K100773 · Kai Medical, Inc. · BZQ · Jun 23, 2010 · Anesthesiology
Device Facts
Record ID
K100773
Device Name
KAI SPOT MODEL KMS 200
Applicant
Kai Medical, Inc.
Product Code
BZQ · Anesthesiology
Decision Date
Jun 23, 2010
Decision
SESE
Submission Type
Special
Regulation
21 CFR 868.2375
Device Class
Class 2
Indications for Use
The Kai Medical Non-Contact Respiratory Rate Spot Check Model KMS 200 is intended for a one-time measurement of respiratory rate, as part of a vital signs assessment. The device is indicated for hospital or clinical use in adult patients. The device is intended to be operated by clinicians and medically qualified personnel. It is available for sale only upon the order of a physician or licensed health care provider. The Kai Medical Non-Contact Respiratory Rate Spot Check Model KMS 200 is not intended to monitor vital signs. This device is not an apnea monitor
Device Story
Non-contact respiratory rate spot-check device; uses 2.4 GHz Doppler radar to detect chest displacement; sensor emits low-power radio-frequency signal; reflected signal phase shift converted to voltage; digitized and processed to determine respiratory rate; device features OLED touch-screen for user interface and display; mounted on medical-grade stands via VESA pattern; operated by clinicians in hospitals/clinics; provides single-point respiratory rate measurement during vital signs assessment; aids clinical decision-making by providing objective respiratory data; benefits patients by enabling non-invasive, contact-free assessment.
Clinical Evidence
Bench testing only. Data demonstrates device operates within specifications, including accuracy (±2 breaths/minute) over the 8-48 breaths/minute range. No clinical data provided.
Technological Characteristics
2.4 GHz Doppler radar sensor; 2.435-2.465 GHz frequency; <18dBm EIRP; <2MHz bandwidth; pseudo-random phase modulation; 13 dBi antenna gain. USB 2.0 connectivity. OLED touch-screen display. VESA mounting. Powered via USB (5V, <500mA).
Indications for Use
Indicated for one-time respiratory rate measurement in adult patients in hospital or clinical settings. Operated by clinicians/medically qualified personnel. Prescription use only. Not for continuous monitoring or apnea detection.
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.
Predicate Devices
Kai Medical Non-Contact Respiratory Rate Spot Check Model 100 (K090273)
Submission Summary (Full Text)
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K60773
# JUN 2 3 2010
・・
# 510(k) SUMMARY
## Kai Medical Non-Contact Respiratory Rate Spot Check Model KMS 200
# Submitter's Name, Address, Telephone Number, Contact Person and Date Prepared
Kai Medical, Inc. 3465 Waialae Aveñue, Suite 370 Honolulu, Hawaii 96816 USA
Phone: +1.808.687.2900 Facsimile: +1.808.356.0367
Contact Person: Robert Nakata
Date Prepared: March 2, 2010
## Name of Device
The Kai Medical Non-Contact Respiratory Rate Spot Check Model KMS 200 ("Kai Spot KMS 200")
# Common or Usual Name
Respiratory Rate Spot Check
## Classification Name
Breathing Frequency Monitor
## Predicate Devices
The Kai Medical Non-Contact Respiratory Rate Spot Check Model KMS 200 ("Kai Spot KMS 200") is substantially equivalent to the Kai Medical Non-Contact Respiratory Rate Spot Check Model 100 ("Kai RSpot 100", 510(k) Number: K090273).
# Device Description
The sensor includes a 2.4 GHz Doppler radar, data acquisition circuitry, processing, user interface, and touch-screen display. The touch-screen display provides the display and user interface. The device is powered over the USB connection, either by a PC, with a wall-power adapter, or with an external battery. If desired, the Kai Spot KMS 200 has the capability to communicate via its USB interface with a personal computer (PC) using select Kai Spot data
# KAI MEDICAL INC, HONOLULU, HI 96816
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management software applications. The sensor uses Doppler radar to detect respiratory effort, and the respiratory effort signal is analyzed to provide a respiratory rate. A radio wave in the 2.4 GHz ISM band is emitted from the antenna included in the hardware module. The Kai Spot KMS 200 sensor enclosure includes screw holes in a VESA mounting pattern (VESA is a standard mounting configuration), which can be used to connect to any VESA mount, including stands, carts, wall-mounts, or adapters to other stands or carts. A stand is not included with the device; the customer's Biomedical Engineering Department or maintenance service should install the device on a medical-grade stand used for vital signs measurement equipment. Screws to be used for mounting are provided with the device.
## Physical Characteristics
Dimensions of the Kai Spot KMS 200 Sensor Unit: 7.5" X 7.5" X 2" Weight of the Kai Spot KMS 200 Sensor Unit: 1.2 lb
## Performance
Detectable Respiratory rate range: 8 to 48 breaths/minute Accuracy: ±2 breaths/minute Resolution: 0.5 breath/minute Range between sensor and subject: 0.2 to 1 meter
## Operational Modes
Measurement Duration: 30, 60, 120(3b) sec 3b mode: calculates rate for 3 consecutive breaths within 2 minute period
#### Power
Power Input: USB type B Power Reguirements: USB powered (5V, < 500mA) Power Consumption: Less than 500 mA at 5V
#### Communications
USB 2.0
- Start/Stop measurement .
- Aiming light on/off .
- Respiration rate in breaths/minute .
- Retry/Error with code for type of Retry/Error .
- Sensor status feedback .
# Radio Specifications
Radio frequencies: 2.435 to 2.465 GHz Radio power (EIRP): Less than 18dBm Signal Bandwidth: Less than 2MHz Modulation: Psuedo Random Phase modulation Antenna gain: 13 dBi
#### KAI MEDICAL INC, HONOLULU, HI 96816
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# Features
Aiming Light: 8° viewing angle illuminating area of measurement
# OLED Touch Screen Displav
Diagonal Size; 2.83" Resolution: 240 x RGB x 320 Pixel Pitch: 0.060 × 0.180 mm Active Area; 43.2 x 57.6 mm Outline Area; 49.1 x 67.3 mm Thickness; 1.75 (Typ) ; 1.95 (Max) mm
#### Speaker
Impedance: 8Ω±15% Rated power: 0.75 W Maximum power: 1.10 W Resonant frequency: 620 ±20% Hz Frequency range: 240 Hz - 20KHz
# Intended Use / Indications for Use
The Kai Medical Non-Contact Respiratory Rate Spot Check Model KMS 200 is intended for a one-time measurement of respiratory rate, as part of a vital signs assessment. The device is indicated for hospital or clinical use in adult patients. The device is intended to be operated by clinicians and medically qualified personnel. It is available for sale only upon the order of a physician or licensed health care provider.
The Kai Medical Non-Contact Respiratory Rate Spot Check Model KMS 200 is not intended to monitor vital signs. This device is not an apnea monitor
#### Technological Characteristics
The The Kai Spot KMS 200 is a reusable sensor for measuring respiratory rate during vital sign assessments. The Kai Spot KMS 200 uses a low-power radar to sense chest displacement in order to obtain a respiratory rate. When the Kai Spot KMS 200 is operating and facing a patient, the Doppler radar transmits a low-power radio-frequency signal and receives the signal after it has reflected off the patient's torso. The receiver detects a phase shift on the signal due to chest displacement and converts this phase shift into a voltage that is digitized and processed with software, which determines a respiratory rate from the chest motion (respiratory effort) signal. A touch-screen provides the display and user interface for the device. The Kai Spot KMS 200 may communicate over USB with a personal computer (PC) using select Kai Spot data management software applications. The Kai Spot KMS 200 may operate on wall power, USB power from a PC, or power from an external battery.
## KAI MEDICAL INC, HONOLULU, HI 96816
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# Performance Data
The bench performance data demonstrates that the Kai Spot KMS 200 is as safe and effective as the Kai RSpot 100. Bench performance data further demonstrates that the Kai Spot KMS 200 operates within its specifications, including accuracy over the range of measured respiratory rates.
Because the Kai Spot KMS 200 does not contact the patient, there is no risk of inadvertent exposure to electric current, and there are no patient-contacting materials that could cause allergic reactions or skin sensitivity. The radio signals emitted by the Kai Spot KMS 200 are at a power well below that emitted by many consumer wireless devices and many medical devices.
#### Substantial Equivalence
The Kai Spot KMS 200 has the same intended use, indications, and principles of operation as its predicate device, the Kai RSpot 100, and similar technological characteristics. The minor technological differences between the Kai Spot KMS 200 and its predicate device raise no new issues of safety or effectiveness. Performance data demonstrates that the Kai Spot KMS 200 is as safe and effective as the Kai RSpot 100. Thus, the Kai Spot KMS 200 is substantially equivalent.
#### KAI MEDICAL INC, HONOLULU, HI 96816
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# DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
Mr. Robert Nakata Chief Technology Officer Kai Sensors, Incorporated 3465 Waialae Avenue, Suite 370 Honolulu, Hawaii 96816
JUN 2 8 2010
Re: K100773
Trade/Device Name: The Kai Sensors Non-Contact Respiratory Rate Spot Check Model 200 Regulation Number: 21 CFR 868.1400 Regulation Name: Carbon Dioxide Gas Analyzer Regulatory Class: II Product Code: CCK Dated: May 20, 2010 Received: May 24, 2010
Dear Mr. Nakata:
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.
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Page 2- Mr. Nakata
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 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to
http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours
Susan Tunnes
Anthony D. Watson, B.S., M.S., M.B.A. Director
Division of Anesthesiology, General Hospital, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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#### Indications for Use Statement
510(k) Number (if known): K090273
Device Name: The Kai Sensors Non-Contact Respiratory Rate Spot Check Model 200
Indications for Use:
The Kai Sensors Non-Contact Respiratory Rate Spot Check Model 200 is intended for a onetime measurement of respiratory rate as part of a vital signs assessment. The device is indicated for hospital or clinical use in adult patients. The device is intended to be operated by clinicians and medically qualified personnel. It is available for sale only upon the order of a physician or licensed health care provider.
The Kai Sensors Non-Contact Respiratory Rate Spot Check Model 200 is not intended to monitor vital signs. This device is not an apnea monitor
enter
L. Schultheis
(Division Sign-Off) Division of Anesthesiology, General Hospital Infection Control, Dental Devices
510(k) Number: k/00773
Prescription Use X (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
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.