Nellcor Bedside Respiratory Patient Monitoring System
Applicant
Covidien
Product Code
DQA · Cardiovascular
Decision Date
Mar 5, 2015
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 870.2700
Device Class
Class 2
Attributes
Real-World Evidence, Pediatric
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K141518 · Mar 5, 2015
Nellcor Bedside Respiratory Patient Monitoring System
Covidien
Hospital general care floor patient monitoring data
Clinical validation of the Respiration Rate Software algorithm accuracy in a hospital general care setting.
Respiration rate accuracy; General care floor; Clinical validation
Clinical Evidence
Study Design
Population
Comparator
Key Endpoints
Clinical validation study
Subjects from the hospital general care floor
Not applicable for this study
Respiration rate accuracy (+/- 1 breath per minute)
Indications for Use
The Nellcor™ Bedside Respiratory Patient Monitoring System is a portable pulse oximeter intended for prescription use only as a continuous non-invasive monitor of arterial oxygen saturation (SpO2) and pulse rate of adult, pediatric, and neonatal patients during both motion conditions, and for patients who are well or poorly perfused. The monitoring system is intended for use in hospital-type facilties, and during intra-hospital transport. The OxiMax SPD™ Alert (SPD) feature is intended only for facility-use care of adults to detect patterns of desaturation indicative of repetitive reductions in airflow through the upper airway and into the lungs. The Nellcor™ Respiration Rate parameter, when used in conjunction with the Nellcor™ Bedside Respiratory Patient Monitoring System and Nellcor™ Adult Respiratory Sensor, is intended for the continuous, non-invasive monitoring of respiration rate in adult patients in hospitals and hospital-type facilities.
Device Story
Portable pulse oximeter; monitors arterial oxygen saturation (SpO2), pulse rate, and respiration rate. Inputs: photoplethysmography (PPG) signals from compatible Nellcor OxiMax sensors. Operation: RR software algorithm (Version 2.0) processes PPG data to derive respiration rate (breaths per minute). Output: digital display of SpO2, pulse rate, and respiration rate. Used in hospitals/clinical facilities; operated by healthcare professionals. OxiMax SPD™ Alert feature detects desaturation patterns indicating upper airway airflow reduction. Output informs clinical assessment of patient respiratory status; supports continuous monitoring during intra-hospital transport.
Clinical Evidence
Clinical validation conducted on healthy adult volunteers and hospital general care floor patients. Study assessed accuracy of the RR Software algorithm (V2.0) against predicate. Results confirmed accuracy of +/- 1 breath/minute over a 4-32 breaths/minute range. No device-related adverse events reported.
Technological Characteristics
Portable pulse oximeter; utilizes photoplethysmography for SpO2, pulse, and respiration rate monitoring. Compatible with Nellcor OxiMax sensors. Software-based RR algorithm (Version 2.0) calculates respiration rate (4-40 breaths/minute). Complies with ISO 80601-2-61:2011 and IEC 60601-1:2005.
Indications for Use
Indicated for adult, pediatric, and neonatal patients requiring continuous non-invasive monitoring of SpO2 and pulse rate; adult patients requiring continuous non-invasive monitoring of respiration rate in hospital settings. Applicable to well or poorly perfused patients and motion conditions.
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.
Predicate Devices
Nellcor™ Bedside Respiratory Patient Monitoring System (K121806)
Nellcor™ Bedside Respiratory Patient Monitoring System (K123581)
Nellcor™ Bedside Respiratory Patient Monitoring System (K130320)
Submission Summary (Full Text)
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
March 5, 2015
Covidien Jamie Thomas Senior Regulatory Affairs Specialist 6135 Gunbarrel Ave. Boulder, CO 80301
Re: K141518
> Trade/Device Name: Nellcor™ Bedside Respiratory Patient Monitoring System Regulation Number: 21 CFR 870.2700 Regulation Name: Oximeter Regulatory Class: Class II Product Code: DQA, BZQ Dated: January 30, 2015 Received: February 2, 2015
Dear Ms. Thomas,
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.
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 devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in
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the quality systems (OS) 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 Industry and Consumer Education 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. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
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 Industry and Consumer Education 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,
Tejashri Purohit-Sheth, M.D.
Tejashri Purohit-Sheth, M.D. Clinical Deputy Director DAGRID/ODE/CDRH FOR
Erin I. Keith, M.S. 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) K141518
#### Device Name
Nellcor™ Bedside Respiratory Patient Monitoring System
#### Indications for Use (Describe)
The Nellcor™ Bedside Respiratory Patient Monitoring System is a portable pulse oximeter intended for prescription use only as a continuous non-invasive monitor of arterial oxygen saturation (SpO2) and pulse rate of adult, pediatric, and neonatal patients during both motion conditions, and for patients who are well or poorly perfused. The monitoring system is intended for use in hospital-type facilties, and during intra-hospital transport. The OxiMax SPD™ Alert (SPD) feature is intended only for facility-use care of adults to detect patterns of desaturation indicative of repetitive reductions in airflow through the upper airway and into the lungs.
The Nellcor™ Respiration Rate parameter, when used in conjunction with the Nellcor™ Bedside Respiratory Patient Monitoring System and Nellcor™ Adult Respiratory Sensor, is intended for the continuous, non-invasive monitoring of respiration rate in adult patients in hospitals and hospital-type facilities.
Type of Use (Select one or both, as applicable)
> Prescription Use (Part 21 CFR 801 Subpart D)
_ Over-The-Counter Use (21 CFR 801 Subpart C)
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# 510(k) SUMMARY
In accordance with the Food and Drug Administration Rule to implement provisions of the Safe Medical Devices Act of 1990 and in conformance with 21 CFR 807.92, provided is the 510(k) summary for the Nellcor™ Bedside Respiratory Patient Monitoring System.
#### SUBMITTER INFORMATION:
| Submitted By: | Covidien<br>6135 Gunbarrel Avenue<br>Boulder, CO 80301 |
|----------------------|--------------------------------------------------------|
| Contact: | Jamie Thomas<br>Sr. Regulatory Affairs Specialist |
| Phone: | 303-305-2315 |
| Fax: | 303-305-2212 |
| Date of Preparation: | June 6, 2014 |
### Device Name:
| Trade Name(s): | Nellcor ™ Bedside Respiratory Patient Monitoring System |
|-----------------------|---------------------------------------------------------|
| Common/Usual Name: | Pulse Oximeter |
| Classification Names: | Class II, Anesthesiology |
| CFR Reference: | 21 CFR 870.2700 |
| Product Code: | DQA, BZQ |
### PREDICATE DEVICES:
| Covidien Nellcor™ Bedside<br>Respiratory Patient Monitoring<br>System | K121806 |
|-----------------------------------------------------------------------|---------|
| Covidien Nellcor™ Bedside<br>Respiratory Patient Monitoring<br>System | K123581 |
| Covidien Nellcor™ Bedside<br>Respiratory Patient Monitoring<br>System | K130320 |
# DEVICE DESCRIPTION:
The subject device is the Nellcor™ Bedside Respiratory Patient Monitoring System (oximeter) which contains the Nellcor™ Respiration Rate Parameter (RR Version 2.0 Application device). The oximeter is designed for continuous, non-invasive monitoring of functional oxygen saturation of arterial hemoglobin (SpO2), pulse rate, and respiratory rate by use of one of compatible Nellcor OxiMax oxygen transducers (sensors). The oximeter displays digital values of SpO2 and pulse and respiratory rate. The oximeter device features the same technological characteristics as the predicate, which is the exact same system featuring a system software upgrade.
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The oximeter features the optional Nellcor™ Respiration Rate (RR) Software Application for use on the finished oximeter device. Covidien is submitting this traditional 510(k) submission as the result of a design change to the RR software device residing on the oximeter. The design change to the RR Software Application involves a modification to the principles of operation of the RR software algorithm.
The RR software application is intended for continuous non-invasive monitoring of respiration rate in adult patients, and it is calculated by an RR algorithm residing on the monitor which derives patient respiratory rate in breaths per minute based upon oximetry photoplethysmography data that is received from the oximetry sensor on the patient. The software parameter was cleared by the FDA through traditional 510(k) premarket notification (K111933) as the Nellcor Respiration Rate Software, Version 1.0 on March 15, 2012. Version 2.0 (V2.0) of the Respiration Rate (RR) software is an upgraded design of the original cleared software.
## INDICATIONS FOR USE:
The Nellcor™ Bedside Respiratory Patient Monitoring System is a portable pulse oximeter intended for prescription use only as a continuous non-invasive monitor of arterial oxygen saturation (SpO2) and pulse rate of adult, pediatric, and neonatal patients during both motion conditions, and for patients who are well or poorly perfused. The monitoring system is intended for use in hospitals, hospitaltype facilities, and during intra-hosport. The OxiMax SPD™ Alert (SPD) feature is intended only for facility-use care of adults to detect patterns of desaturation indicative of repetitive reductions in airflow through the upper airway and into the lungs.
The Nellcor™ Respiration Rate parameter, when used in conjunction with the Nellcor™ Bedside Respiratory Patient Monitoring System and Nellcor™ Adult Respiratory Sensor, is intended for the continuous, non-invasive monitoring of respiration rate in hospitals and hospitals and hospital type facilities.
# TECHNOLOGICAL CHARACTERISTICS SUMMARY & SUBSTANTIAL EQUIVALENCE STATEMENT:
The subject device, is the Nellcor™ Bedside Respiratory Patient Monitoring System (oximeter) which contains the Nellcor™ Respiration Rate Software Version 2.0 Application (RR software device), has the same intended use (Adults), general design (continuous, non-invasive indication of respiration rate) and fundamental scientific technology (indicator of central ventilatory drive) as the predicate device Nellcor™ Bedside Respiratory Patient Monitoring System K130320, K123581 and K121806.
The Respiration Rate Software uses photoplethysmography to calculate respiration rate, both of which are indicators of central ventilator drive. The respiration rate measurement range for the Respiration Rate Software is 4-40 breaths/minute, and is indicated for adults only. Both the subject and predicate devices have an accuracy of +1 breaths/minute for the adult population.
# PERFORMANCE DATA SUMMARY:
### Non-clinical performance data summary
The appropriate safety, environmental, performance and functional testing was conducted to ensure that the specifications of the Nellcor Respiration Rate Software and Nellcor™ Adult Respiratory Sensor were met.
The performance testing section of this submission includes verification and validation reports for pulse oximetry performance in accordance with FDA Guidance document: "Pulse Oximeters - Premarket Notification Submissions [510(k)s] Guidance for Industry and Food and Drug Administration Staff". Nonclinical testing in this submission includes, but is not limited to. ISO 80601-2-61:2011 and IEC 60601-1:2005 test reports, Oximetry performance verification, Human Factors Summative Usability validation, testing incorporating simulated motion performed to validate pulse rate accuracy across the operating
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range of 20 to 250 beats per minute, and testing incorporating simulated motion performed to validate respiration rate accuracy across the operating range of 4 to 40 breaths per minute.
The simulated motion data used to assess respiration rate performance was collected from monitored patients on the general care floor which represents the intended populations and includes extreme boundaries of patient characteristics and artifact. Specifically, this simulation assesses respiration rate accuracy in the presence of motion artifact under conditions of low pulse rate (5th percentile) and low perfusion (5th percentile) and low respiratory variations for all of frequency, amplitude and baseline modulations (all 10th percentile) and validates the respiration rate accuracy across the range of 4 to 40 breaths per minute.
The results of this testing demonstrate that the Nellcor™ Bedside Respiratory Patient Monitoring System has a respiration rate measurement range of 4 to 40 breaths per minute with an accuracy of +1 breath per minute, and is substantially equivalent to the predicate device with respect to Respiration Rate (for adults).
## Clinical Summary
Clinical validation studies on healthy adult volunteers and on subjects from the hospital general care floor were conducted to assess the accuracy of the Respiration Rate Software algorithm. The studies demonstrated the accuracy of the Respiration Rate Software algorithm was as good as the predicate. The studies demonstrated the Respiration Rate Software algorithm calculates respiration rate within a stated accuracy of +1 breath per minute over a range of 4-32 breaths per minute and is shown to be substantially equivalent to the predicate device.
No device related adverse events were observed during the clinical studies.
### Conclusions
The information provided in this 510(k) demonstrates the Nellcor™ Bedside Respiratory Patient Monitoring System is substantially equivalent to the predicate devices with respect to performance.
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.