The CO2 Mainstream Module is intended to provide carbon dioxide monitoring system during anesthesia/recovery, in Emergency Medicine/Transport or Respiratory care.
Device Story
Non-dispersive infrared (NDIR) gas analyzer; measures CO2 concentration in breathing gases via infrared energy absorption. Module incorporates autozero adjustment, gain control, and atmospheric pressure sensors for compensation. Inputs: infrared light transmission through gas sample. Outputs: numerical EtCO2 values (mmHg, %, kPa), respiration rate, and optional capnogram waveform. Used in clinical settings (anesthesia, ICU, transport) by healthcare providers; integrates with host monitoring systems. Provides real-time airway integrity and endotracheal tube placement assessment; aids clinical decision-making regarding patient ventilation status.
Clinical Evidence
No clinical data. Substantial equivalence supported by bench testing, including electrical safety (IEC 60601-1), EMC (IEC 60601-1-2), performance testing per ISO 80601-2-55, and biocompatibility testing per ISO 10993 and ISO 18562 series.
Technological Characteristics
Non-dispersive infrared (NDIR) gas analyzer; multi-channel infrared detector; no moving parts. Complies with ISO 80601-2-55. Includes atmospheric pressure sensors for compensation. Class II, Type BF applied part. Connectivity: integrates with host monitoring system. Non-sterile.
Indications for Use
Indicated for CO2 monitoring in neonates to adults during anesthesia, recovery, emergency medicine, transport, or respiratory care. Capno-M is for intubated patients; Capno-M+ is for intubated and non-intubated patients.
Regulatory Classification
Identification
A carbon dioxide gas analyzer is a device intended to measure the concentration of carbon dioxide in a gas mixture to aid in determining the patient's ventilatory, circulatory, and metabolic status. The device may use techniques such as chemical titration, absorption of infrared radiation, gas chromatography, or mass spectrometry.
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Image /page/0/Picture/0 description: The image shows the logos of the Department of Health & Human Services and the Food and Drug Administration (FDA). The Department of Health & Human Services logo is on the left, and the FDA logo is on the right. The FDA logo is a blue square with the letters "FDA" in white, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue.
Beijing Kingst Commercial & Trade Co.,Ltd. % Charlie Mack Principal Engineer Irc 2950 E Lindrick Drive Chandler, Arizona 85249
# Re: K192446
Trade/Device Name: CO2 Mainstream Module Regulation Number: 21 CFR 868.1400 Regulation Name: Carbon Dioxide Gas Analyzer Regulatory Class: Class II Product Code: CCK Dated: March 21, 2020 Received: April 14, 2020
# Dear Charlie Mack:
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/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Todd Courtney Assistant Director DHT1C: Division of ENT, Sleep Disordered Breathing, Respiratory and Anesthesia Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K192446
Device Name
CO2 Mainstream Module, Capno-M, Capno-M+
Indications for Use (Describe)
The CO2 Mainstream Module is intended to provide carbon dioxide monitoring system during anesthesia/recovery, in Emergency Medicine/Transport or Respiratory care.
| Type of Use (Select one or both, as applicable) |
|-------------------------------------------------|
|-------------------------------------------------|
X Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
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Image /page/3/Picture/2 description: The image shows a logo for a company called "Jingst". The logo is blue and features a stylized letter "J" on the left side. Below the company name are three Chinese characters.
# Beijing Kingst Commercial & Trade Co., Ltd.
510(k) Summary (21 CFR §807.92)
# K192446
# Submitter Information:
| Submitter Name: | Beijing Kingst Commercial & Trade Co., Ltd. |
|----------------------|----------------------------------------------------------------------------------------|
| Address: | 6th Floor of No.2-7, Beibinhe Road, Xibianmen, Xicheng<br>Dist, Beijing, P.R.C. 100053 |
| Telephone: | +86-10-68158013 |
| Fax: | +86-10-68156857 |
| Contact Person: | Mr. Judong Gao<br>General Manager |
| Email: | charliemack@irc-us.com |
| Date of Preparation: | May 18, 2020 |
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#### K192446
### Subject Devices :
Trade/proprietary name : CO2 Mainstream Module Model Capno-M, Capno-M+ Carbon Common Name: Dioxide Gas Analyzer Classification: CCK
Regulatory Class: Class II
Regulation Number: 21CFR868.1400
# Predicate Device :
| Trade Name: | CAPNOSTAT 5 |
|--------------------|------------------------------|
| 510(k) Reference: | K042601 |
| Common Name: | Carbon Dioxide Gas Analyzer |
| Regulation Number: | 21CFR868.1400 |
| Regulatory Class: | Class II |
| Manufacturer: | Respironics Novametrix, Inc. |
# Purpose of Submission
This is a new traditional 510(K) submission of a Carbon Dioxide Gas Analyzer.
# Device Description
The CO2 Mainstream module is a non-dispersive infrared gas analyzer with an autozero adjustment system and gain control.
The operation of the CO2 Mainstream module is based on CO2 energy absorption rates. CO2 molecules absorb infrared light energy of specific wavelengths, with the amount of energy absorbed being directly related to the CO2 concentration. When an IR light beam is passed through a gas sample containing CO2, the electronic signal from the infrared sensor (which measures the remaining light energy), can be obtained. This signal is then compared to the energy of the IR source, and calibrated to reflect CO2 concentration in the sample accurately. Calibration is performed using the infrared sensor's response to a known concentration of CO2 stored in the module'smemory.
The circuit module retains the atmospheric absolute pressure sensors and control of the pressure sensor. Modules can measure atmospheric pressure, and atmospheric can compensate the calculation for the concentrations of carbon dioxide, which improves the design accuracy.
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The module then determines CO2 concentration in the breathing gases by measuring the amount of light absorbed by these gases. EtCO2 displays a numerical value in millimeters of mercury (mmHg), percent (%), or kilopascals (kPa). In addition, a CO2 waveform (Capnogram) may be displayed, which is a valuable clinical tool that can be used to assess patient airway integrity and proper endotracheal tube placement. Respiration rate is calculated by measuring the time interval between detected breaths.
The differences between the Capno M and M+ are only with the intended patient type. The Capno M is intended for use on intubated patients, where the Capno M+ is intended for use with intubated and non-intubated patients. The operating principles, unit of measurement, ETCO2 measurement range, accuracy, respiration rate range, and respiration rate accuracy are the same for both devices.
# Indication for use
The CO2 Mainstream Module is intended to provide carbon dioxide monitoring to a monitoring system during anesthesia/recovery in host Emergencv Medicine/Transport or Respiratory care.
# Comparison with the predicate device:
Beijing Kingst Commercial & Trade Co., Ltd. believes that the Beijing Kingst Commercial & Trade Co., Ltd. CO2 Mainstream Module is substantially equivalent to the Respironics Novametrix. Inc. CAPNOSTAT 5 Carbon Dioxide Gas Analyzer (K042601).
There are differences in the CO2 response time and the respiration rate measurement range. The response time difference is 10 ms. This does not affect the accuracy or usage. The measurement range difference is at the lowest part of the scale. The predicate devices' range is 2-150 breaths per minute, where the submitted device range is 3-150 breaths per minute. The difference at the lower end of the range does not pose any risks or hazards to patients. They have the same intended use. The minor differences in technological characteristics do not raise issues of safety and effectiveness. The subject device is identical to the predicate device. Please refer to the following pages for specific difference details.
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# Comparison to Predicate Devices
| Element of<br>comparison | Subject Device | Predicate Device | Discussion |
|-------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------|
| Company | Beijing Kingst Commercial & Trade<br>Co., Ltd. | RESPIRONICS NOVAMETRIX, INC. | N/A |
| FDA510(K) Number | Pending | K042601 | N/A |
| Device Name | CO2 Mainstream Module | CAPNOSTAT 5 EtCO2 SENSOR (Mainstream) | N/A |
| Model Number | Capno-M, Capno-M+ | CAPNOSTAT 5 | N/A |
| Indications for Use | The CO2 Mainstream Module is<br>intended to provide carbon dioxide<br>monitoring to a host monitoring system<br>during anesthesia/recovery, in the<br>intensive care unit (ICU), and in<br>Emergency Medicine/Transport or<br>Respiratory care. | The intended use of the Capnostat 5 CO2<br>sensor is to provide carbon dioxide monitoring<br>to a host monitoring system during<br>anesthesia/recovery, in the intensive care unit<br>(ICU), and in Emergency Medicine/Transport or<br>Respiratory care. | IFU is the same for both<br>devices. |
| The type of<br>protection against<br>electric shock | Class II | Class II | No difference in insulation<br>methodology. |
| The degree of<br>protection against<br>electric shock | Type BF | Type BF | No difference in<br>protection against electric<br>shock. |
| Waveform Display | No display | No display | Neither device has a<br>display. |
| Intended patient<br>population | from newborn (neonate) to adult | from newborn (neonate) to adult | Same patient population. |
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| Element of<br>comparison | Subject Device | Predicate Device | Discussion |
|----------------------------|-----------------------------------|----------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------|
| CO2 module | CO2 Mainstream Module | CAPNOSTAT 5 EtCO2 (Main-stream)<br>Module(K042601) | N/A |
| CO2 measurement<br>method | Infrared absorption method | Infrared absorption method | No difference in<br>the<br>measurement<br>method |
| CO2 measure mode | Mainstream | Mainstream | Same measure<br>mode |
| Performance<br>Standards | Complies with ISO80601-2-55 | Unknown | N/A |
| Measuring<br>parameters | EtCO2 and Respiration Rate | EtCO2 and Respiration Rate | Matching<br>measuring<br>parameters |
| CO2 Response Time | <70 ms | Mainstream: < 60 ms (rise time) | The 10 ms<br>difference in<br>response time will<br>not influence the<br>usage effect.<br>It complies with<br>ISO80601-2-55 |
| Units | mmHg, kPa or Vol% | mmHg, kPa or Vol% | The same<br>unit of<br>measurement |
| EtCO2 Measurement<br>Range | 0-150 mmHg<br>0-19.7%<br>0-20 kPa | 0 - 150 mmHg<br>0 - 20%<br>0 - 20 kPa | It complies with<br>ISO80601-2-55 |
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| Element of<br>comparison | Subject Device | Predicate Device | Discussion |
|-----------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------|
| EtCO2 Accuracy<br>(at 760 mmHg,<br>ambient<br>temperature of<br>25°C) | 0~40 mmHg ±2 mmHg<br>41~70 mmHg ±5% of reading<br>71~100 mmHg ±8% of reading<br>101~150mmHg±10% of reading | 0~40 mmHg ±2 mmHg<br>41~70 mmHg ±5% of reading<br>71~100 mmHg ±8% of reading<br>101~150mmHg±10% of reading<br>(At respiration rates > 80 breaths per<br>minute, all ranges are ±12% of actual.) | It complies with ISO80601-2-<br>55 |
| Respiration Rate<br>measure range | 3 - 150 breaths/minute (RPM) | 2~150 breaths/minute (RPM) | 2 RPM of the respiration rate<br>will be abnormal. Respiration<br>at the minimum is not critical,<br>and the device complies with<br>ISO80601-2-55 |
| Respiration Rate<br>accuracy | ±1% of reading or ±1 breaths/min<br>whichever is greater | ±1 breath per minute | Both devices have the same<br>accuracy. |
| Operation principles | Non-dispersive infrared gas analysis, a<br>multi-channel infrared detector, no moving<br>parts | Non-dispersive infrared (NDIR) single<br>beam optics, dual-wavelength, no moving<br>parts | The measurement technology<br>principle is the same.<br>Both devices adopt NDIR (non-<br>dispersive infrared gas)<br>technology. |
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# Biocompatibility:
The subject device is classified as an external communicating device in contact with tissue (indirect via the gas pathway) for limited contact duration (<24 h).
# Safety and Performance Data :
To establish substantial equivalence to the identified predicate devices, tests were completed as defined below to the subject devices, Carbon Dioxide Gas Analyzer. The results of the testing demonstrate that the device complies with the requirements of the applicable standards, and the device is substantially equivalent to the predicate device.
# Non-Clinical Study:
# Electrical Safety and EMC
- ANSI AAMI ES60601-1:2005/(R)2012 and A1:2012, C1:2009/(R)2012 and A2:2010/(R)2012 (Consolidated Text) Medical electrical equipment - Part 1: General requirements for basic safety and essential performance (IEC 60601 - 1:2005, MOD)
- -IEC 60601-1-2: 2014 Medical devices part 1-2: General requirements for basic safety and essential performance - Collateral standards: electromagnetic compatibility - Test and requirements
# Performance Data:
- Bench testing for Inspired CO2 range and accuracy, and Respiration rate range and accuracy in accordance to ISO 80601-2-55 Second edition 2018-02 Medical electrical equipment - Part2-55: Particular requirements for the basic safety and essential performance of respiratory gas monitors
# Biocompatibility
- ISO 10993-5: 2009 Biological evaluation of medical devices Part 5 Tests for In Vitro -Cytotoxicity
- ISO 10993-10: 2010 Biological evaluation of medical Devices Part 10: Tests for -Irritation and Delayed-Type Hypersensitivity
- ISO 18562-1 First edition 2017-03 Biocompatibility evaluation of breathing gas pathways in healthcare applications - Part 1: Evaluation and testing within a risk management process
- ISO 18562-2 First edition 2017-03 Biocompatibility evaluation of breathing gas pathways in healthcare applications - Part 2: Tests for emissions of particulate matter
- ISO 18562-3 First edition 2017-03 Biocompatibility evaluation of breathing gas pathways in healthcare applications - Part 3: Tests for emissions of volatile organic compounds
- ISO 18562-4 First edition 2017-03 Biocompatibility evaluation of breathing gas pathways in healthcare applications - Part 4: Tests for leachables in condensate
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## Clinical Study:
- No clinical studies were performed. -
# Sterility Information:
- This device is not delivered sterile and is not sterile during operation. -
# Package and Shelf Life:
- -The CO2 Mainstream module (Capno-M, Capno-M+) is not subject to shelf life, as the device does not contain any sterile or degradable elements.
# Conclusion:
The subject device has the same intended use as the predicate device, and the technological differences are addressed by performance testing, and do not raise different questions of safety and effectiveness.
In accordance with the Federal Food, Drug and Cosmetic Act, 21 CFR Part 807, and based on the information provided in this premarket notification, the subject device, CO2 Mainstream Module, models Capno-M and Capno-M+ is substantially equivalent to predicate device
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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.