The Invacare® Platinum™ Mobile Oxygen Concentrator is intended to provide supplemental oxygen to patients with respiratory disorders. The Invacare® Platinum™ Mobile Oxygen Concentrator can be used in a home, institution, vehicle, or other environments outside the home. The device is not intended to be life supporting or life sustaining.
Device Story
Portable oxygen concentrator; provides supplemental oxygen via pulsed demand flow (settings P1-P4). Uses synthetic zeolite sieve beds to concentrate oxygen from ambient air (87%-95.6% purity). Operated by patient in home, institution, or vehicle. Nasal cannula delivers oxygen to patient. Includes oxygen purity sensor and alarms for low purity, sensor failure, and no breath detection. Powered by removable battery or AC/DC adapters. Healthcare provider uses device to manage patient oxygen therapy; output affects clinical decision-making by ensuring prescribed oxygen delivery. Benefits patient by providing portable, on-demand supplemental oxygen.
Clinical Evidence
No clinical data. Substantial equivalence supported by bench testing, including respiratory performance (pulse volume, trigger sensitivity, oxygen purity), electrical safety (AAMI ES60601-1, IEC 60601-1), EMC (IEC 60601-1-2), software verification, and biocompatibility (ISO 10993).
Indicated for adult patients with respiratory disorders requiring supplemental oxygen. Not for life-supporting or life-sustaining use.
Regulatory Classification
Identification
A portable oxygen generator is a device that is intended to release oxygen for respiratory therapy by means of either a chemical reaction or physical means (e.g., a molecular sieve).
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
September 27, 2016
Invacare Corporation Elijah Wreh Regulatory Affairs Manager One Invacare Way Elyria, OH 44035
Re: K160630
Trade/Device Name: Invacare® Platinum™ Mobile Oxygen Concentrator Regulation Number: 21 CFR 868.5440 Regulation Name: Portable Oxygen Generator Regulatory Class: Class II Product Code: CAW Dated: August 25, 2016 Received: August 26, 2016
Dear Elijah Wreh:
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 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 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.
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If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free 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" (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 Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours,
Tejashri Purohit-Sheth, M.D.
Tejashri Purohit-Sheth, M.D. Clinical Deputy Director DAGRID/ODE/CDRH FOR
Tina Kiang, Ph.D. Acting 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) K160630
Device Name
Invacare® Platinum™ Mobile Oxygen Concentrator
Indications for Use (Describe)
The Invacare® Platinum™ Mobile Oxygen Concentrator is intended to provide supplemental oxygen to patients with respiratory disorders. The device can be used in a home, institution, vehicle, or other environments outside the home.
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) |
|----------------------------------------------|---------------------------------------------|
|----------------------------------------------|---------------------------------------------|
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#### 510(k) Summary
| SUBMITTER: | Invacare Corporation<br>One Invacare Way<br>Elyria, OH 44035 |
|----------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------|
| CONTACT PERSON: | Elijah N. Wreh<br>Regulatory Affairs Manager (Pre-Market)<br>Phone: (440) 329-6840<br>Email: ewreh@invacare.com |
| Date Prepared: | September 22, 2016 |
| DEVICE<br>Name of Device:<br>Common or Usual Name:<br>Classification Name: | Invacare® Platinum™ Mobile Oxygen Concentrator<br>Generator, Oxygen, Portable<br>Portable Oxygen Generator 21 CFR §868.5440 |
| Regulatory Class: | II |
| Product Code: | CAW: Generator, Oxygen, Portable |
| PREDICATE DEVICE: | The Invacare Flyer (Model XPO100) (K071928)<br>No reference devices were used in this submission |
| Patient Population: | Adult Patient Only |
| Environment of Use: | Home, institution, vehicle, or other environments outside the<br>home |
#### DEVICE DESCRIPTION
This Traditional [510(k)] submission is being supplied to the U.S. FDA to obtain authorization to market the Invacare® Platinum™ Mobile Oxygen Concentrator. The Invacare® Platinum™ Mobile Oxygen Concentrator is a portable oxygen concentrator that provides oxygen in pulsed demand flow dosages at settings of P1 through P4. The oxygen concentration level of the output gas ranges from 87% to 95.6%. The device is used with a nasal cannula to direct oxygen from the device to the patient. The Invacare® Platinum™ Mobile Oxygen Concentrator can be used in a home, institution, vehicle, or other environments outside the home. The device is not intended to be life supporting or life sustaining. There is no prior submission for the subject device.
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The associated accessories include:
- Invacare® Battery .
- . Invacare® Battery Charger
- AC Adapter ●
- DC Power Cable .
- Carry Bag .
# INDICATIONS FOR USE
The Invacare® Platinum™ Mobile Oxygen Concentrator is intended to provide supplemental oxygen to patients with respiratory disorders. The device can be used in a home, institution, vehicle, or other environments outside the home.
## INTENDED USE
The Invacare® Platinum™ Mobile Oxygen Concentrator is intended to provide supplemental oxygen to patients with respiratory disorders. The Invacare® Platinum™ Mobile Oxygen Concentrator can be used in a home, institution, vehicle, or other environments outside the home. The device is not intended to be life supporting or life sustaining.
## INDICATIONS FOR USE COMPARISON
The subject device and the previously cleared predicate device is indicated to provide supplemental oxygen to patients with respiratory disorders. The subject device and the predicate device is intended to be used in a home, institution, vehicle, or other environments outside the home. The subject device is substantially equivalent to the predicate device in regards to intended use to provide supplemental oxygen to patients with respiratory disorders.
# COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE
The device comparison demonstrates that the subject device is substantially equivalent in design, materials, and operational principles to the previously cleared The Invacare Flyer (Model XPO100) (K071928).
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#### Design Characteristics Comparison
| No. | Feature | Subject Device<br>Platinum Mobile Oxygen Concentrator<br>(K160630) | Predicate Device<br>The Invacare Flyer (Model XPO100)<br>(K071928) | |
|-----|----------------------|--------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------|-------------------------|
| 1. | Sieve Bed Material | Synthetic zeolite OP-76 | Synthetic zeolite Z12-07 | |
| 2. | Height | 9.45" max | 10.0" +/- 1" | |
| | Width | 7.5" max | 7.0" +/- 1" | |
| | Depth | 3.88" max | 4.3" +/-1" | |
| | Dimensions<br>Weight | < 5 lbs. (with standard removable battery) | ≤ 7 lbs. (with non-removable internal battery) | |
| 3. | Oxygen Purity Sensor | Yes | No | |
| 4. | Flow Rates | Pulse flow P1, P2, P3, P4<br>Flow volume per minute is 220-880ml | Pulse flow 1, 2, 3, 4, 5<br>Flow volume per minute is 300-840ml | |
| 5. | Alarms | Low oxygen<br>purity | Yes | No |
| | | Oxygen sensor<br>failure | Yes | No |
| | | No breath detect | Will supply bolus of O2 if no inhalation detected in 15<br>seconds. Unit will shut down if no breath is detected for ><br>120 seconds. | No "Auto-Pulse" feature |
## PERFORMANCE DATA
#### Respiratory Testing
Respiratory testing was performed to evaluate the functionality of the design, materials, and operational principles of the subject device. This includes the following:
- Product Weight Test
- Pulse Volume/Pulse Time/Trigger Sensitivity / Oxygen Purity Test ●
- External Battery Charger Charge Time ●
- Oxygen Sensor Accuracy ●
- Oxygen Purity at AC Supply Mains Extremes
- Oxygen Purity at DC Power Extremes ●
- Oxygen Purity after Storage Thermal Cycling
- Oxygen Purity at Low and High Temperature ●
- . Hot – Swapping Batteries
- Battery Discharge Times
- Battery Charge Times
- Oxygen Purity at Low and High Altitude
- Software Functional Test ●
- Oxygen Alarms Test
- Operational Alarms Test ●
- Full Assembly Sound Performance Test ●
- POC1 Battery Charge Time When POC1 Unit Not Running ●
## Electrical Safety and Electromagnetic Compatibility (EMC)
Electrical Safety and Electromagnetic Compatibility testing was performed to evaluate the functionality of the design, materials, and operational principles of the subject device. This includes the following:
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- AAMI ES60601-1: Medical Electrical Equipment Part 1: General Requirements for . Basic Safety and Essential Performance
- . IEC 60601-1: Medical Electrical Equipment - Part 1: General Requirements for Basic Safety & Essential Performance
- ISO 80601-2-67: Medical Electrical Equipment Part 2-67: Particular Requirements . for Basic Safety and Essential Performance of Oxygen Conserving Equipment
- ISO 80601-2-69 Medical electrical equipment Part 2: Particular requirements for the . basic safety and essential performance of oxygen concentrator equipment
- . IEC 60601-1-2: Medical Electrical Equipment – Part 1-2: General requirements for basic safety and essential performance – Collateral standard: Electromagnetic compatibility - Requirements and tests
- IEC 60601-1-6: Medical electrical equipment Part 1-6 General requirements for safety -Collateral Standard: Usability
- IEC 62366: Medical devices Application of usability engineering to medical devices ●
- IEC 60601-1-8: Medical electrical equipment General requirements for basic safety . and essential performance – Collateral standard: General requirements, tests and guidance for alarm systems in medical electrical equipment and medical electrical systems
- IEC 60601-1-11 Medical electrical equipment Part 1-11: General requirements for . basic safety and essential performance – Collateral Standard: Requirements for medical electrical equipment and medical electrical systems used in the home healthcare environment
## Software Verification Testing
Software Verification Testing was performed to evaluate the functionality of the design, materials, and operational principles of the subject device. This includes the following: Software verification testing was conducted on the subject device as recommended by the FDA's guidance document "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices."
Level of Concern: The software for this device was considered as a minor level of concern because the subject device is a supplement to a patient's normal oxygen intake. A software failure will not result in injury to a patient or user. The device is not intended to be life supporting or life sustaining.
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# Biocompatibility Testing
Biocompatibility testing was performed on the subject device raw materials and the test results demonstrated that the subject device is biocompatible. The testing was conducted in accordance with the FDA Blue Book Memorandum #G95 – 1 "Use of International Standard ISO – 10993, 'Biological Evaluation of Medical Devices Part 1: Evaluation and Testing,"' May 1, 1995, and International Standard ISO 10993 – 1 "Biological Evaluation of Medical Devices – Part 1: Evaluation and Testing Within a Risk Management Process," as recognized by FDA. The battery of testing included the following tests:
- AAMI / ANSI / ISO 10993-5:2009. Biological Evaluation of Medical Devices Part 5: . Tests for in vitro Cytotoxicity
- . AAMI / ANSI / ISO 10993-10:2010, Biological Evaluation of Medical Devices - Part 10: Tests for Skin Irritation
- . ISO 10993-11:2010, Biological Evaluation of Medical Devices - Part 11: Tests for Systemic Toxicity
- . Volatile Organic Chemicals Using the EPA TO-17 Method
- . Particulate Matter (PM)
# Animal Study
Animal testing was not required for this submission.
# Clinical Testing
Clinical testing was not required to demonstrate substantial equivalence to the predicate device.
# CONCLUSIONS
The subject device has the same intended use and similar technological characteristics as the predicate device. The non-clinical laboratory data support the substantial equivalence of Invacare® Platinum™ Mobile Oxygen Concentrator and demonstrates that the subject device performs as intended in the specified use conditions. Therefore, the subject Invacare® Platinum™ Mobile Oxygen Concentrator is substantially equivalent to the predicate device.
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.