Finger Pulse Oximeter, Model: X1906P

K221798 · Shenzhen Changkun Technology Co., Ltd. · DQA · May 4, 2023 · Cardiovascular

Device Facts

• Record ID: K221798
• Device Name: Finger Pulse Oximeter, Model: X1906P
• Applicant: Shenzhen Changkun Technology Co., Ltd.
• Product Code: DQA · Cardiovascular
• Decision Date: May 4, 2023
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 870.2700
• Device Class: Class 2

Indications for Use

The Fingertip Pulse Oximeter are intended for measuring functional oxygen saturation of arterial hemoglobin (SpO2) and pulse rate for both adults and adolescent as non-invasive spot checking in home and professional caring environment. It is designed for fingers between 7mm and 25.4mm in diameter (0.28 inches to 1.0inches). And it is not intended to be used under motion or low perfusion scenarios.

Device Story

Fingertip pulse oximeter (Model X1906P) measures arterial SpO2 and pulse rate via non-invasive photoelectric sensor. Device uses dual-wavelength LEDs (660nm red, 940nm infrared) to transmit light through fingertip; photosensitive element captures signal. Microprocessor processes signal using Lambert-Beer Law and capacity pulse scanning/recording technology to calculate SpO2 and pulse rate. Results displayed on device screen. Intended for spot-checking by patients or clinicians in home or professional settings. Features include low battery indicator and auto-power off. Powered by 2x AAA batteries. Provides real-time physiological monitoring to assist in health assessment.

Clinical Evidence

Clinical study conducted with 13 adult volunteers (5 male, 8 female; Fitzpatrick skin types II, IV, VI). Compared SpO2 readings against blood gas analyzer (SaO2) and pulse rate against patient monitor (HR). Results confirmed compliance with ISO 80601-2-61 requirements. No safety issues or adverse effects reported.

Technological Characteristics

Materials: ABS and silicone rubber. Sensing: Dual-wavelength LED (660nm/940nm) photoelectric sensor. Power: 2x AAA batteries (DC 3V). Form factor: 60mm x 35mm x 37mm. Connectivity: Standalone. Ingress protection: IP22. Standards: ISO 80601-2-61, IEC 60601-1, IEC 60601-1-11, IEC 60601-1-2, ISO 10993-1.

Indications for Use

Indicated for adults and adolescents for non-invasive spot checking of arterial hemoglobin oxygen saturation (SpO2) and pulse rate in home and professional care settings. Designed for finger diameters 7mm-25.4mm. Contraindicated for use under motion or low perfusion scenarios.

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

• Fingertip Pulse Oximeter (K160268)

Submission Summary (Full Text)

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Mav 4, 2023

Shenzhen Changkun Technology Co., Ltd. % Reanny Wang General Manager Shenzhen Reanny Medical Devices Management Consulting.. Ltd Room 1407, Jingting Building, Dongzhou Community, Guangming Street, Guangming District Shenzhen, Guangdong 518000 China

Re: K221798

Trade/Device Name: Finger Pulse Oximeter, Model: X1906P Regulation Number: 21 CFR 870.2700 Regulation Name: Oximeter Regulatory Class: Class II Product Code: DQA Dated: May 4, 2023 Received: May 4, 2023

Dear Reanny Wang:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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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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 and Part 809); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE(@fda.hhs.gov) or phone [phone] or 301-796-7100).

Sincerely.

James J. Lee -S

James J. Lee, Ph.D. Director DHT1C: Division of Sleep Disordered Breathing, Respiratory and Anesthesia Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health Enclosure

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### Indications for Use

510(k) Number (if known) K221798

Device Name Finger Pulse Oximeter, Model: X1906P

Indications for Use (Describe)

The Fingertip Pulse Oximeter are intended for measuring function of arterial hemoglobin (SpO2) and pulse rate for both adults and adolescent as not checking in home and professional caring environment. It is designed for fingers between 7mm and 25.4mm in diameter (0.28 inches to 1.0inches). And it is not intended to be used under motion or low perfusion scenarios.

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

This summary of 510(K) safety and effectiveness information is being submitted in accordance with the requirements of SMDA and 21 CFR §807.92.

The assigned 510(k) number is:_____K221798

# 1.0 Information of Submitter and Correspondent

### Submitter's information:

Company Name: Shenzhen Changkun Technology Co. Ltd.

Address: Room 501, Changkun Technology Building A, 12 Shijia Road, Biling Community, Biling Subdistrict, Pingshan District, Shenzhen City, Guangdong Province, 518118, P.R. China

Telephone: [phone] Contact Person: Wang Qingpeng General Manager Contact Title:

Contact Email: [e-mail]

### Submission correspondent's information:

Company Name: Shenzhen Reanny Medical Devices Management Consulting Co., Ltd

Address: Room 1407, Jingting Building, Dongzhou Community, Guangming Street,

Guangming District, Shenzhen, Guangdong Province, China

Contact person: Reanny Wang

E-Mail: [e-mail]

### 2.0 Device Information

| Type of 510(k) submission: | Traditional |
|----------------------------|--------------------------|
| Trade Name: | Fingertip Pulse Oximeter |
| Model: | X1906P |
| Classification name: | Oximeter |
| Review Panel: | Anesthesiology |
| Product Code: | DQA |
| Device Class: | Class II |
| Regulation Number: | 870.2700 |

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### 3.0 Predicate Device Information

| Sponsor: | Beijing Choice Electronic Technology Co., Ltd. |
|----------------|------------------------------------------------|
| Device: | Fingertip Pulse Oximeter |
| 510(K) Number: | K160268 |

### 4.0 Intended Use

The Fingertip Pulse Oximeter are intended for measuring functional oxygen saturation of arterial hemoglobin (SpO2) and pulse rate for both adults and adolescent as non-invasive spot checking in home and professional caring environment. It is designed for fingers between 7mm and 25.4mm in diameter (0.28 inches to 1.0inches). And it is not intended to be used under motion or low perfusion scenarios.

# 5.0 Product introduction

The Fingertip Pulse Oximeter X1609P is a fingertip device, which can measure the arterial SpO2 and pulse rate value and can display the results to the user.

Moreover, the X1609P also has the function of low battery voltage indicate and automatically power off. The power source is 2xAAA batteries. Fingertip Pulse Oximeter X1609P is small in volume, light in weight and convenient in carrying. It is composed of light signal driving circuit, preamplification circuit, low pass filtering circuit, DC bias circuit, gain control circuit, display control circuit, and main control circuit.

The device is for prescription. It is neither for life-supporting nor for implanting. It does not contain any drug or biological product and it does not need to be sterile.

The intended use, design principle, operation principle, functions, material and the applicable standards of X1609P Fingertip Pulse Oximeter are the same as the predicated device MD300CG51 Fingertip Pulse Oximeter (K160268) manufactured by Beijing Choice Electronic Technology Co., Ltd.

# 6.0 Summary comparing technological characteristics with predicate device

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| Technological Characteristics | Comparison result |
|----------------------------------|-------------------|
| Indications for use | Same |
| Design principle | Same |
| Appearance | Similar |
| Patients contact materials | Same |
| Performance | Similar |
| Biocompatibility | Same |
| Mechanical and Electrical safety | Same |
| Standards met | Same |
| EMC | Same |
| Function | Similar |

## 7.0 Performance Summary

Performance data includes "Non-Clinical Data", brief description of which are shown as below.

### Non-Clinical Testing:

The following performance data were provided in support of the substantial equivalence determination.

#### Biocompatibility testing

The biocompatibility evaluation for the Fingertip Pulse Oximeter was conducted in accordance with the International Standard ISO 10993-1 "Biological Evaluation of Medical Devices - Part 1: Evaluation and Testing within a Risk Management Process," as recognized by FDA. The testing included the following tests, results of which demonstrate the biocompatibility of the subject device:

- Cytotoxicity
- Skin Sensitization
- Skin Irritation

### Electrical safety, Home Healthcare environment and electromagnetic compatibility (EMC)

Electrical safety, Home Healthcare environment and EMC testing were conducted, and the results show that the subject device complies with the IEC 60601-1: 2005+CORR. 1 (2006)+CORR. 2 (2007)+A1: 2012 Medical electrical equipment Part 1: General requirements for basic safety and essential performance, IEC 60601-1-11: 2015 Medical

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electrical equipment -Part 1-11: General requirements for basic safety and essential performance – Collateral Standard: Requirements for medical electrical equipment and medical electrical systems used in the home healthcare environment and the IEC 60601-1-2: 2014 Medical electrical equipment -Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances - Requirements and tests.

#### Bench Testing

Bench testing was conducted, and the results show that the subject device complies with the ISO 80601-2-61: 2017 Medical electrical equipment — Part 2-61: Particular requirements for basic safety and essential performance of Fingertip Pulse Oximeter Equipment standard. And Pulse Rate Accuracy meets the requirements defined in ISO 80601-2-61, Clause 201.12.1.104.

#### Software Verification and Validation Testing

Software documentation including verification & validation was provided in accordance with FDA Guidance: Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices for software with a moderate level of concern.

The above tests were selected to show substantial equivalence between the subject device and the predicate device.

#### Clinical test:

Clinical studies were conducted to verify the accuracy of proposed device. The clinical studies were conducted per following standards:

- ISO 80601-2-61: 2017 Medical Electrical Equipment Part 2-61: Particular Requirements for Basic Safety and Essential Performance of Pulse Oximeter Equipment.
- · Pulse Oximeters-Premarket Notification Submissions: Guidance for Industry and Food and Drug Administration Staff.

There were 13 adult volunteers to validated the accuracy of finger pulse oximeter (Model: X1906P). 5 males and 8 females (including 3 subjects with Fitzpatrick VI, 3 subjects with Fitzpatrick II and 7 with Fitzpatrick IV). The measure result between the SpO2 measured by subject device and the SaO2 measured by the blood gas analyzer, the measure result between the PR measured by subject device and the HR measured by the patient monitor

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were conformed with the requirements of this clinical trial and related standards. The pulse oximeter had not been found any safety issues, adverse effects and complications during the clinical trial.

# 8.0 Comparison to predicate device

The subject device X1906P Fingertip Pulse Oximeter is substantially equivalent to MD300CG51 Fingertip Pulse Oximeter whose 510(k) number is K160268.

| Elements of<br>Comparison | Subject Device | Predicate Device | Judgment |
|--------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------|
| Company | Shenzhen Changkun<br>Technology Co. Ltd. | Beijing Choice Electronic<br>Technology Co., Ltd. | -- |
| Device Name | Fingertip Pulse Oximeter | Fingertip Pulse Oximeter | -- |
| Model | X1906P | MD300CG51 | -- |
| 510(k) Number | Pending | K160268 | -- |
| Product code | DQA | DQA | Same |
| Intended patient<br>population | Adult and Children | Adult, adolescent, child<br>and infant patient | Same,<br>within the<br>range of<br>predicate<br>device |
| Intended<br>application site | Finger | Finger | Same |
| Intended use | The Fingertip Pulse<br>Oximeter are intended for<br>measuring functional<br>oxygen saturation of<br>arterial hemoglobin (SpO2)<br>and pulse rate for both<br>adults and adolescent as<br>non-invasive spot checking<br>in home and professional<br>caring environment. It is<br>designed for fingers<br>between 7mm and 25.4mm | The Fingertip Pulse<br>Oximeter MD300CG11/<br>D300CG51 is a portable,<br>non-invasive device<br>intended for spot checking<br>of oxygen saturation of<br>arterial hemoglobin (SpO2)<br>and pulse rate of adult,<br>adolescent, child and infant<br>patient with the fingers<br>between 0.9 - 2.2 m (0.4 -<br>0.9 inch) thick in hospital. | Same, the<br>description<br>is<br>difference<br>and the<br>finger thick<br>range have<br>been<br>evaluated<br>in clinical<br>trial<br>according |
| Elements of<br>Comparison | Subject Device | Predicate Device | Judgment |
| | in diameter (0.28 inches to<br>1.0inches). And it is not<br>intended to be used under<br>motion or low perfusion<br>scenarios. | | to ISO<br>80601-2-<br>61. |
| Presentation or<br>OTC | Presentation | Presentation | Same |
| Measurement<br>range of SPO2 | 0~99% | 0~99% | Same |
| Accuracy of SPO2 | 70% to 99% range $\pm$ 2%;<br>less than 70% are<br>unspecified | 70%-99%, $\pm$ 2%;<br>Less than 70% no<br>definition | Same |
| Resolution of<br>SPO2 | 1% | 1% | Same |
| Transducer of<br>SPO2 | Dual-wavelength LED<br>sensor | Dual-wavelength LED<br>sensor | Same |
| Measurement<br>wavelength of<br>SPO2 | Red light:660nm,<br>Infrared light: 940nm | Red light: 660nm,<br>Infrared light: 940nm | Same |
| Measurement<br>range of pulse rate | 30-250bpm | 30-235bpm | Similar |
| Accuracy of pulse<br>rate | $\pm$ 3bpm | 30-99bpm, $\pm$ 2bpm; 100-<br>235bpm, $\pm$ 2% | Similar |
| Resolution of<br>pulse rate | 1 bpm | 1 bpm | Same |
| Pulse intensity of<br>pulse rate | Bar graph indicator | Bar graph indicator | Same |
| Design principle | A mathematical formula is established making use of<br>Lambert Beer Law according to Spectrum Absorption<br>Characteristics of Reductive hemoglobin(RHb) and<br>Oxyhemoglobin (HbO2) in glow and near-infrared zones.<br>Operation principle of the instrument: Photoelectric | | Same |
| Elements of<br>Comparison | Subject Device | Predicate Device | Judgment |
| | Oxyhemoglobin Inspection Technology is adopted in<br>accordance with Capacity Pulse Scanning and<br>Recording Technology, so that two beams of different<br>wavelength of lightscan be focused onto a human nail tip<br>through a clamping finger-type sensor. A measured<br>signal obtained by a photosensitive element, will be<br>shown on the Oximeter's display through process in<br>electronic circuits and microprocessor shown on the<br>Oximeter's display through electronic circuits and a<br>microprocessor. | | |
| Power source | Internal powered<br>equipment<br>DC3V, 2 x AAA batteries | Internal powered<br>equipment<br>1 AAA-size alkaline battery | Same |
| Dimensions | 60mm×35mm×37mm | Unknown | / |
| Weight | About 56g (including 2<br>AAA alkaline batteries) | Unknown | / |
| Classification | Internally powered<br>equipment, type BF<br>applied part | Internally powered<br>equipment, type BF<br>applied part | Same |
| Grade of<br>waterproof | IP22 | IPX2 | Same |
| Material of pulse<br>oximeter | ABS and silicone rubber | ABS and Silicone gel | Same |
| Performance | Compliance with ISO<br>80601-2-61 | Compliance with ISO<br>80601-2-61 | Same |
| Biocompatibility | All the patient contacting<br>materials are compliance<br>with ISO 10993-1/-5/-10 | All the patient contacting<br>materials are compliance<br>with ISO 10993-1/-5/-10 | Same |
| Electrical Safety | Compliance with IEC<br>60601-1 | Compliance with IEC<br>60601-1 | Same |
| Safety of home<br>healthcare | Compliance with IEC<br>60601-1-11 | Compliance with IEC<br>60601-1-11 | Same |
| Elements of<br>Comparison | Subject Device | Predicate Device | Judgment |
| environment | | | |
| EMC | Compliance with IEC<br>60601-1-2 | Compliance with IEC<br>60601-1-2 | Same |

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As seen in the comparison tables, the subject and predicate devices have same design principle, similar design features and performance specifications. The different technological characteristics between the subject and predicate devices will not raise different questions of safety or effectiveness

# 9. Conclusion

The Fingertip Pulse Oximeter is monitoring the patient's SpO2 and pulse rate in non-invasive, timely and convenient. Non-clinical testing and clinical testing were conducted on the subject device and all testing passed pre-specified criteria. The risks of Finger Pulse Oximeter also have been evaluated according to ISO 14971, the overall residual risk and side effect are acceptable, the benefit is greater than risk and hazard. Which demonstrate that the subject device is as safe, as effective, and performs as well as the legally marketed device predicate. The subject device is substantially equivalent to the predicate device.

## 10. Summary prepared date

May 4, 2023