<br>Guro-dong, Guro-gu, Seoul, South Korea (ZIP 152-050) |
| Contact: | Marc Goodman |
| Company: | Noblitt & Rueland<br>5405 Alton Parkway, Suite A530<br>Irvine, CA 92604 |
| Voice: | (949) 398-5222 |
| FAX: | (949) 398-5223 |
| Cell:<br>Email: | (949) 872-1011<br>marcgood@ca.rr.com |
| Date Prepared: | March 26, 2013. |
# 1.2 Device Name
| Device Name: | SPM-300 |
|----------------------|--------------------------------------------|
| Common Name: | Spirometer |
| Classification Name: | Diagnostic Spirometer (868.1840, Class II) |
| 510(k) Number: | K130322 |
# 1.3 Identification of Legally Marketed Device
Substantial equivalence is claimed to the Caird Technology Spirometer (K971336); which is marketed as the Medikro spirometer.
### 1.4 Device Description
SPM-300 is a pulmonary function monitoring system consisting of a spirometry data acquisition unit (spirometer handle and mouthpiece) and a host device that provides data analysis and management, display and user interface functions. (See Figure 1).
# Figure 1: SPM-300/Host Block Diagram
Image /page/0/Figure/10 description: The image shows a block diagram of the SPM-300 Spirometer Unit. The unit consists of a disposable mouthpiece and a handle and cradle. The unit is connected to the SPM-300 Host Device via RS-232. The host device is connected to a PC.
# 1.5 Intended Use
SPM-300 is intended for use as a diagnostic tool by trained operators in healthcare facilities. It provides the following functions:
- Acquire pulmonary function data.
- Input patient data. .
- Use Host device to .
- View, store and print captured data. o
- Analyze captured data; display and print analysis results. 0
- o Retain captured data and analysis results for up to 120 patients.
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- o Transfer retained data to a PC.
# 1.6 Indications for Use
The SPM-300 Spirometer is intended for prescription use only to conduct diagnostic spirometry testing of adults and pediatric patients in general practice, specialty physician, and hospital settings.
# 1.7 Comparison to Cleared Device
Bionet believes that SPM-300 is substantially equivalent to the Caird Technology Spirometer (K971336) with respect to essential characteristics, user interface, and measurement characteristics. This device is marketed as the Medikro spirometer and was selected as the predicate for SPM-300 because both can be used in conjunction with EKG measurement devices that provide all user interface functions. Table 1 compares SPM-300 to the Medikro spirometer for the several characteristic specified above.
#### Comparison of Indications for Use to Recently Cleared Device 1.7.1
SPM-300's Indications for Use derive from the spirometer most recently cleared by FDA, which is Benson Medical Instruments' CCS-200 Spirometer (K123896).
# Table 1: Comparison of SPM-300 to Predicate Device
| | Bionet SPM-300 Spirometer | Medikro D9 Spirometer |
|---------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Essential Characteristics | | |
| Device Type | Diagnostic Spirometer | same |
| Target<br>Population | Adult and pediatric patients | same |
| Where used | Healthcare facilities | same |
| Indication for<br>Use | The SPM-300 Spirometer is intended for<br>prescription use only to conduct diagnostic<br>spirometry testing of adults and pediatric<br>patients in general practice, specialty<br>physician, and hospital settings. | See 1.7.1. |
| Mouthpiece | Disposable | same |
| Environment | • Temperature: 15 ~ 40° C (59 ~ 104° F)<br>• Relative humidity: 10 to 90% (non-condensing)<br>• Atmospheric pressure: 700 to 1060hPa | • Temperature: 10 ~ 40°C (50 ~104 °F)<br>• Relative humidity: 15 ~ 95% (non-condensing)<br>• Atmospheric pressure: 700 ~ 1060 hPa |
| Power supply | AC or optional built-in battery<br>95~240 VAC, 50/60Hz, 1.0~0.5A, 60W max | Universal AC Power supply (100~240<br>VAC at 50/60Hz) 65 VA |
| | User Interface Comparisons | |
| User Interface | Provided by Host Device (Cardio7 or<br>CardioTouch3000) | Provided by external device |
| Presentation | • Volume/time curve<br>• Flow/volume curve<br>• Measurement Values Table | • Volume/time curve<br>• Flow/volume curve<br>• Tidal volume<br>• Both volume/time and displayed curves<br>• No curves |
| Data storage | Up to 120 tests | Up to 50 tests |
| Measurement Comparisons | | |
| Measured<br>values | • FVC: FVC, FEV1, FEV1/FVC, FEF 0.2-1.2L, FEF<br>25-75%, FEF 75-85%, PEF, FEF 25%, FEF 50%,<br>FEF 75%,<br>• SVC: SVC, ERV, IRV, TV, EC, IC, RV<br>• MVV: MVV, FB, TV | • FVC: FVC, FIVC, FIV1, FIV1%, FEV0.5, FEV1,<br>FEV2, FEV3, FEV5, FEV6, FEV1/FEV6,<br>FEV0.5%, EV1%, FEV2%, FEV3%, FEV5%,<br>FEV6%, PEF, FEF25, FEF50, FEF75, FEF0.2-<br>1.2, FEF25-75, FEF75-85, PIF, FIF50,<br>FEF50/FIF50, FET<br>• SVC: SVC, ERV, IRV, VT, IC, BF, MV, Tin, Tex, |
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| | Bionet SPM-300 Spirometer | Medikro D9 Spirometer |
|------------------------|-------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Measurement<br>range | • Flow: 0 to ±14 L/s<br>• Volume: 0 to ±11 L | • Flow: 0 to 14 L/s<br>• Volume: 0 to 11 L |
| Measurement<br>method | Differential pressure method | Pneumotach |
| Prediction<br>equation | Morris-Polgar, ECCS-Quanjer,<br>Knudson-ITS | Berglund, Crapo, ECCS/Quanjer,<br>Falaschetti, Forche II, Gore, Gulsvik,<br>Hedenström, Knudson, Kory, Morris,<br>NHANES III, Paoletti, Roca, Schoenberg,<br>Viljanen |
| Measuring<br>accuracy | Complies with ATS (American Thoracic<br>Society) standards. | same |
#### Differences between SPM-300 and Medikro Spirometer 1.7.2
There are no meaningful differences between the Essential Characteristics of SPM-300 and the Medikro Spirometer with respect to safety or efficacy. The temperature and humidity ranges are slightly different but both devices can be used in the same environments and these slight differences do not affect performance of the spirometry function. There are minor power supply differences, but both power supplies adequately cover the US power environment.
The differences in the User Interface and Measurement categories do not make SPM-300 less safe or less effective than the Medikro Spirometer as described in the following paragraphs.
# 1.7.2.1 User Interface Difference
The only User Interface difference is the presentation of pulmonary test data. This difference in presentation does not make SPM-300 less safe or less effective than the Medikro Spirometer because both devices display the same curves and parameters.
- . Both use external devices to display graph and parameter data.
- . Both display Volume/time curve and Flow/volume curve.
- The predicate displays standalone Tidal volume but SPM-300 displays Tidal . volume in its Measurement Values Table (along with other parameters).
# 1.7.2.2 Measurement Differences
The measurement accuracy of both devices is assured by compliance with ATS standards. The several measurement differences do not make SPM-300 less safe or less effective than the Medikro Spirometer because the SPM-300 aleorithm calculates the same parameters as the predicate device but only shows the important parameters to reduce complexity.
Even though their measurement methods differ, both devices ultimately derive lung volume from air flow.
- The predicate device uses the pneumotachometer sensor to measure air flow ● directly.
- . SMP-300 uses a symmetric pivot tube to get the differential air pressure which it uses to derive air flow using Bernoulli's principal.
The difference in data storage capacities does not affect the actual performance of spirometry.
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The different measurement methods do not affect spirometry performance because the accuracy of air flow measurement for both devices is within the ATS tolerance.
The popular prediction equation in the US is the Morris-Polgar equation, which both devices provide. While the predicate provides more prediction equations than SPM-300, the difference is choice rather than performance.
# 1.8 Biocompatibility
The patient contact component of the SPM-300 Spirometer is the SmarTube™ disposable mouthpiece, which is inside the patient's mouth during spirometry testing. Bionet contracted an independent testing organization to conduct the following biocompatibility testing for the mouthpiece in accordance with the ISO 10993 standard:
- cytotoxicity .
- . skin sensitization
- o oral mucosa irritation
The independent testing organization found (and certified) that the disposable mouthpiece meets or exceeds all biocompatibility requirements for components with patient contact duration ≤ 24 hours in accordance with the ISO 10993 standard.
# 2. Performance Information
SPM-300 has been demonstrated to comply with the ATS (American Thoracic Society) standards for measuring FVC, FEVI, MVV, and PEF (accuracy and repeatability). This is based on the recommendation of the ATS/ERS Task Force titled, "Standardisation of Lung Function Testing; Standardisation of spirometry".
SPM-300 was subjected to Electrical Safety and EMI (Electromagnetic Interference) testing in accordance with the IEC 60601 standard (Part 1: General requirements for safety and Part 1-2, Electromagnetic Compatibility Requirement and tests). SPM-300 was found to satisfy the requirements of both parts of the standard.
The patient contacting component of SPM-300 (disposable mouthpiece) was subjected to biocompatibility testing as described in 1.8 (above).
# 3. Conclusion.
Based on non-clinical testing, SPM-300 has been demonstrated to be as safe and as effective as the Caird Technology Spirometer predicate device (K971336).
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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 three tail feathers, representing the three levels of government: federal, state, and local. The eagle is enclosed in a circle, with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter of the circle.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
November 15, 2013
Bionet Company, Limited C/O Marc Goodman, Senior Associate Noblitt & Rueland 5405 Alton Parkway 5A, Suite A530 IRVINE, CA 92604
Re: K130322
Trade/Device Name: SPM-300 Regulation Number: 21 CFR 868.1840 Regulation Name: Diagnostic Spirometer Regulatory Class: Class II Product Code: BZG Dated: September 27, 2013 Received: October 7, 2013
Dear Mr. Goodman:
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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
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.
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Page 2 - Mr. Goodman
۰۰ ۰۰ ۰
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 (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 contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. 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.
Tejash
Clinic
DAGR
Tejashri Purohit-Sheth, M.D. Clinical Deputy Director DAGRID
FOR
Kwame Ulmer M.S. Acting Division Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
# Indications for Use
510(k) Number (if known) K130322
#### Device Name
SPM-300
#### Indications for Use (Describe)
The SPM-300 Spirometer is intended for prescription use only to conduct diagnostic spirometry testing of adults and pediatric patients in general practice, specialty physician, and hospital settings.
Type of Use (Select one or both, as applicable)
> Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
### PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.
| FOR FDA USE ONLY | |
|------------------------------------------------------------------------------|--|
| Concurrence of Center for Devices and Radiological Health (CDRH) (Signature) | |
| Anya C. Harry -S | Digitally signed by Anya C. Harry -S<br>DN: c=US, o=U.S. Government, ou=HHS,<br>ou=FDA, ou=People, cn=Anya C. Harry -S,<br>0.9.2342.19200300.100.1.1=0011315590<br>Date: 2013.11.15 15:48:05 -05'00' |
|------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
|------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
FORM FDA 3881 (9/13)
. .
PSC Publishing Services | 901) 441-6741 | ELF
Form Approved: OMB No. 0910-0120 Expiration Date: December 31, 2013 See PRA Statement on last 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.