K993637 · Nellcor Puritan Bennett, Inc. · DQA · Nov 24, 1999 · Cardiovascular
Device Facts
Record ID
K993637
Device Name
N-395 PULSE OXIMETER, WITH EXTENDED DEVICE CLAIMS
Applicant
Nellcor Puritan Bennett, Inc.
Product Code
DQA · Cardiovascular
Decision Date
Nov 24, 1999
Decision
SESE
Submission Type
Special
Regulation
21 CFR 870.2700
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The N-395 Pulse Oximeter is indicated for the continuous, non-invasive monitoring of functional oxygen saturation of arterial hemoglobin (SpO2) and pulse rate. For use with neonatal, pediatric and adult patients during both no motion conditions and for patients who are well or poorly perfused, in hospital-type facilities and intra-hospital transport environments. For prescription use only.
Device Story
N-395 Pulse Oximeter provides continuous, non-invasive monitoring of SpO2 and pulse rate. Device uses red and infrared LEDs as light sources and a photodiode to measure light absorption through tissue during the pulsatile cycle. OXISMART XL digital signal processing algorithm filters motion artifacts to maintain accurate readings during patient movement. Output includes digital SpO2/pulse rate values, a pulse amplitude 'blip bar', and audible/visual alarms. Device features 'SatSeconds' alarm management to reduce nuisance alarms from short-duration desaturations. Operated by clinicians in hospital-type facilities and intra-hospital transport environments. Data output available via serial port (EIA-232/RS-422) for printers or nurse call systems. Benefits include reliable monitoring during motion and reduced alarm fatigue.
Clinical Evidence
Bench testing only. Motion performance claims were verified by comparing the N-395 to the N-3000 predicate under 'challenging motion' conditions (defined as motion causing the N-3000 to be in Pulse Search at least 40% of the time). Results demonstrated a 20% improvement in motion performance for the N-395 compared to the N-3000 in adult and neonatal patient populations using specified sensors.
Technological Characteristics
Class II pulse oximeter; Class I, Type BF equipment per IEC 601-1. Uses red/infrared LED light sources and photodiode detectors. Powered by AC (100-240V) or internal 6V rechargeable lead-acid battery. Includes serial (EIA-232/RS-422) and nurse call interfaces. Software includes OXISMART XL digital signal processing for motion artifact reduction and SatSeconds alarm management. Flash ROM upgradable.
Indications for Use
Indicated for continuous, non-invasive monitoring of SpO2 and pulse rate in neonatal, pediatric, and adult patients. Suitable for well or poorly perfused patients in hospital or intra-hospital transport 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.
Model 2000 Pulse Oximeter, Ivy Biomedical Systems, Inc. (K982255)
Submission Summary (Full Text)
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NOV 2 4 1999
## SUMMARY OF SAFETY AND EFFECTIVENESS
| SUBMITTER: | Nellcor Puritan Bennett Inc.<br>A subsidiary of Mallinckrodt Inc. |
|--------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| DATE: | October 27, 1999 |
| COMMON NAME: | Pulse Oximeter |
| PROPRIETARY NAME: | N-395 Pulse Oximeter with extension of Motion Performance<br>Claims to cover three additional oximetry sensors |
| CONTACT: | David A. C. Green<br>Site Manager, Regulatory Affairs<br>Nellcor Puritan Bennett Inc.,<br>A subsidiary of Mallinckrodt Inc.<br>2200 Faraday Avenue<br>CARLSBAD, CA 92008<br>USA<br>Phone: (760) 603-5978<br>Fax: (760) 603-5907 |
| CLASSIFICATION: | Class II per 21 CFR 870.2700/74DQA<br>Oximeter |
| PREDICATE DEVICES: | Predicate devices are as follows:<br>1. N-3000 Pulse Oximeter, Nellcor Puritan Bennett Inc., K955642<br>2. Model 2000 Pulse Oximeter, Ivy Biomedical Systems, Inc., K982255 |
## l. DEVICE DESCRIPTION
The N-395 Pulse Oximeter is manufactured by Nellcor Puritan Bennett Inc., in GALWAY, Ireland.
The N-395 is a Class II Oximeter, per 21 CFR Part 870.2700. This device is designated as Class I, Type BF equipment, per IEC 601-1.
The N-395 Pulse Oximeter is designed for continuous, non-invasive monitoring of functional oxygen saturation of arterial hemoglobin (SpO2) and pulse rate by use of one of a range of compatible Nellcor Puritan Bennett oxygen transducers (sensors). The N-395 displays digital values of SpO2 and Pulse Rate. Pulse Amplitude is displayed by means of a "blip bar" presentation. The N-395 can be powered by an internal power supply operating on AC from a standard electrical utility receptacle (manually switchable from 100V to 240V) or alternatively by an integral sealed 6V rechargeable lead-acid battery. The N-395 is intended for prescription
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use with adult, pediatric and neonatal patients in hospital-type facilities and intrahospital transport environments.
Audible and visual alarms for high/low saturation, pulse search are provided. The N-395 also includes adjustable alarm silence duration and other configurable power-on settings. The N-395 provides an audible low battery warning to alert the user of impending loss of power and consequent loss of monitoring capability. The N-395 Pulse Oximeter has visual indicators for pulse search, motion, power mode (i.e. battery or AC) and alarm silence in addition to alarm features.
In addition to the above mentioned device features, the instrument has been designed to satisfy the needs of both the user and the patient. A convenient carrying handle is incorporated into the case. There is also a serial port (EIA-232 and RS-422 interface) that provides ASCII output of real-time data every two seconds. This data can be printed on serial printers. There is also an interface for nurse call systems through the rear connector. The device is also Flash ROM upgradable.
The N-395 Pulse Oximeter measures functional oxygen saturation by calculating the light absorption of tissue, bone and blood in the sampling light beam path during the pulsatile cycle. Red and infrared LED's are utilized as light sources. A photodiode acting as a photodetector senses the signal strengths of the two wavelengths of light, which vary inversely with the amount of light transmitted through the tissue. The N-395 receives this electrical information from the sensor and processes the information by use of an oximetry algorithm to provide real time values of SpO2, Pulse Rate and Pulse Amplitude.
The N-395 uses a similar SpO2 and Pulse Rate software algorithm to process the information from the sensor as the predicate device, N-3000, cleared under K955642,
In addition, the N-395 possesses motion-filtering software that reduces the effects of patient/sensor motion, enabling the N-395 to read through motion artifact to provide valid SpO2 and Pulse Rate readings for many types of motion.
Also included is an alam management software technique, known as SatSeconds which allows the caregiver to set the N-395 to accept desaturations below a specified threshold without alarming if those desaturations are of short duration or small magnitude.
This submission requests clearance for a labeling modification to the original N-395, cleared under K991823, to extend Motion Performance Claims to three additional oximetry sensors, as follows:
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N-395 Motion Performance Device Claims:
The N-395 features OXISMART®XL advanced digital signal processing which 1. enables the N-395 to read through motion artifact to deliver accurate saturation and pulse rate values.
The N-395 reads through challenging motion conditions giving valid SpO2 and 2. Pulse Rate readings for many types of motion.
Note 1:"Challenging motion" is of a nature and of sufficient magnitude to cause the N-3000 to be in Pulse Search at least 40% of the time.
Note 2: Under "challenging motion" conditions, the N-395 produces a 20% improvement in motion performance compared to the N-3000
Note 3: The N-3000 detects and indicates motion.
Note 4: Motion performance claims verified for Adult and Neonatal patients using D-25 and N-25 sensors.
Applicability: Models D-25, N-25, D-25L, D-20, I-20, Nellcor OXISENSOR II Oximetry Sensors.
Nellcor Puritan-Bennett Inc., asserts that:
- the intended use of the N-395 Pulse Oximeter, as described in its labeling, has not a) changed from that of the device cleared under K991823 and,
- b) the fundamental scientific technology of the N-395 Pulse Oximeter has not changed from that of the device cleared under K991823.
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Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
NOV 2 4 1999
Mr. David A.C. Green Nellcor Puritan Bennett Inc. 2200 Faraday Avenue Carlsbad, CA 92008-7208
K993637 Re: N-395 Pulse Oximeter Requlatory Class: II (two) Product Code: 74 DQA Dated: October 27, 1999 Received: October 28, 1999
Dear Mr. Green:
We have reviewed your Section 510(k) notification of intent to market the device referenced above and we 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). 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 (Premarket Approval), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 A substantially equivalent determination assumes compliance to 895. with the Current Good Manufacturing Practice requirements, as set forth in the Quality System Regulation (QS) for Medical Devices: General regulation (21 CFR Part 820) and that, through periodic QS inspections, the Food and Drug Administration (FDA) will verify such assumptions. Failure to comply with the GMP regulation may result in requlatory action. In addition, FDA may publish further announcements Please note: concerning your device in the Federal Register. this response to your premarket notification submission does not affect any obligation you might have under sections 531 through 542 of the Act for devices under the Electronic Product Radiation Control provisions, or other Federal laws or regulations.
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Page 2 - Mr. David A.C. Green
This letter will allow you to begin marketing your device as described in your 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4648. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers Assistance at its toll-free number (800) 638-2041 or (301) 443-6597, or at its internet address "http://www.fda.gov/cdrh/dsma/dsmamain.html".
Sincerely yours,
Christy Forman for
Celia M. Witten, Ph.D., M.D. Acting Director Division of Cardiovascular, Respiratory, and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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## INDICATIONS FOR USE
Page _________________________________________________________________________________________________________________________________________________________________________ l of
510(k) Number (if known): K993637
N-395 Pulse Oximeter Device Name:
Indications For Use:
The N-395 Pulse Oximeter is indicated for the continuous, non-invasive monitoring of functional oxygen saturation of arterial hemoglobin (SpO2) and pulse rate. For use with neonatal, pediatric and adult patients during both no motion conditions and for patients who are well or poorly perfused, in hospital-type facilities and intra-hospital transport environments. For prescription use only.
## N-395 Motion Performance Device Claims:
Applicability: Models D-25, N-25, D-25L, D-20, 1-20, Nellcor OXISENSOR // Oximetry Sensors,
The N-395 features OXISMART®XL advanced digital signal processing which enables the N-395 to read through motion artifact to deliver accuration and pulse rate values.
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Prescription Use (Per 21 CFR 801.109)
OR
Over-The-Counter Use
(Optional Format 1-2-96)
Christy foreman
(Division Sign-Off) Division of Cardiovascular, Respiratory, and Neurological Devices
510(k) Number
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.