The PRO2 Elite Plus Oxygen Analyzer is intended as a tool to be used by qualified personnel to spot-check oxygen concentration, flow, and pressure of a delivered air/oxygen mixture of an oxygen concentrator. The Oxygen Analyzer is intended to be used in an environment where oxygen concentrators are being serviced or repaired. This includes hospitals, nursing homes, extended care facilities, patient homes, and respiratory device service and repair centers. The Oxygen Analyzer is not intended for use in continuous monitoring of oxygen delivery to patients.
Device Story
Handheld, battery-powered ultrasonic analyzer; measures oxygen concentration (%), flow (LPM), and pressure (kPa/PSI) of oxygen concentrator output. Device connects to concentrator output port via tube; uses ultrasonic time-of-flight technology to analyze gas transit time and signal differentials; internal pressure sensor measures gas pressure. Operated by service technicians/respiratory therapists in hospitals, clinics, or homes during routine maintenance. User views measurements on LCD screen; device does not store data. Calibration verified via pure oxygen source mode. Provides objective performance data to technicians to ensure concentrator functionality; benefits patients by ensuring accurate oxygen delivery equipment maintenance.
Clinical Evidence
Bench testing only. Device performance verified against consensus standards including ISO 80601-2-55 (respiratory gas monitors), IEC 60601-1 (safety), and IEC 60601-1-11 (home healthcare). Testing confirmed accuracy for oxygen concentration (±1.5% full scale), flow (±0.2 LPM), and pressure (±0.5%). Comparative performance evaluation against predicate confirmed equivalent or improved response times (≤10s vs ≤17s).
Technological Characteristics
Ultrasonic time-of-flight sensing; piezo-electric transducers; piezoresistive silicon pressure sensor. Powered by 2x AA alkaline batteries. Dimensions: 64.9mm x 144.5mm x 22.5mm. Weight: 125g. Interface: LCD with button controls. Connectivity: None (standalone). Ingress protection: IP22. Firmware-controlled microprocessor. Complies with ISO 80601-2-55, IEC 60601-1, IEC 60601-1-11, and IEC 62304.
Indications for Use
Indicated for use by qualified personnel (service technicians, biomedical equipment technicians, respiratory therapists) to spot-check oxygen concentration, flow, and pressure of oxygen concentrator output during maintenance or repair in clinical and home environments. Not for continuous patient monitoring.
Regulatory Classification
Identification
An oxygen gas analyzer is a device intended to measure the concentration of oxygen in respiratory gases by techniques such as mass spectrometry, polarography, thermal conductivity, or gas chromatography. This generic type of device also includes paramagnetic analyzers.
{0}
FDA U.S. FOOD & DRUG
ADMINISTRATION
July 30, 2026
Salter Labs
% Tanja-Maria Ranta
Advisor, Regulatory Management
Airlife Finland OY
Kuortaneenkatu 2
Helsinki, Uusimaa 00510
Finland
Re: K261389
Trade/Device Name: PRO2 Elite Plus Oxygen Analyzer (PRO2PLUS-1)
Regulation Number: 21 CFR 868.1720
Regulation Name: Oxygen Gas Analyzer
Regulatory Class: Class II
Product Code: CCL
Dated: July 6, 2026
Received: July 6, 2026
Dear Tanja-Maria Ranta:
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 (the 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 available 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.
U.S. Food & Drug Administration
10903 New Hampshire Avenue
Silver Spring, MD 20993
www.fda.gov
{1}
K261389 - Tanja-Maria Ranta
Page 2
Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).
Your device is also subject to, among other requirements, the Quality Management System Regulation (QMSR) (21 CFR Part 820), which includes, but is not limited to, ISO 13485 clause 7.3 (Design controls), ISO 13485 clause 8.3 (Nonconforming product), ISO 13485 clause 8.5.2 (Corrective action), and ISO 13485 clause 8.5.3 (Preventative action). Please note that regardless of whether a change requires premarket review, the QMSR requires device manufacturers to review and approve changes to device design and production (ISO 13485 clause 7.3 and ISO 13485 clause 7.5) and document changes and approvals in the Medical Device File (ISO 13485 clause 4.2.3).
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR Part 803) for devices or postmarketing safety reporting (21 CFR Part 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reporting-combination-products); good manufacturing practice requirements as set forth in the Quality Management System Regulation (QMSR) (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.
All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rule"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-devices/device-advice-comprehensive-regulatory-assistance/unique-device-identification-system-udi-system.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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-devices/medical-device-safety/medical-device-reporting-mdr-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/medical-devices/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.
{2}
K261389 - Tanja-Maria Ranta
Page 3
See the DICE website (https://www.fda.gov/medical-devices/device-advice-comprehensive-regulatory-assistance/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,
Bradley Q. Quinn -S
Bradley Quinn
Assistant Director
DHT1C: Division of Anesthesia,
Respiratory, and Sleep Devices
OHT1: Office of Ophthalmic, Anesthesia,
Respiratory, ENT, and Dental Devices
Office of Product Evaluation and Quality
Center for Devices and Radiological Health
Enclosure
{3}
| Indications for Use | | |
| --- | --- | --- |
| Please type in the marketing application/submission number, if it is known. This textbox will be left blank for original applications/submissions. | K261389 | ? |
| Please provide the device trade name(s). | | ? |
| PRO2 Elite Plus Oxygen Analyzer (PRO2PLUS-1) | | |
| Please provide your Indications for Use below. | | ? |
| The PRO2 Elite Plus Oxygen Analyzer is intended as a tool to be used by qualified personnel to spot-check oxygen concentration, flow, and pressure of a delivered air/oxygen mixture of an oxygen concentrator. The Oxygen Analyzer is intended to be used in an environment where oxygen concentrators are being serviced or repaired. This includes hospitals, nursing homes, extended care facilities, patient homes, and respiratory device service and repair centers. The Oxygen Analyzer is not intended for use in continuous monitoring of oxygen delivery to patients. | | |
| Please select the types of uses (select one or both, as applicable). | ☑ Prescription Use (21 CFR 801 Subpart D) ☐ Over-The-Counter Use (21 CFR 801 Subpart C) | ? |
| Please select the age group(s) for which the device(s) is to be used. | ☐ Neonates/Newborns (Birth to < 29 days old) ☐ Infants (29 days old to < 2 years old) ☐ Children (2 years old to < 12 years old) ☐ Adolescents (12 years old to < 22 years old) ☐ Adults (22 years old and greater) | ? |
{4}
AirLife
# Attachment 10.2 510(k) Summary
# Contents
I. Manufacturer: Salter Labs... 2
II. Subject Device... 2
III. Predicate Device... 2
IV. Device Description... 2
V. Indications for use... 3
VI. Equivalence Comparison to the Predicate Device... 3
VII. Performance test... 3
VIII. Conclusion... 4
IX. Annex A - Comparison to the Predicate Device... 5
1
Toll Free 800.433.2797
T 616.259.8400
F 616.647.3430
www.myAirLife.com
2710 Northridge Dr NW, Ste. A
Grand Rapids, MI 49544
{5}
AirLife
# 510 (K) Summary
Initial Submission
Date of Submission prepared: 27 April 2026
# I. Manufacturer: Salter Labs
Address: 30 Spur Drive, El Paso, TX 79906, United States
Telephone: 01-616-2598373
Email: ryamashita@myairlife.com
Official Contact: Robert Yamashita / VP of Regulatory Affairs
FDA Establishment Registration Number: 3004748541
# II. Subject Device
| **Trade name:** | PRO2 Elite Plus Oxygen Analyzer |
| --- | --- |
| **Model:** | Pro2PLUS-1 |
| **Regulation Number:** | 21 CFR 868.1720 Oxygen gas analyzer |
| **Product Code:** | CCL - Analyzer, Gas, Oxygen, Gaseous-Phase |
| **Medical Specialty:** | Anesthesiology |
| **Regulatory Class:** | Class II |
# III. Predicate Device
| **Trade name:** | UltraMax O2 Oxygen Analyzer |
| --- | --- |
| **510 (k) Number** | K112402 |
| **Regulation Number:** | 21 CFR 868.1720 Oxygen gas analyzer |
| **Product Code:** | CCL - Analyzer, Gas, Oxygen, Gaseous-Phase |
| **Medical Specialty:** | Anesthesiology |
| **Regulatory Class:** | Class II |
# IV. Device Description
The PRO2 Elite PLUS™ Oxygen Analyzer is intended for spot-checking oxygen concentration, flow, and pressure of a delivered air/oxygen mixture of an oxygen concentrator. It is not intended for continuous monitoring of oxygen delivery to patients.
The PRO2 Elite PLUS™ Oxygen Analyzer is a micro-processor controlled handheld device designed for testing the functionality of an oxygen concentrator, for example during routine maintenance. It is connected to the output port of the oxygen concentrator via a connection tube. After the concentrator's output stabilizes, the oxygen analyzer is turned on. It can measure the enriched gas's oxygen concentration (%), flow (LPM), and pressure (kPa or PSI). The measured parameters are displayed on the device's screen. The device does not store the
2
Toll Free 800.433.2797
T 616.259.8400
F 616.647.3430
www.myAirLife.com
2710 Northridge Dr NW, Ste. A
Grand Rapids, MI 49544
{6}
AirLife
values. The analyzer can be changed from oxygen concentration and flow mode to pressure measurement mode by sliding the switch on the side of the device.
To verify the calibration of the subject device's oxygen/flow sensor, it can be connected to a pure oxygen (100%) source. Using the source button, the user can set the device to "pure O2" mode and compare the reading to the known content of the bottle.
## V. Indications for use
The PRO2 Elite Plus™ Oxygen Analyzer is intended as a tool to be used by qualified personnel to spot-check oxygen concentration, flow, and pressure of a delivered air/oxygen mixture of an oxygen concentrator. The Oxygen Analyzer is intended to be used in an environment where oxygen concentrators are being serviced or repaired. This includes hospitals, nursing homes, extended care facilities, patient homes, and respiratory device service and repair centers. The Oxygen Analyzer is not intended for use in continuous monitoring of oxygen delivery to patients.
## VI. Equivalence Comparison to the Predicate Device
See Tables 1 and 2 in Annex A below for detailed comparison.
## VII. Performance test
PRO2 Elite PLUS™ Oxygen Analyzer complies with the following consensus standards:
- ISO 80601-2-55 Second edition 2018-02 [Including AMD1:2023] [FR Recognition No. 1-184]
Medical electrical equipment - Part 2-55: Particular requirements for the basic safety and essential performance of respiratory gas monitor [Including Amendment 1 (2023)].
- ANSI AAMI ISO 14971: 2019 [FR Recognition No. 5-125]
Medical devices - Application of risk management to medical devices
- IEC 60601-1 Edition 3.2 2020-08 CONSOLIDATED VERSION [FR Recognition No. 19-49]
Medical electrical equipment - Part 1: General requirements for basic safety and essential performance
- ANSI AAMI IEC 60601-1-2:2014 [Including AMD 1:2021] [FR Recognition No. 19-36]
Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances - Requirements and tests [Including Amendment 1 (2021)]
- IEC 60601-1-11 Edition 2.1 2020-07 CONSOLIDATED VERSION [FR Recognition No. 19-38]
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
- ANSI AAMI IEC 62304:2006/A1:2016 [FR Recognition No. 13-79]
Medical device software - Software life cycle processes [Including Amendment 1 (2016)]
- IEC 60601-1-6 Edition 3.2 2020-07 CONSOLIDATED VERSION [FR Recognition No. 5-132]
Medical electrical equipment - Part 1-6: General requirements for basic safety and essential performance - Collateral standard: Usability
- IEC 62366-1 Edition 1.1 2020-06 CONSOLIDATED VERSION [FR Recognition No. 5-129]
Medical devices - Part 1: Application of usability engineering to medical devices
3
Toll Free 800.433.2797
T 616.259.8400
F 616.647.3430
www.myAirLife.com
2710 Northridge Dr NW, Ste. A
Grand Rapids, MI 49544
{7}
AirLife
### VIII. Conclusion
The subject device (PRO2 Elite PLUS™ Oxygen Analyzer Model: PRO2PLUS-1) and the predicate (UltraMaxO2 Oxygen Analyzer) are handheld, battery-powered ultrasonic oxygen analyzers. Both devices are intended to be used in an environment where oxygen concentrators are being serviced or repaired.
Both Devices:
- Have the same intended use, same fundamental measurement technology and same measurement capabilities.
- Use ultrasonic time-of-flight measurement as technology for O2 measurements.
- Measure oxygen concentration by analyzing transit time of ultrasonic pulses.
- Measure flow using upstream/downstream ultrasonic signal differentials.
- Measure pressure via an internal pressure sensing mechanism.
- Display measured values on an LCD interface.
- Atmospheric Pressure and Humidity are similar. The Subject device operating pressure range is slightly wider than predicate device to be compliant with the requirements of ANSI/AAMI HA60601-1-11.
- Flow measurement ranges are similar. Subject device has a minimum measurement capability of 0.5 LPM. Although the subject device has a different flow range compared to the predicate device, the flow range for the subject device is within the cleared range of the predicate.
Both devices consist of piezo-electric ultrasonic transducers, injection molded structural components, and common PCBA materials / integrated circuit components. The control mechanism on both devices is a firmware controlled microprocessor. The subject device and the predicate device have minor technical and operational differences. The subject device (PRO2 Elite PLUS™ Oxygen Analyzer Model: PRO2PLUS-1) performs as well or better than the predicate device (UltraMaxO2 Oxygen Analyzer). Based on comparisons of technical and safety features, and comparative performance evaluations, the proposed PRO2 Elite PLUS™ Oxygen Analyzer device is substantially equivalent to the predicate UltraMaxO2 Oxygen Analyzer.
4
Toll Free 800.433.2797
T 616.259.8400
F 616.647.3430
www.myAirLife.com
2710 Northridge Dr NW, Ste. A
Grand Rapids, MI 49544
{8}
AirLife™
## IX. Annex A - Comparison to the Predicate Device
TABLE 1: MAIN ATTRIBUTES COMPARISON OF SUBJECT DEVICE PRO₂ ELITE PLUS™ VERSUS PREDICATE DEVICE ULTRAMAXO2
| Attributes | PRO₂ Elite PLUS™ Oxygen Analyzer Model: PRO2PLUS-1 | UltraMaxO₂ Oxygen Analyzer K112402 | Remarks |
| --- | --- | --- | --- |
| Intended Use | The PRO2 Elite Plus Oxygen Analyzer is intended as a tool to be used by qualified personnel to spot-check oxygen concentration, flow, and pressure of a delivered air/oxygen mixture of an oxygen concentrator. | The UltraMaxO₂ Oxygen Analyzer is a tool used to measure oxygen purity, flow and pressure at the outlet of an oxygen concentrator. | The intended uses are materially the same. Indications for use are materially the same. |
| Indications for Use | The Oxygen Analyzer is intended to be used in an environment where oxygen concentrators are being serviced or repaired. The Oxygen Analyzer is not intended for use in continuous monitoring of oxygen delivery to patients. | The UltraMaxO₂ Oxygen Analyzer is intended to be used in an environment where oxygen concentrators are being serviced or repaired. This includes hospitals, nursing homes, extended care facilities, patient homes, and respiratory device service and repair centers. | |
| Principle of Operation | The O₂ analyzer detects oxygen concentration and flow rate using ultrasonic transducers. The pressure is measured using a pressure sensor. | The UltraMax O2 Oxygen Analyzer measures oxygen concentration and flow using ultrasound technology and measures pressure using a piezoresistive silicon pressure sensor. | Same |
| Intended User | Service technician Delivery technician Biomedical equipment technician Respiratory therapist | Professional use | The professional intended users are materially the same. |
| Intended Use Environment | Hospitals, nursing homes, extended care facilities, patient homes, and respiratory device service and repair centers. | Hospitals, nursing homes, extended care facilities, patient homes, and respiratory device service and repair centers. | The environments where the professional users operate are materially the same. |
| Atmospheric Pressure | 70 to 106 kPa (700 - 1060 mbar hPa) | 80-100 kPa 800 - 1000 mbar (hPa) | Similar. The Subject device operating pressure range is slightly wider than that of predicate device to comply with the requirements of ANSI/AAMI HA60601-1-11 subclause 4.2.3.1. |
| Humidity | 5-90% non-condensing | 0-95% non-condensing | Similar. The subject device has a slightly narrower range for relative humidity than the predicate. The range for proposed device complies with requirements of ANSI/AAMI HA60601-1-11 subclause 4.2.3.1. |
| Electrical Requirements | 2 x AA Alkaline batteries (2 x 1.5 Volts) | 2 x AA Alkaline batteries (2 x 1.5 Volts) | Identical. |
| Operating Temperature Range | 15°C - 40°C (59°F-104°F) | 15°C - 40°C (59°F-104°F) | Identical. |
| Storage Temperature Range | -15°C - 60°C (5°F-140°F) | -15°C - 60°C (5°F-140°F) | Identical. |
Toll Free 800.433.2797
T 616.259.8400
F 616.647.3430
www.myAirLife.com
2710 Northridge Dr NW, Ste. A
Grand Rapids, MI 49544
{9}
AirLife
| Attributes | PRO₂ Elite PLUS™ Oxygen Analyzer Model: PRO2PLUS-1 | UltraMaxO₂ Oxygen Analyzer K112402 | Remarks |
| --- | --- | --- | --- |
| Mode of Operation | Continuous | Continuous | Identical. |
| Electrical Classification: | Internally powered Medical Electrical equipment | Internally powered Medical Electrical equipment | Identical. |
| Protection against water | IP22 | IPX1 | Similar. Subject device was tested to more challenging ingress protection (IP) requirements for residential environments per ANSI/AAMI HA60601-1-11 Clause 8.3.1. |
| Measurement Capability - Oxygen Measurement Range | 20.9- 96% | 20.9- 96% | Identical. |
| Oxygen Measurement Resolution | 0.1% Oxygen | 0.1% Oxygen | Identical. |
| Oxygen Measurement Accuracy | ± 1.5% Full Scale (at constant temp. & optimal flow) | ±-1.5% Full Scale (at constant temp. & optimal flow) | Identical. |
| Measurement Capability - Flow Measurement Range | 0.5 - 10 LPM | 0 - 10 LPM | Similar. Subject device has a minimum measurement capability of 0.5 LPM. Although the subject device has a slightly different flow range, the flow range is within the cleared range of the predicate. |
| Flow Measurement Resolution | 0.1 LPM | 0.1 LPM | Identical. |
| Flow Measurement Accuracy | ±0.2 LPM | ±0.2 LPM | Identical. |
| Measurement Capability - Pressure Measurement Range | 0.5 - 50 (PSI), 3.4 - 344 (kPa) | 0.5 - 50 (PSI), 3.4 - 344 (kPa) | Identical. |
| Pressure Measurement Resolution | 0.1 (PSI), 0.1 up to 199, 1 from 200 to 344 (kPa) | 0.1 (PSI), 0.1 up to 199, 1 from 200 to 344 (kPa) | Identical. |
| Pressure Measurement Accuracy | ±0.5% (PSI), ±0.5% (kPa) | ±0.5% (PSI), ±0.5% (kPa) | Identical. |
| Response Time: | ≤10 seconds | ≤17 seconds | Similar. The subject device has an improved response time compared to the predicate. |
| Warm-up Time: | < 1 second | < 1 second | Identical. |
| Low Battery Indication: | Low battery icon displayed on graphics screen | Low battery icon displayed on graphics screen | Identical. |
| Battery life | ≥ 1,100 hours (16,500 read cycles) | ≥ 1,100 hours (16,500 read cycles) | Identical. |
Toll Free 800.433.2797
www.myAirLife.com
T 616.259.8400
2710 Northridge Dr NW, Ste. A
F 616.647.3430
Grand Rapids, MI 49544
{10}
AirLife™
| Attributes | PRO₂ Elite PLUS™ Oxygen Analyzer Model: PRO2PLUS-1 | UltraMaxO₂ Oxygen Analyzer K112402 | Remarks |
| --- | --- | --- | --- |
| Sensor Type | Ultrasonic | Ultrasonic | Same |
| Sensor Life | Device lifetime | Device lifetime | Identical. |
| Drift of Measurement: | Within accuracy specifications. No need for field calibration. | Within accuracy specifications. No need for field calibration. | Identical. |
| Alarms | None | None | Identical. |
TABLE 2: COMPARISON OF OTHER SPECIFICATIONS FOR SUBJECT DEVICE PRO₂ ELITE PLUS™ VERSUS PREDICATE DEVICE ULTRAMAXO2
| Attributes | PRO₂ Elite PLUS™ Oxygen Analyzer Model: PRO2PLUS-1 | Predicate: UltraMaxO₂ Oxygen Analyzer K112402 | Remarks |
| --- | --- | --- | --- |
| Interface | Two buttons: On\Off and Source. Pressure channel switch | Two buttons: On\Off and Mode. Pressure channel switch | Similar. |
| Controls | ON/OFF button O₂ Source button Mode switch (Oxygen & Flow mode or pressure mode) Pressure unit button | ON/OFF button Mode button Gas sample outlet (blocking it with finger triggers pressure measurement) Pressure unit switch | Similar. The subject and predicate device have the same primary features. The subject device has a different means for switching between modes. |
| Display | PSI indicator Kpa Indicator Lpm indicator % indicator Low battery symbol 3 digits and 1 decimal 2 digits and 1 decimal O₂ concentrator indicator Pure oxygen indicator | PSI indicator Kpa Indicator Lpm indicator % indicator Low battery symbol 3 digits and 1 decimal 2 digits and 1 decimal | Similar. The subject device's display includes the same fields/icons as the predicate device. The subject device integrates two additional icons for indicating which mode is active to the user. |
| Battery cover | Battery cover locked in place with a spring-loaded lever. No tool needed for removing battery cover. | Battery cover locked in place using a small screw. Tool/screwdriver needed for removing battery cover. | Similar. The subject device does not require a tool for removing the battery cover/changing the batteries. ESD testing per ISO 60601-1-2 was performed to subject device with battery cover removed. |
| Weight | 125 g (without batteries) | 181 g | When accounting for the weight of the batteries, the weights of the devices are very similar and suitable for the user population. |
| Dimensions | 64.9 mm x 144.5 mm x 22.5 mm | 80.3 mm x 129.5 mm x 26.5 mm | Sizes are similar and suitable for use in the use environment. |
| EMC Emissions Compliance | Group 1 Class B | Group 1 Class A | Different. The subject device was tested to a more challenging CISPR 11 Class B requirements for residential environments per ANSI/AAMI HA 60601-1-11 Clause 12. |
Toll Free 800.433.2797
www.myAirLife.com
T 616.259.8400
2710 Northridge Dr NW, Ste. A
F 616.647.3430
Grand Rapids, MI 49544
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.