MULTI-PARAMETER MOBILE CAREGUIDE 3100 OXIMETER WITH TABLET
Applicant
Reflectance Medical, Inc.
Product Code
MUD · Cardiovascular
Decision Date
Apr 11, 2014
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 870.2700
Device Class
Class 2
Indications for Use
The Multi-Parameter Mobile CareGuide™ 3100 Oximeter with Tablet is intended for use as an adjunct, non-invasive monitor of the hemoglobin oxygen saturation and pH of microvascular blood in a region of skeletal muscle tissue beneath the sensor may be positioned on pigmented skin. The Multi-Parameter Mobile CareGuide 3100 Oximeter is intended to allow for display of SmO2 and pHm data on an Android Tablet display, which would interface with the Multi-Parameter Mobile CareGuide 3100 Oximeter via USB connection. The Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet is intended for prescriptive use (Rx only) by a trained healthcare professional in a hospital. The Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet provides display of the most recent values of SmO2 and pHm in a trend, as well as operational device information. The Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet should not be used as the sole basis for diagnosis or therapy. Note: The prospective clinical value of data from the Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet has not been demonstrated in disease states.
Device Story
Device uses Near Infrared (NIR) spectroscopy to measure muscle oxygen saturation (SmO2) and muscle pH (pHm). System consists of a reusable sensor, disposable sleeve, and an Android tablet display. Sensor contains optical/electronic elements to collect spectra from skin, fat, and muscle; communicates via proprietary protocol over USB to tablet. Tablet runs locked-down software displaying real-time values and historical trends. Used by healthcare professionals in hospitals as an adjunct monitoring tool. Does not provide diagnostic output; intended to support clinical decision-making by providing physiological trends. Benefits include non-invasive, real-time monitoring of microvascular status.
Clinical Evidence
Bench testing only. No clinical data provided. Bench and software testing demonstrated that the device meets performance requirements for an oximeter and is equivalent to predicates.
Indicated for trained healthcare professionals in hospital settings as an adjunct, non-invasive monitor of hemoglobin oxygen saturation (SmO2) and pH (pHm) of microvascular blood in skeletal muscle tissue. Suitable for use on pigmented skin. Not for use as sole basis for diagnosis or therapy.
Regulatory Classification
Identification
An oximeter is a device used to transmit radiation at a known wavelength(s) through blood and to measure the blood oxygen saturation based on the amount of reflected or scattered radiation. It may be used alone or in conjunction with a fiberoptic oximeter catheter.
Predicate Devices
Multi-Parameter Mobile CareGuide Oximeter (K130079)
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K133923
Reflectance Medical, Inc.
510(k) Premarket Notification Submission: Multi-Parameter Mobile CareGuide™ 3100 Oximeter with Tablet
APR 1 2014
# SECTION 5
-
#### 510(k) SUMMARY
# SUMMARY OF SAFETY AND EFFECTIVENESS FOR Multi-Parameter Mobile CareGuide™ 3100 Oximeter, with Tablet
# Submitter Information
| Name: | Reflectance Medical, Inc. (RMI) |
|----------------------|-----------------------------------------------------------------------------------------------------------------------|
| Address: | 116 Flanders Road, Suite 1000 Westborough, MA 01581 USA |
| Telephone Number: | 508.366.4700 |
| Registration Number: | NA (RMI will apply for registration number following 510(k) clearance, prior to commencement of commercial shipment.) |
| Contact Person: | Dr. Babs Soller |
| Telephone Number: | 508.366.4700, Ext 223 |
| Fax Number: | 508.366.4770 |
| Email: | Babs.Soller@reflectancemedical.com |
| Date Prepared: | 12/19/2013 |
### Device Name
| Trade name of New Device: | Multi-Parameter CareGuide™ Oximeter with Tablet |
|---------------------------|-------------------------------------------------|
| Model Number: | 3100 |
| 510(k) Holder/Submitter: | Reflectance Medical, Inc. (RMI) |
| 510(k) Number: | N/A |
| Product codes: | 21 CFR § 870.2700, 21 CFR 868.1170 |
| Classification Panel: | Cardiovascular |
# Predicate Devices
| Predicate Device #1: | Mobile CareGuide |
|--------------------------|------------------------------------------------------------------------------|
| Trade Name of Device: | Multi-Parameter Mobile CareGuide Oximeter |
| Model #: | 3100 : |
| 510(k) Holder/Submitter: | Reflectance Medical Inc. |
| 510(k) Numbers: | K130079, CareGuide 3100 |
| Product codes: | MUD, 21 CFR 870.2700, Cardiovascular<br>CBZ, 21 CFR 868.1170, Anesthesiology |
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510(k) Premarket Notification Submission: Multi-Parameter Mobile CareGuide™ 3100 Oximeter with Tablet
| Predicate Device #2: | CareGuide |
|--------------------------|--------------------------------------|
| Trade Name of Device: | CareGuide Oximeter |
| Model #: | 1100 |
| 510(k) Holder/Submitter: | Reflectance Medical Inc. |
| 510(k) Numbers: | K113656, CareGuide 1100 |
| Product code: | MUD, 21 CFR 870.2700, Cardiovascular |
#### Device Description
The Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet uses Near Infrared (NIR) Spectroscopy to calculate muscle oxygen saturation (SmO2) and muscle pH (pHm) and displays those parameters as real-time values and historical trends on a tablet device.
| Characteristics | |
|--------------------------------------------------------------------------------|-----------------------------------------------------------------|
| Reflectance Medical Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet | |
| Principle of Operation | NIR spectroscopy |
| Components | Monitor with reusable sensor, disposable pad and display tablet |
| Light Source | LEDs |
| Parameters Measured | Tissue oxygen saturation (SmO2) and muscle pH (pHm) |
The Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet is a multiple parameter oximeter. The sensor contains algorithms that calculate SmO2 and pHm from collected spectra and communicates the current SmO2 and pHm results to an Android tablet with display software through a proprietary protocol. The Android tablet (qualified models Acer A500 and Asus Google Nexus 7) contains 3d party software that locks down the tablet so that only the CareGuide software may run and no other application or operating software can be modified. The Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet reusable sensor contains the optical and electronic elements necessary to collect spectra from skin, fat and muscle. The sensor has a 3m long cord with a USB connection to the Android tablet. The sensor is identical to the predicate (K130079) Multi-parameter Mobile CareGuide 3100 Oximeter. The Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet uses the same disposable element as the Multi-Parameter Mobile CareGuide 3100 Oximeter, a disposable sleeve that isolates the sensor optical elements from the patient's skin.
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510(k) Premarket Notification Submission: Multi-Parameter Mobile CareGuide™ 3100 Oximeter with Tablet
### Indications for Use
The Multi-Parameter Mobile CareGuide™ 3100 Oximeter with Tablet is intended for use as an adjunct, non-invasive monitor of the hemoglobin oxygen saturation and pH of microvascular blood in a region of skeletal muscle tissue beneath the sensor may be positioned on pigmented skin. The Multi-Parameter Mobile CareGuide 3100 Oximeter is intended to allow for display of SmO2 and pHm data on an Android Tablet display, which would interface with the Multi-Parameter Mobile CareGuide 3100 Oximeter via USB connection. The Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet is intended for prescriptive use (Rx only) by a trained healthcare professional in a hospital. The Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet provides display of the most recent values of SmO2 and pHm in a trend, as well as operational device information. The Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet should not be used as the sole basis for diagnosis or therapy. Note: The prospective clinical value of data from the Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet has not been demonstrated in disease states.
# Rationale for Substantial Equivalence
The CareGuide 3100 device's oximetry feature has been already cleared under classification regulation 21 C.F.R § 870.2700, Oximeter. The device's pHm feature has been already cleared under classification regulation 21 C.F.R § 868.1170, Anesthesiology. This 510(k) is seeking clearance for use of the CareGuide 3100 with a dedicated Android Display device.
There is no change in how the User would use the information generated by the Multi-Parameter Care Guide 3100 with Tablet relative to the predicate devices. They are all intended for monitoring of respective parameters. Neither the Multi-Parameter CareGuide 3100 with Tablet nor any of the predicate devices identified by RMI provides diagnostic output.
The Multi-Parameter CareGuide 3100 with Tablet has the same technological characteristics as the previously cleared RMI devices, the CareGuide 1100 (K113656) and the Multi-Parameter Mobile CareGuide 2100 (K130079).
- The principle of operation of the Multi-Parameter Mobile CareGuide 3100 Oximeter with . Tablet is identical to that of the predicate CareGuide devices. They use the exact same NIR spectroscopic platform to measure tissue oxygen saturation and muscle. The same software quantitative algorithm for SmO2 and pHm is used in both devices.
- The Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet is equivalent to the ● Multi-Parameter Mobile CareGuide 3100 Oximeter predicate in reusable components. Both devices use the exact same sensor hardware: main sensor CPU board, battery, optical board (light sources, spectrometer and microprocessor), USB interfaces, plastic housing and cables.
- . The Multi-Parameter Mobile CareGuide 3100 Oximeter with Table is equivalent to the Multi-Parameter Mobile CareGuide 3100 Oximeter predicate in disposable components. Both devices use the exact same disposable sheath ("Ray") and disposable sensor check device ("Cradle").
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510(k) Premarket Notification Submission: Multi-Parameter Mobile CareGuide™ 3100 Oximeter with Tablet
- . The Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet has the identical underlying LED light source as the CareGuide predicates, with the exact same range of wavelength (700-900 nm).
- . The Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet and the predicated CareGuide 1100 Oximeter are equivalent. The CareGuide 1100 System includes a Monitor display while the CareGuide 3100 {subject of this 510(k)} includes a dedicated Android display. Both displays are functionally equivalent. Both CareGuide 1100 and 3110 displays are tools that interface with the CareGuide oximeter and display real-time parameters and historical trends per their cleared indications for use.
- . The predicate Multi-Parameter Mobile CareGuide 3100 Oximeter is compatible with any USB-connected display device that supports the specified communications protocol. The Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet {subject of this 510(k)} now includes such a USB-connected display device (i.e. dedicated Android tablet), supporting that specified communications protocol.
# Summary of Safety and Effectiveness Data
Bench testing demonstrates that the Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet is safe and effective, meeting all relevant consensuses and FDA recognized standards. The bench and software test results in this submission demonstrate that the Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet meets the expected performance requirements for an Oximeter. The Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet is therefore equivalent to the predicates by indications for use and device features and functionality.
#### Conclusion
The Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet is equivalent to predicate device in terms of technology (NIR Spectroscopy) and intended use. The Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet does not raise new questions of safety or effectiveness, as compared to the predicate. Therefore, the Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet is substantially equivalent to the predicate device.
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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 and Human Services. The logo features a stylized caduceus, which is a symbol of medicine and health. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular pattern around the caduceus. The logo is black and white.
#### Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
April 11, 2014
Reflectance Medical, Inc. Babs Soller Chief Executive Officer 116 Flanders Road, Suite 1000 Westborough, MA 01581 US
Re: K133923
> Trade/Device Name: Multi-parameter Mobile CareGuide 3100 Oximeter with Tablet Regulation Number: 21 CFR 870.8700 Regulation Name: Oximeter Regulatory Class: Class II Product Code: MUD Dated: March 7, 2014 Received: March 13, 2014
Dear Dr. Soller,
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.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean r lease be actised may be notal your device complies with other requirements of the Act
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Page 2 - Dr. Babs Soller
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 devicerelated 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/Resourcesfor You/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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,
Image /page/5/Picture/8 description: The image shows a logo with the letters FDA. The letters are stylized and have a bold, geometric design. There are lines drawn through the logo, which may indicate that it is not valid or has been rejected. The logo is black and white and appears to be a scanned image.
for Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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510(k) Premarket Notification Submission: Multi-Parameter Mobile CareGuide™ 3100 Oximeter with Tablet
# Indications for Use Form
Indications for Use
510(k) Number (if known): K133923_
Device Name: Multi-Parameter Mobile CareGuide™ 3100 Oximeter with Tablet
Indications for Use:
The Multi-Parameter Mobile CarcGuide™ 3100 Oximeter with Tablet is intended for use as an adjunct, non-invasive monitor of the hemoglobin oxygen saturation and pH of microvascular blood in a region of skeletal muscle tissue beneath the sensor may be positioned on pigmented skin. The Multi-Parameter Mobile CareGuide 3100 Oximeter is intended to allow for display of SmO2 and pHm data on an Android Tablet display, which would interface with the Multi-Parameter Mobile CareGuide 3100 Oximeter via USB connection. The Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet is intended for prescriptive use (Rx only) by a trained healthcare professional in a hospital. The Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet provides display of the most recent values of SmO2 and pHm in a trend, as well as operational device information. The Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet should not be used as the sole basis for diagnosis or therapy. Note: The prospective clinical value of data from the Multi-Parameter Mobile CareGuide 3100 Oximeter with Tablet has not been demonstrated in disease states.
Prescription Use X (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)
Page of of
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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.