K130170 · Respiratory Motion, Inc. · BZK · May 29, 2013 · Anesthesiology
Device Facts
Record ID
K130170
Device Name
EXSPIRON 1XI
Applicant
Respiratory Motion, Inc.
Product Code
BZK · Anesthesiology
Decision Date
May 29, 2013
Decision
SESE
Submission Type
Special
Regulation
21 CFR 868.1850
Device Class
Class 2
Indications for Use
ExSpiron 1xi is indicated for use by healthcare professionals in healthcare facilities, such as post-operative care and critical care units, to monitor breathing in adult (at least 21 years old) patients. ExSpiron 1xi is a non-invasive system that graphically displays lung volume against time and reports an approximate value of: Tidal volume, Respiratory rate, and Minute ventilation. ExSpiron 1xi measurements are used as an adjunct to other clinical information sources.
Device Story
ExSpiron 1xi is a non-invasive respiratory monitor for use in clinical settings by healthcare professionals. The system utilizes thoracic bioimpedance to measure lung volume; it employs a stabilized high-frequency current generator connected to two outer electrodes on a six-electrode torso PadSet. Four inner electrodes capture voltage signals, which are conditioned by an adaptive circuit and converted to digital form. A Windows 7 PC performs signal processing, calibration, and GUI management. The device displays real-time respiratory traces, tidal volume, respiratory rate, and minute ventilation. These outputs serve as an adjunct to other clinical information, assisting providers in patient monitoring and clinical decision-making.
Clinical Evidence
No new clinical testing was performed for this 510(k). The measurement algorithm and software are unchanged from the predicate device (K120087). Performance statistics were established in the clinical trials reported in the predicate submission.
Indicated for monitoring breathing in adult patients (≥21 years) in healthcare facilities (e.g., post-operative, critical care).
Regulatory Classification
Identification
A monitoring spirometer is a device used to measure continuously a patient's tidal volume (volume of gas inhaled by the patient during each respiration cycle) or minute volume (the tidal volume multiplied by the rate of respiration for 1 minute) for the evaluation of the patient's ventilatory status.
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K130170
## 510(k) Summary ..
# MAY 2 9 2013
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| 510(k) Owner | Respiratory Motion, Inc. | | | | |
|-----------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|--|--|--|
| Address | 305 Second Avenue, Suite B | | | | |
| | Waltham, Massachusetts 02451 | | | | |
| Phone | 781-373-1636 | | | | |
| Fax | 781-373-1653 | | | | |
| Contact person | Jenny Freeman, MD | | | | |
| Date 510(k) | January 13, 2013 | | | | |
| Summary | | | | | |
| prepared | | | | | |
| Trade name | ExSpiron™ 1xi | | | | |
| Common name | Respiratory Monitor | | | | |
| Classifications | Monitoring spirometer | | | | |
| | Product code: BZK | | | | |
| | Regulation: 21 CFR 868.1850 | | | | |
| | | | | | |
| | Breathing frequency monitor | | | | |
| | Product code BZQ | | | | |
| | Regulation: 21 CFR 868.2375 | | | | |
| Predicate | ExSpiron Respiratory Monitor, cleared in 510(k) K120087. | | | | |
| devices | | | | | |
| Device | The ExSpiron 1xi system consists of: | | | | |
| Description | Bioimpedance measurement system: A stabilized high frequency current<br>generator is connected to two outer electrodes. The inner four electrodes are<br>connected to an adaptive circuit that conditions the resulting voltage signal<br>and converts it to digital form. Firmware performs signal acquisition and<br>relays data to the panel PC.<br>Computer: A Windows 7 PC performs signal processing and calibration,<br>and runs the graphical user interface (GUI). The PC takes user input from a<br>touch screen. The GUI is used for recording patient data and displaying the<br>respiratory trace as well as scalar values and trends for minute volume, tidal<br>volume, and respiratory rate.<br>Single Patient Use ExSpiron™ 1xi Electrode PadSet: An electrode<br>assembly containing six electrodes to be placed on the torso. It delivers<br>current and records impedance measurements. The electrode PadSet is also<br>used to perform subsystem checks prior to patient measurements. | | | | |
| Intended use | ExSpiron 1xi is indicated for use by healthcare professionals in healthcare facilities,<br>such as post-operative care and critical care units, to monitor breathing in adult (at<br>least 21 years old) patients.<br>ExSpiron 1xi is a non-invasive system that graphically displays lung volume against<br>time and reports an approximate value of:<br>Tidal volume,<br>●<br>Respiratory rate, and<br>Minute ventilation<br>� | | | | |
| | ExSpiron 1xi measurements are used as an adjunct to other clinical information<br>sources. | | | | |
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| Comparison of | Characteristic | ExSpiron 1xi | ExSpiron | Comment | | | |
|------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------|----------|---------------------------------|--|--|--|
| technological | Intended Use | See above | Same | The Indications for Use are not | | | |
| characteristics | | | | changed in this Special 510(k). | | | |
| | Technology | Measurement | Same | The fundamental technology is | | | |
| | | is by thoracic | | not changed | | | |
| | | bioimpedance. | | | | | |
| | Volume | Tidal volume | Same | No change | | | |
| | Measurements | | | | | | |
| | | Minute | | | | | |
| | | volume | | | | | |
| | | | | | | | |
| | | Volume vs. | | | | | |
| | | time chart | | | | | |
| | Rate | Respiratory | Same | No change | | | |
| | Measurements | rate | | | | | |
| | | (breaths/min) | | | | | |
| | Safety | IEC 60601-1, | Same | No change | | | |
| | | second edition | | | | | |
| Nonclinical | Performance testing addressed specific modifications to the Monitor, Patient Cable, | | | | | | |
| performance | and Electrode PadSet as follows: | | | | | | |
| testing: | Software Verification & Validation | | | | | | |
| | | | | | | | |
| | Safety Testing - IEC 60601-1 2nd Edition | | | | | | |
| | Electromagnetic Compatibility - IEC 60601-1-2 | | | | | | |
| | ExSpiron 1Xi System Test Plan | | | | | | |
| | | Patient Cable Design Verification - Included testing to all the relevant | | | | | |
| | sections of AAMI / ANSI EC53:1995/(R) 2008, ECG Cables and Leadwires | | | | | | |
| | Electrode PadSet Design Verification - Included testing to all the relevant | | | | | | |
| | section of AAMI / ANSI EC12:2000/(R)2010, Disposable ECG Electrodes | | | | | | |
| | & AAMI / ANSI EC53:1995/(R) 2008, ECG Cables and Leadwires | | | | | | |
| | Electrode - Biocompatibilty - ANSI/AAMI/ISO 10993-1 (Skin, prolonged | | | | | | |
| | duration) | | | | | | |
| | All performance testing conducted on modifications to the Monitor, Patient | | | | | | |
| | Cable, and Electrode Padset were completed with successful | | | | | | |
| | results. Performance testing raised no new safety or efficacy concerns and | | | | | | |
| | demonstrated substantial equivalence to the predicate device. | | | | | | |
| Clinical | No clinical testing was performed for this 510(k). The measurement algorithm and | | | | | | |
| performance | software are unchanged from the predicate. Measurement performance statistics | | | | | | |
| testing: | were determined by clinical trials reported in the predicate 510(k), K120087. | | | | | | |
| Conclusions | Based on the comparisons of intended use and on the results of testing, the ExSpiron<br>I xi is substantially equivalent in intended use, safety, and effectiveness to the | | | | | | |
| regarding safety | ExSpiron respiratory monitor. | | | | | | |
| and | | | | | | | |
| effectiveness: | | | | | | | |
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### DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/2/Picture/1 description: The image shows the logo for the Department of Health & Human Services (HHS). The logo consists of a stylized caduceus, which is a symbol often associated with healthcare. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular fashion around the caduceus.
#### Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
May 29, 2013
Jenny Freeman, M.D. President Respiratory Motion 305 Second Avenue, Suite B WALTHAM, M.A., 02451
Re: K130170
Trade/Device Name: ExSpiron™ 1xi Regulation Number: 21 CFR 868.1850 Regulation Name: Monitoring Spirometer Regulatory Class: II Product Code: BZK, BZQ Dated: April 26, 2013 Received: April 29, 2013
Dear Ms. Freeman:
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 - Ms. Freeman
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 contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. 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/ResourcesforYou/Industry/default.htm.
Sincerely yours.
Kwame O. Ulmer -S for
Anthony D. Watson, B.S., M.S., M.B.A. 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): K 130170 Device Name: ExSpiron 1xi Indications for Use:
ExSpiron 1xi is indicated for use by healthcare professionals in healthcare facilities, such as postoperative care and critical care units, to monitor breathing in adult (at least 21 years of age) patients.
ExSpiron 1xi is a non-invasive system that graphically displays lung volume against time and reports an approximate value of:
- Tidal volume, .
- . Respiratory rate, and
- Minute ventilation. *
ExSpiron 1xi measurements are used as an adjunct to other clinical information sources.
# Lester Wª 2013.05 29 10
(Division Sign-Off) Division of Anesthesiology, General Hospital Intection Control, Dental Devices
K130170 510 (k) Number:
Prescription Use × (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use (Part 21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF 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.