Masimo Acoustic Respiration Sensors, infant and neonate
Applicant
Masimo Corporation
Product Code
BZQ · Anesthesiology
Decision Date
Sep 5, 2018
Decision
SESE
Submission Type
Abbreviated
Regulation
21 CFR 868.2375
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The Masimo Acoustic Respiration Sensor RAS-45 Inf/Neo is indicated for continuous, noninvasive monitoring of respiratory rate (RRa®). The Masimo Acoustic Respiration Sensor RAS-45 Inf/Neo is intended for use with infant and neonatal patients, in hospitals, hospital-type facilities, home environments, and transport within healthcare facilities. The rainbow Acoustic Monitoring® sensors are not indicated for Apnea monitoring.
Device Story
Device is a disposable, single-use piezoelectric sensor applied to infant/neonatal chest to capture acoustic respiratory signals (vibrations). Sensor connects via dual cable to compatible pulse oximeter monitor. Monitor digitizes signals, evaluates frequency of signal envelope, and calculates real-time respiratory rate. Used in hospitals, home environments, and transport by clinicians or caregivers. Output displayed on oximeter screen; assists clinicians in continuous respiratory monitoring. Benefits include noninvasive, continuous tracking of respiratory rate in small patients.
Clinical Evidence
Clinical study on convenience sample of infant/neonatal patients. Raw acoustic data collected via production-equivalent sensors and processed through RAS-45 Inf/Neo algorithm. Compared against manual/auditory annotation (ground truth) and capnography. Results: Accuracy Root Mean Square (Arms) of 1.1 breaths per minute vs. manual reference; 1.1 Arms vs. 2.1 Arms for capnography.
Technological Characteristics
Piezoelectric sensor element; adhesive strip; M6 rainbow® connector. Patient-contacting materials ISO 10993 compliant. Dimensions 2.18" x 1.7" x 0.12". Powered by host oximeter. Non-sterile. Connectivity via dual cable to Masimo rainbow® Acoustic Monitoring-enabled pulse oximeter.
Indications for Use
Indicated for continuous, noninvasive respiratory rate monitoring in infant and neonatal patients weighing < 10 kg. Not indicated for apnea monitoring.
Regulatory Classification
Identification
A breathing (ventilatory) frequency monitor is a device intended to measure or monitor a patient's respiratory rate. The device may provide an audible or visible alarm when the respiratory rate, averaged over time, is outside operator settable alarm limits. This device does not include the apnea monitor classified in § 868.2377.
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September 5, 2018
Masimo Corporation Sindura Penubarthi Regulatory Affairs Specialist 52 Discovery Irvine, California 92618
Re: K173976
Trade/Device Name: Masimo Acoustic Respiration Sensors Regulation Number: 21 CFR 870.2700 Regulation Name: Oximeter Regulatory Class: Class II Product Code: DQA, BZQ Dated: August 3, 2018 Received: August 6, 2018
Dear Ms. Penubarthi:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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
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801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.htm); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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 comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice
(https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
James J. Lee -S
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) K173976
Device Name Masimo Acoustic Respiration Sensors
#### Indications for Use (Describe)
The Masimo Acoustic Respiration Sensor RAS-45 Inf/Neo is indicated for continuous, noninvasive monitoring of respiratory rate (RRa®). The Masimo Acoustic Respiration Sensor RAS-45 Inf/Neo is intended for use with infant and neonatal patients, in hospitals, hospital-type facilities, home environments, and transport within healthcare facilities.
The rainbow Acoustic Monitoring® sensors are not indicated for Apnea monitoring.
Type of Use (Select one or both, as applicable)
| <span style="font-family: DejaVu Sans, sans-serif">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) |
|----------------------------------------------------------------------------------------------------------|
| <span style="font-family: DejaVu Sans, sans-serif">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) |
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Image /page/3/Picture/0 description: The image shows the logo for Masimo, a medical technology company. The logo consists of a red symbol to the left of the word "Masimo" in a bold, sans-serif font. To the right of the word "Masimo" is the company's address, which is "52 Discovery, Irvine CA 92618".
#### 510(k) Summary Section 5:
| Submitter and Address of<br>Manufacturing Facility: | Masimo Corporation<br>52 Discovery<br>Irvine, CA 92618<br>Phone: (949) 297-7000<br>FAX: (949) 297-7592 |
|-----------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Date: | December 27, 2017 |
| Contact: | Sindura Penubarthi<br>Regulatory Affairs Manager |
| Trade Name: | Masimo Acoustic Respiration Sensors |
| Common Name: | Pulse Oximeter |
| Classification Regulation/<br>Product Code: | 21 CFR 870.2700, Class II/DQA - oximeter |
| Secondary Classification/<br>Product Code: | Class II/BZQ - breathing frequency monitor |
| Establishment Registration<br>Number: | 2031172 |
| Reason for Premarket<br>Notification: | New Device |
| Predicate Device: | K120984 - Masimo Acoustic Respiration Sensor (adult/pediatric) |
| Performance Standards | No performance standards for the above device have been<br>promulgated pursuant to Section 514 of the Food and Drug<br>Administration Modernization Act of 1997 (FDAMA) |
### 5.1 Device Description
The subject device, the Masimo Acoustic Respiration Sensor RAS-45 Inf/Neo, is a noninvasive, disposable, single-use device comprising a piezoelectric sensor element and an adhesive strip that is attached to the patient's chest for the purpose of noninvasive respiration/respiratory rate monitoring in infant and neonatal patients (< 10 kg). Like the predicate (K120984), the RAS-45 Inf/Neo sensor is a rainbow Acoustic Monitoring® sensor intended to be used with, and attached via dual cable to, pulse oximeter monitors incorporating the Masimo rainbow® Acoustic Monitoring technology to provide a continuous calculation and display of the patient's acoustic respiration/respiratory rate (RRa®).
## 5.2 Intended Use/Indications for Use
The Masimo Acoustic Respiration Sensor RAS-45 Inf/Neo is indicated for continuous, noninvasive monitoring of respiratory rate (RRa"). The Masimo Acoustic Respiration Sensor RAS-45 Inf/Neo is intended for use with infant and neonatal patients, in hospital-type facilities, home
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Image /page/4/Picture/0 description: The image shows the logo for Masimo, a medical technology company. The logo consists of a red circle with a white checkmark inside, followed by the company name in bold, black letters. To the right of the logo is the company's address, which is 52 Discovery, Irvine CA 92618.
#### Section 5: 510(k) Summary
environments, and transport within healthcare facilities.
The rainbow Acoustic Monitoring® sensors are not indicated for Apnea monitoring.
### 5.3 Device Specifications
Specifications of the RAS-45 Inf/Neo are provided in Table 5.1 below.
| Table 5.1 Specifications of RAS-45 Inf/Neo | | |
|--------------------------------------------|-----------------------------------------------|--|
| Feature | Specification | |
| Application Site | Chest | |
| Body Weight | Infant, Neonate < 10 kg | |
| Type of Use | Single-use | |
| Sterility | Supplied non-sterile | |
| Performance | | |
| Respiration Rate Measurement | 4-120 breaths per minute | |
| Range | | |
| Respiration Rate Measurement | ± 1 breaths per minute, over the entire range | |
| Accuracy | | |
| Physical | | |
| General Overall Dimensions | 2.18" x 1.7" x 0.12" | |
| Weight | 13 grams | |
| Shelf Life | 2 years | |
| Patient-Contacting Materials | ISO 10993 compliant | |
| Electrical | | |
| Interface | M6 rainbow® connector | |
| Type of Power | Oximeter dependent | |
| Environmental | | |
| Operating Temperature | +5°C to +40°C, ambient humidity | |
| Storage/Transport Temperature | -40°C to +60°C, ambient humidity | |
| Storage/Transport Humidity | 10% to 95%, non-condensing | |
### 5.4 Technological Characteristics
### 5.4.1 Principle of Operation
Rainbow® Acoustic Monitoring involves capture of the acoustic signals (vibrations) associated with respiration via a piezoelectric sensor attached to the measurement site (i.e., patient's chest). The captured signals are transmitted via the sensor cable and the dual cable to a compatible pulse oximeter monitor where they are digitized and the frequency of the resultant signal envelope (outline) is evaluated to provide and display a real-time, continuous respiratory rate.
### 5.4.2 Mechanism of Action
The pulse oximeter is turned on for its operation. The RAS-45 Inf/Neo sensor is applied to the patient's chest. The RAS 45 Inf/Neo sensor and an SpO2 sensor are connected to a dual channel cable.
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Image /page/5/Picture/0 description: The image shows the logo for Masimo, a medical technology company. The logo consists of a red circle with a white checkmark inside, followed by the company name in black, bold letters. To the right of the logo is the company's address, which is 52 Discovery, Irvine CA 92618.
#### Section 5: 510(k) Summary
The dual channel cable is connected to a pulse oximeter that has the Masimo rainbow" Acoustic Monitoring technology. The pulse oximeter displays acoustic respiration/respiratory rate (RRa) measurements. Once use is complete, the user turns the pulse oximeter power "off" and removes the sensor from the patient.
### 5.5 Summary of Similarities and Difference between the Subject and Predicate Devices
The subject device, RAS-45 Inf/Neo, and the predicate device, RAS-125c (K120984), have the following key similarities:
- . both have the same intended use,
- both have the same technological characteristics, including principle of operation (except that the subject device intended to be applied to the patient's chest, rather than the neck) and mechanism of action,
- . both have the same intended environment (e.g., hospital-type facilities, mobile and home environments), and
- both have the same acoustic respiration/respiratory rate (RRa) measurement accuracy (± 1 ● breaths per minute).
The subject device, RAS-45 Inf/Neo, and the predicate device, RAS-125c, have the following key differences:
- the subject device is designated for use with infant and neonatal patients (< 10 kg) whereas the predicate device is designated for use with adult and pediatric patients (> 10 kg),
- . the subject device has a respiration/respiratory rate (RRa) measurement range of 4 to 120 breaths per minute whereas the predicate device has a measurement range of 4 to 70 breaths per minute,
- the subject device is intended to be applied to the patient's chest whereas the predicate device ● is intended to be applied to the patient's neck, and
- . the subject device has a circular shape and a smaller footprint than the predicate device.
Table 5.2 compares specification differences between the RAS-45 Inf/Neo and the RAS-125c.
| Table 5.2 RAS-45 Inf/Neo and RAS-125c Comparison | | |
|--------------------------------------------------|----------------------------------|---------------------------------|
| Feature | Specifications | |
| | RAS-45 Inf/Neo | RAS-125c |
| Application Site | Chest | Neck |
| Body Weight | Infant, Neonate < 10 kg | Adult, Pediatric > 10 kg |
| Range and Accuracy,<br>(breaths per minute) | 4-120 ± 1, over the entire range | 4-70 ± 1, over the entire range |
| Sensor Shape | Circular | Rectangular |
### 5.6 Non-Clinical Testing
Bench testing was performed on the subject device to validate measurement accuracy (of ± 1 breaths
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Image /page/6/Picture/0 description: The image shows the logo for Masimo, a medical technology company. The logo consists of a red circle with a white checkmark inside, followed by the company name in black, bold letters. To the right of the logo is the company's address, which is 52 Discovery, Irvine CA 92618.
# Section 5: 510(k) Summarv
per minute) for the entire measurement range of 4 to 120 breaths per minute. Additionally, the following non-clinical testing, as applicable, was performed in accordance with Masimo design control requirements and quality system to demonstrate substantial equivalence of the subject device with its predicate:
- Electromagnetic Compatibility and Electrical Safety testing per IEC 60601-1 .
- EMC testing per: ●
- o IEC-60601-1-2
- ISO 80601-2-61 Clause 202.6.2.3 o
- IEC 60601-2-49 Section 202.6.2.101 O
- AIM 7351731 O
- . Usability testing per FDA Human Factors and Usability Guidance
- . Testing per IEC 60601-1-11
- . Biocompatibility testing per ISO-10993
- Mechanical testing per ISTA-2A and MIL-STD 810E ●
- Environmental testing per IEC-60601-1 ●
### 5.7 Clinical Testing
Clinical testing was completed to assess clinical performance of the subject device in the infant and neonate population. Production equivalent sensors, connected to pulse oximeters with Masimo rainbow® Acoustic Monitoring technology, were applied to a convenience sample of infant and neonatal patients to gather raw acoustic data. The production equivalent sensors were physically and functionally identical to the RAS-45 Inf/Neo, and only differed in that the sensors did not identify themselves as RAS-45 Inf/Neo sensors to the pulse oximeters. The raw acoustic data was processed through the RAS-45 Inf/Neo algorithm and, as with the predicate K120984, compared against clinicians manually annotating the raw acoustic data. The results showed that the Ams (Accuracy Root Mean Square) of the subject device was 1.1 breaths per minute when compared to the manual/auditory reference method. Clinical performance of the subject device was further assessed by comparison to the performance of a capnography device in a similar infant and neonatal patient population, and the results showed comparable performance (See Table 5.3).
| Table 5.3 – Comparison of Clinical Performance of RAS-45 Inf/Neo vs. Capnograph | |
|---------------------------------------------------------------------------------|----------------------------|
| Device | Arms (breaths per minute)* |
| RAS-45 Inf/Neo* | 1.1 |
| Capnograph* | 2.1 |
* Assessment of clinical performance was based on convenience sampling on two similar cohorts of patients.
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Image /page/7/Picture/0 description: The image shows the logo for Masimo, a medical technology company. The logo consists of a red symbol on the left and the company name "Masimo" in black text to the right of the symbol. Below the company name is the address "52 Discovery Irvine CA 92618".
# Section 5: 510(k) Summary
## 5.8 Conclusion
The information in this 510(k) submission demonstrates that the Masimo Acoustic Respiration Sensor RAS-45 Inf/Neo 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.