K130784 · Mir Medical Intl. Research Srl · BZG · Oct 30, 2013 · Anesthesiology
Device Facts
Record ID
K130784
Device Name
SPIROTEL
Applicant
Mir Medical Intl. Research Srl
Product Code
BZG · Anesthesiology
Decision Date
Oct 30, 2013
Decision
SESE
Submission Type
Special
Regulation
21 CFR 868.1840
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The Spirotel spirometer and pulse oximeter is intended to be used by a physician or by a patient under the instruction of a physician or paramedic to test lung function in people of all ages. It is also intended to be used as a single-patient device and can be used in any setting home, factory, pharmacy, hospital or physician's office.
Device Story
Spirotel is a pocket-sized diagnostic spirometer with optional pulse oximetry. Spirometry uses a bi-directional turbine with infra-red light interruption to measure airflow and volume (FVC, FEV1, PEF, etc.). Oximetry uses red and infra-red LEDs to measure SpO2 and pulse rate via finger absorption. Device operates autonomously or connects to PC via USB, Bluetooth, or GSM/GPRS/EDGE. Used by physicians, paramedics, or patients in homes, clinics, or hospitals. Data is transmitted to PCs or via email/SMS for clinical review. Provides objective respiratory and oxygenation metrics to assist in patient monitoring and clinical decision-making.
Clinical Evidence
Bench testing only. Spirometry accuracy verified against American Thoracic Society (ATS) standards. Oximetry accuracy (SpO2 and pulse rate) verified using optical simulators per FDA guidelines and ISO 9919:2005. Data transmission integrity (USB, Bluetooth, GSM) verified in-house. Battery performance and safety verified for the new rechargeable Li-ion power system.
Technological Characteristics
Bi-directional turbine (infra-red interruption) for spirometry; dual-LED (red/IR) sensor for oximetry. Enclosure: PC and ABS+PC. Power: 3.7V 1100mAh Li-ion battery. Connectivity: USB 2.0, Bluetooth (2402-2480 MHz), GSM (Quad-Band). Processor: ATMEL UC3A0512. Memory: Flash AT49BV320D. Standards: EN 60601-1, EN 60601-1-2, ISO 9919:2005, ATS spirometry standards.
Indications for Use
Indicated for lung function testing in patients of all ages. Intended for use by physicians, paramedics, or patients under professional instruction in home, clinical, or occupational 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.
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Image /page/0/Picture/1 description: The image shows the logo for Medical International Research (MIR). The logo consists of a stylized, three-peaked mountain range above the letters "MIR" in bold, sans-serif font. Below the logo is the full name of the company, "MEDICAL INTERNATIONAL RESEARCH," in a smaller, sans-serif font.
**OCT** 30 2013
# 510 (k) Summary
# 1. Applicant Information
| Date Prepared: | Oct 30, 2013 |
|-----------------|-----------------------------------------------|
| Submitter: | MIR Medical International Research |
| Address: | Via del Maggiolino, 125<br>00155 Roma - Italy |
| Contact Person: | Gerda Van Houts |
| Phone Number: | +39 06.22.754.777 |
## 2. Device Information
| Trade Name: | Spirotel |
|----------------------|------------------------|
| <i>As spirometer</i> | |
| Classification Name: | Spirometer, diagnostic |
| Regulation Number | 868.1840 |
| Product code | BZG |
| <i>As oximeter</i> | |
| Classification Name | Oximeter |
| Regulation Number | 870.2700 |
| Product code | DQA |
# 3. Identification of legally marketed device to which the submitter claims equivalence:
| Company Name: | MIR Medical International Research |
|----------------|------------------------------------|
| Device Name: | Spirotel |
| 510(k) number: | K043528 |
### 4. Description of the device:
Spirotel is a pocket spirometer that can also feature a pulse oximeter function (optional). It measures a range of functional respiratory parameters, and the oxygen saturation and pulse rate.
The device can operate completely autonomously or can be connected to a personal computer by means of various types of connections: USB, Bluetooth, GSM.
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| Option | BT | GSM | SpO2 | Ref. Code |
|-----------------|-----|-----|------|-----------|
| - | No | No | No | 9107000 |
| SpO2 | No | No | Yes | 9107001 |
| GSM | No | Yes | No | 9107010 |
| GSM + SpO2 | No | Yes | Yes | 9107011 |
| BT | Yes | No | No | 9107100 |
| BT + SpO2 | Yes | No | Yes | 9107101 |
| BT + GSM | Yes | Yes | No | 9107110 |
| BT + GSM + SpO2 | Yes | Yes | Yes | 9107111 |
The device is identified as follows, according with the presence/absence of the options Bluetooth, GSM, SpO2:
#### Spirometry function
A turbine inside the device that uses the interruption of infra-red light as its operating principle, measures volume and flow rate.
#### Parameters measured
| Symbol | Description | Units |
|----------|-----------------------------------------|-------|
| FVC | Forced Vital Capacity | L |
| FEV1 | Volume exhaled in 1st second of test | L |
| FEV1% | $FEV1/FVC x 100$ | % |
| PEF | Peak expiratory flow | L/m |
| FEF-2575 | Average flow between 25% and 75% of FVC | L/s |
### Oximetry function
The oximetry sensor features two light emitting diodes (LED), one emits visible red light and the other infra-red. Both bands of light pass through the finger to reach a light detector. During the passage through the finger, some of the light is absorbed by the blood and soft tissue depending on the concentration of haemoglobin. The amount of each light frequency absorbed depends on how oxygenated the blood is inside the tissue.
#### Technical specifications
| Spirometry function | |
|------------------------------|------------------------|
| Flow/volume sensor | Bi-directional turbine |
| Temperature sensor | semiconductor (0-45°C) |
| Method of detection | Infra-red interruption |
| Maximum volume measured | 10 L |
| Volume accuracy | $\pm$ 3% or 50 mL |
| Flow rate measurement range | $\pm$ 16 L/s |
| Flow rate accuracy | $\pm$ 5% or 200 mL/s |
| Dynamic resistance at 12 L/s | <0.5 cmH2O/L/s |
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| Oximetry function | |
|------------------------------|------------------------------------|
| Method of detection | Red and infra-red light absorption |
| SpO2 measurement range | 0 - 99% (with 1% increments) |
| SpO2 resolution | 1% |
| SpO2 accuracy | ± 2% (between 70-100% SpO2) |
| Pulse rate measurement range | 30 – 300 BPM |
| Pulse rate resolution | 1 BPM |
| Pulse rate accuracy | ± 2 BPM or 2% whichever is greater |
Bluetooth function
| Operating frequency range | 2402 - 2480 MHz |
|---------------------------|---------------------------------|
| Number of antennas | 1 |
| Antenna type | Integrated ceramic chip antenna |
| Output power | 0.1 mW |
GSM function
| Band | Quad-Band 850/900/1800/1900 MHz |
|------------------------|-----------------------------------|
| Communication standard | EDGE (E-GPRS) multi-slot class 10 |
| Antenna type | Internal |
| Antenna gain | gain 2.42 dBi |
Other specifications
| Power supply | Li-ion 3.7 V 1100mAh battery |
|--------------|--------------------------------|
| Dimensions | 88x74x38 mm; |
| Weight | 151 g (including battery pack) |
# 5. Statement of Intended Use:
The Spirotel spirometer and pulse oximeter is intended to be used by a physician or by a patient under the instruction of a physician or paramedic to test lung function in people of all ages. It is also intended to be used as a single-patient device and can be used in any setting home, factory, pharmacy, hospital or physician's office.
# 6. Summary of the technological characteristics of the new device in comparison to those of the predicate devices:
The new device has the following characteristics:
- light restyling of the enclosure to adapt to the new larger graphic display with touchscreen. Enclosure material is the same as the material used in Spirodoc (K082766)
- recheargeable battery
- same oximetry board and oximetry sensors as used in Minispir (K122384)
- data transmission based on new technologies as USB 2.0, Bluetooth (optional) and GSM/GPRS/EDGE (optional)
- new Main Board
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# Detailed description of the modification
| Modification | Description of modification<br>Spirotel (subject device) | | predicate device<br>name and 510(k)<br>number |
|---------------------------|------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------|-----------------------------------------------|
| Enclosure | Light restyling of the enclosure to<br>adapt to the new larger graphic<br>display with touchscreen. | | |
| | Color is white with an orange stripe<br>which goes all around the device. | Same color as | Spirodoc (K082766) |
| | Material has changed to PC (orange<br>part of the enclosure) and ABS + PC<br>(white part of the enclosure). | Same material as | Spirodoc (K082766) |
| Dimensions | 74 x 88 x 38 mm | 70 x 80 x 30 mm | Spirotel (K043528) |
| Weight | 151 g | 100 g | Spirotel (K043528) |
| Display | LCD backlit touch screen display,<br>resolution 160 x 80 | STN LCD, 2 lines x 16<br>alphanumeric characters | Spirotel (K043528) |
| Keyboard | None | Membrane, 5 keys | Spirotel (K043528) |
| Power supply | 3.7V, 1100mA rechargeable lithium-<br>ion battery | 3V Lithium battery CR123A | Spirotel (K043528) |
| Oximetry board | MIR 046 | Same board as | Minispir (K122384) |
| Oximetry sensors | BCI 1300<br>BCI 3026<br>BCI 3043<br>BCI 3078<br>BCI 3178<br>BCI 3444<br>BCI 3044 | Same sensors as | Minispir (K122384) |
| Oximetry sensor connector | Mini HDMI | Same connector as | Minispir (K122384) |
| Spirometry Board | MIR 043<br>Processor: ATMEL UC3A0512<br>Memory: Flash AT49BV320D (4M)<br>RTC: embedded in the ferro-<br>magnetic RAM FM33256 | MIR 007<br>Processor: Motorola 68HC11F1<br>Memory: SRAM TC551001 (1M)<br>RTC: DS2417 | Spirotel (K043528) |
| Data transmission | USB 2.0<br>Bluetooth (optional)<br>GSM, GPRS, EDGE (optional) | RS 232<br>Acoustic coupling via telephone | Spirotel (K043528) |
# 7. Brief discussion of the clinical and nonclinical tests relied on for a determination of SE.
Testing was done to ensure that the MIR Spirotel is substantially equivalent to the predicate device within the environments for which it is to be marketed.
Safety and environmental testing was conducted in accordance with EN 60601-1:2006 and EN 60601-1-2:2007. Electromagnetic compatibility (EMC), electrical, mechanical durability, safety (operator and patient), and temperature/humidity testing have been completed. The results demonstrates that the MIR Spirotel is in compliance with the guideline and standards referenced and that it performs within its specifications.
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Spirometry testing was performed according with American Thoracic Society (ATS) Standards. The results obtained were within the range of accuracy required by ATS.
The accuracy of oximetry parameters SpO2 and pulse rate has been verified in-house using an optical simulator. The results obtained were within the range of accuracy required by FDA guideline on Pulse Oximeters and ISO 9919:2005.
A battery testing was performed on the rechargeable battery (3.7V, 1100mA lithium-ion battery) which replaces the primary cell battery (3V CR123A Lithium battery) of the predicate Spirotel, in order to verify charging performance in normal condition and safety in short-circuits condition. Test showed that duration of the battery is approximately the same as the predicate Spirotel.
USB 2.0 transmission replaces RS232 transmission of the predicate Spirotel. A verification of integrity of data transmitted via USB 2.0 to a Personal Computer has been carried out inhouse and the results have shown that data were received without corruption.
Bluetooth transmission is performed using the proprietary module MIR 045 which has been FCC certified by a third party laboratory (FCCID: TUK-MIR045).
A verification of integrity of data transmitted via Bluetooth to a Personal Computer has been carried out in-house and the results have shown that data were received without corruption.
# GSM/GPRS/EDGE transmission is performed using an FCC approved module.
A verification of the integration of the module into Spirotel has been carried out by the manufacturer of the module.
A verification of integrity of data transmitted (e-mail message with attached archive sent to a specific email address, or SMS message sent to a specific mobile phone) has been carried out in-house and the results have shown that data were received without corruption.
#### 8. Conclusions
Based on these results, it is our determination that the device is substantially equivalent to the legally marketed device.
This summary on 510(k) substantial equivalence information is being submitted in accordance with the requirements of SMDA 1990 and 21 CFR 807.92.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
October 30, 2013
M.I.R. Medical International Research Ms. Gerda Van Houts Export Area Manager Via Del Maggiolino, 125 Roma - Italy 00155
Re: K130784
Trade/Device Name: Spirotel Regulation Number: 21 CFR 868.1840 Regulation Name: Diagnostic Spirometer Regulatory Class: II Product Code: BZG, DQA Dated: September 12, 2013 Received: September 27, 2013
Dear Ms. Van Houts:
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 -- Ms. Van Houts
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.
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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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# Indications for Use
510(k) Number (if known): ¥1307 8 Y
Device Name: Spirotel
Indications for Use: The Spirotel spirometer and pulse oximeter is intended to be used by a physician or by a patient under the instruction of a physician or paramedic to test lung function in people of all ages. It is also intended to be used as a singlepatient device and can be used in any setting - home, factory, pharmacy, hospital or physician's office.
Prescription Use (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
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Page 1 of 1 for Anya Harry MD PhD
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.