The SpiroPro is a portable, battery operated device and can be used by physicians in the office or hospital, in occupational medicine or by patients in the home. The SpiroPro measures inspiratory and expiratory lung function parameters in adults and children 4 years and older. In addition to the pulmonary function measurements, oxygen saturation and heart rate can be recorded.
Device Story
SpiroPro is a portable, battery-operated diagnostic system for measuring/recording lung function (Flow-Volume curves, VCin, FVC, FEV1, MEF50) and optional SpO2/pulse rate. Input via pneumotachograph and pulse oximetry sensor; data processed by internal microcontroller; output via LCD touch screen, printer, or data transfer to PC via serial/Bluetooth interface. Used by physicians or patients in clinics, hospitals, or homes. Interpretation program automatically assesses measured data; results guide clinical decision-making for pulmonary assessment. Benefits include portable monitoring and automated data analysis.
Clinical Evidence
Bench testing only. Includes biocompatibility testing per ISO 10993-1 for new mouthpiece material, validation of pneumotach disinfection using Cidex OPA, EMC testing per EN 60601-1-2, and FMEA risk analysis for Bluetooth integration. No clinical data presented.
Technological Characteristics
Portable spirometer/oximeter. Materials: Bormed GR 835 MO (mouthpiece), Rotec ABS 1001FR V0 (housing/pneumotach). Sensing: Pneumotachograph (pressure-to-flow), dual-wavelength pulse oximetry. Connectivity: Serial interface and Bluetooth (Mitsumi WML-C46). Power: 3.7V Li-ion battery. Display: LCD touch screen. Software: Interpretation program for lung function assessment. Sterilization: Reusable pneumotach validated for high-level disinfection (Cidex OPA).
Indications for Use
Indicated for adults and children 4 years and older for measurement of inspiratory and expiratory lung function parameters, oxygen saturation, and heart rate. Used by physicians in office/hospital/occupational medicine or by patients in home settings.
Regulatory Classification
Identification
An oximeter is a device used to transmit radiation at a known wavelength(s) through blood and to measure the blood oxygen saturation based on the amount of reflected or scattered radiation. It may be used alone or in conjunction with a fiberoptic oximeter catheter.
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K092324
# 510(k) Summary
SEP - 3 2009
# GENERAL INFORMATION
# 5.1 Type of Submission
Special 510(k) Submission
07/17/2009 Submission date:
#### 5.2 Submitter
Name:
Cardinal Health Germany 234 GmbH
Address:
Leibnizstrasse 7 D-97204 Hoechberg Germany
# Contact person in Germany:
| | Thomas Rust |
|----------|----------------------------------------------------------------------------------|
| Address: | Cardinal Health Germany 234 GmbH<br>Leibnizstrasse 7, 97204 Hoechberg<br>Germany |
| Phone: | +49 931 49 72 - 383 |
| FAX: | +49 931 49 72 - 62383 |
| E-mail | Thomas.Rust@cardinalhealth.com |
# Contact person in the U.S. (Official Correspondent)
Cardinal Health 207 INC Address 22745 Savi Ranch Parkway Yorba Linda, CA 92887 714-283-8472 Phone/Fax: Thomas Gutierrez@cardinalhealth.com E-mail
Thomas Gutierrez
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- Establishment Registration Number 5.3 ... 9615102
- 5.4 Common Name or Classification Name Oxymeter (CFR 870.2700, Product Code DQA) Predicted pulmonary-function value calculator (CFR 868.1890, Product Code BTY)
- Trade Name
SpiroPro
#### Device Classification 5.6
This is a Class II device
# Classification Panel
73 Anesthesiology Part 870 Code DQA and Part 868 Code BTY
#### Reason for Premarket Notification 5.8
Device modification to an existing Cardinal Health - device regarding "The New 510(k) Paradigm"
-- Additional data transfer to computer by blue tooth --
#### Legally predicate marketed device 5.9
- SpiroPro SpO2
- K031515 / Code DQA, BTY
- AM1+ / AM1+ BT
- K090486 / Code BZG
#### Predicate Device Company 5.10
Cardinal Health Germany 234 GmbH
#### Device Description 5.11
SpiroPro® is a recording and diagnostic system for measurement, recording and assessment of the Flow-Volume curve and Flow-Volume parameters. The analyzed data can be immediately printed out or saved to the internal memory.
The portable spirometer is small, easy to handle and allows determination of inspiratory and expiratory lung volumes (VCin, FVC, FEV1, MEF50, ... ) including pre and post measurement with date and time display. An interpretation program automatically assesses the measured data. Optionally, the measurement of the oxygen saturation of the blood (SpO2) and the pulse rate are available and a 6-minute walk test can be performed. The graphic LCD and the menu-guided graphical user interface comply with
the latest technological developments. Just touch the appropriate icon with your finger to enter patient data or to select menu items (touch screen). Selfexplanatory icons and the logical menu structure safely guide you through the procedure Storage capacity is high: up to 550 measurements can be saved in the internal database.
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The rechargeable lithium-ion battery allows operation of the SpiroPro® for approximately two weeks. A charging unit, able to charge the battery within two hours, is included in the delivery.
Patient data, recording results and graphs can be directly printed out on a PCL-compatible printer (for example HP DeskJet series). Of course, data transfer to a PC and vice versa is possible via the serial interface and the Bluetooth interface. The optional software package "SpiroPro® for Windows®" allows automatic transfer of data which are then saved on the PC. The easy-to-exchange, high-quality pneumotach guarantees a high degree of patient safety and provides precise recording results.
#### 5.12 Intended Use Statement
The SpiroPro is a portable, battery operated device and can be used by physicians in the office or hospital, in occupational medicine or by patients in the home. The SpiroPro measures inspiratory and expiratory lung function parameters in adults and children 4 vears and older. In addition to the pulmonary function measurements, oxygen saturation and heart rate can be recorded.
#### Required Components 5.13
SpiroPro (with Nonin Xpod Patient Cable Oximeter) Nonin Finger Clip Sensor Pneumotachograph set Plastic Disposable Mouthpiece Nose clip . . . . Lithium-ion battery 3,7V; rechargeable Charging unit Printer cable Printer adapter User Manual SpiroPro for Windows Software (option)
#### Summary Table of Comparison 5.14
| | SpiroPro SpO2<br>(K031515) | SpiroPro<br>with Bluetooth |
|------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------|
| Indications<br>for Use | The SpiroPro is a portable, battery<br>operated device and can be used by<br>physicians in the office or hospital, in<br>occupational medicine or by patients<br>in the home. The SpiroPro measures<br>inspiratory and expiratory lung<br>function parameters in adults and<br>children 4 years and older. In addition<br>to the pulmonary function.<br>measurements, oxygen saturation and<br>heart rate can be recorded. | identical |
# a) Comparison with SpiroPro SpO2 with 510(k) K031515
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.
1
| Fundamental<br>scientific<br>Technology | Spirometer:<br>Pneumotachograph, pressure to<br>flow conversion technique<br>Oximeter:<br>Conventional dual wavelength pulse<br>technique | identical |
|-----------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------|
| Accessories | Pneumotachograph set Finger clip sensor Nose clip | identical |
| Patient<br>contacting<br>parts | Finger clip sensor Nose clip pad | identical |
| Housing<br>material | Single use mouthpiece<br>(material: Hostalen GD 6250) | Single use mouthpiece<br>(material: Bormed RG835 MO) |
| Housing<br>material | Rotec ABS 1001FR V0 | identical |
| Pneumotach<br>material | Rotec ABS 1001FR V0 | identical |
| Disinfection | Mouthpiece<br>(single patient use) | identical |
| | Pneumotach<br>(single patient use) | Identical<br>(but is validated for disinfection) |
| Display /<br>Key-panel | LCD touch screen<br>120*64 dots / 3*4 touch | Successor model |
| Micro-<br>controller | Micro-controller<br>with internal memory | Successor model |
| Interface | RS232 Interface | identical |
| Energy type | 1 x 3,7V Lithium-ion battery | identical |
| Off-the-Shelf<br>Software | Option | identical |
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| ATS conformity<br>(criteria) | ATS 1994 | ATS 1994 and ATS-ERS 2005 |
|------------------------------|----------|---------------------------|
|------------------------------|----------|---------------------------|
### Discussion to the table above:
The insignificant differences to the SpiroPro SpO2 are found as:
- . Single use Mouthpiece - The material for the single use mouthpiece has changed from Hostalen GD 6250 to Bormed GR 835 MO. For the material Bormed GR 835 MO a biocompatibility test according ISO 10993-1 was successful accomplished.
- · Pneumotach The pneumotach for the SpiroPro now is reusable and has been validated for disinfection with an FDA approved disinfectant. The high level disinfectant for semi-critcal devices "Cidex OPA Solution" with 510(k) K030004 can be used.
- ATS criteria For evaluation of the measurement now the ATS criteria . according ATS 2005 can be selected in the setting menu beside the ATS 1994 criteria. This means, the result can also be shown on the screen of the SpiroPro according the ATS 2005 criteria.
- Micro-controller has been replaced by a successor model due to the fact . that the previous Micro-controller will be not manufactured anymore. Successor model: Micro-controller MB96 F 346 / 16 bit
- LCD-Display has been replaced by a successor model due to the fact that . the previous LCD display will be not manufactured anymore. Successor model: LCD module type - JCG12064A02-02
- b) Comparison with AM1+ / AM1+ BT with 510(k) K090486
| | AM1+ / AM1+ BT<br>(K090486) | SpiroPro<br>with Bluetooth |
|-----------|-----------------------------|----------------------------|
| Interface | RS232 Interface & Bluetooth | identical |
### Discussion to the table above:
The similarities to the AM1+ / AM1+ BT are found as:
- Bluetooth is used for data transfer to the computer as an additional . possibility besides the serial interface communication. The Bluetooth module for the SpiroPro device is identical to the Bluetooth module in the AM1+ / AM1+ BT. Both devices work with the Bluetooth module Mitsumi WML-C46.
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#### Summary of Device Testing 5.15
The following practices were followed and monitored for development of the SpiroPro with the Bluetooth data transmission:
- The Bluetooth data transmission for the above device was developed in . accordance with the Cardinal Health development standard operating procedures (000490 06 - Design Control).
- The risk analysis method used to assess the impact of SpiroPro with . the additional Bluetooth data transmission was a Failure Modes and Effects Analysis (FMEA).
- Safety test procedures demonstrate satisfaction of all safety . requirements and mitigation of all identified hazards.
- The EMC testing was performed according EN 60601-1-2. .
#### 5.16 Conclusions
Based on the above, Cardinal Health Germany 234 GmbH concludes that the SpiroPro is substantially equivalent to legally marketed predicate devices and is safe and effective for its intended use, and performs at least as well as the predicate devices.
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Image /page/6/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized eagle with three legs and a circular border. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged around the border of the logo.
Food and Drug Administration 10903 New Hampshire Avenue Document Mail Center - WO66-G609 Silver Spring, MD 20993-0002
Mr. Thomas Rust Regulatory Affairs Manager Viasys Healthcare GmbH Leibnizstrasse 7. D-97204 Hoechberg GERMANY
SEP - 3 2009
Re: K092324
Trade/Device Name: SpiroPro Regulation Number: 21 CFR 868.1890 Regulation Name: Oximeter Regulatory Class: II Product Code: BTY, DQA Dated: July 30, 2009 Received: August 5, 2009
Dear Mr. Rust:
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.
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. Rust
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.
for
Susan Runner, D.D.S., M.A. Acting 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
510(k) Number (if known):
SpiroPro
ко92324
Device Name:
Indications for Use:
The SpiroPro is a portable, battery operated device and can be used by physicians in the office or hospital, in occupational medicine or by patients in the home. The SpiroPro measures inspiratory and expiratory lung function parameters in adults and children 4 years and older. In addition to the pulmonary function measurements, oxygen saturation and heart rate can be recorded.
Prescription Use × (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Schubton
109232
(Division Sign-Off) (Division Sign-On)
Division of Anesthesiology, General Hospital
Division of Anesthesiology, General Hospital Division of Antrol, Dental Devices
510(k) Number:
Page 1 of
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.