K140707 · International Biomedical · BTL · May 28, 2014 · Anesthesiology
Device Facts
Record ID
K140707
Device Name
LIFEBORNE INFANT RESUSCITATOR
Applicant
International Biomedical
Product Code
BTL · Anesthesiology
Decision Date
May 28, 2014
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 868.5925
Device Class
Class 2
Attributes
Therapeutic, Pediatric
Indications for Use
The LifeBorne Infant Resuscitator is intended to provide the basic equipment required for pulmonary resuscitation of neonatal infants. Pulmonary resuscitation includes practices necessary to establish a clear airway and provide oxygen or air/oxygen mixtures and/or manual ventilation to the neonatal infant.
Device Story
Gas-powered emergency resuscitation system for neonatal/infant patients (<10 kg). Used in hospital settings (delivery suites, nursery, ICU) by trained medical professionals. Inputs: wall gas or cylinder source. Components: Venturi vacuum device for airway suctioning; vacuum gauge; medical blender for FIO2 control (21-100%); flowmeters; T-piece circuit with PEEP control; PIP control; airway pressure manometer. Operation: clinician manually controls ventilation via face mask or ET tube. Output: controlled gas delivery and airway pressure monitoring. Benefits: provides precise FIO2, manual ventilation, and emergency airway clearance to support neonatal resuscitation.
Clinical Evidence
Bench testing only. No clinical data provided. Performance verified via testing: valve function after vomitus, inspiratory/expiratory resistance, dead space (<7 mL), FIO2 accuracy (within 5%), flow valve accuracy, airway manometer accuracy, VOC testing, and particulate analysis.
Technological Characteristics
Gas-powered manual resuscitator. Components: Venturi vacuum, vacuum gauge, medical blender, flowmeters, PIP/PEEP controls, airway pressure manometer. Patient connection: face mask or ET tube. Gas source: wall or cylinder. FIO2 range: 21-100%. Manometer range: -10 to 80 cm H2O. Max flow: 15 LPM. Mechanical/pneumatic operation; no software or electronic algorithms.
Indications for Use
Indicated for pulmonary resuscitation of neonatal infants and infants weighing less than 10 kg. Used to establish clear airway and provide oxygen/air mixtures and manual ventilation.
Regulatory Classification
Identification
A powered emergency ventilator is a demand valve or inhalator intended to provide emergency respiratory support by means of a face mask or a tube inserted into a patient's airway.
Predicate Devices
GE - Giraffe and Panda T-Piece Resuscitation System (k070210)
Fisher & Paykel - NeoPuff (k892885)
Submission Summary (Full Text)
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K140707
## Traditional 510(k) Submission MAY 28 2014 LifeBorne Infant Resuscitator - March 18, 2014
## 510(k) SUMMARY
Submitter Information:
International Biomedical 8206 Cross Park Drive Austin, TX 78754 U.S.A.
Regulatory Affairs Contact:
Amy Pieper Director of Regulatory Affairs (512) 873-0033 - phone (512) 873-9090 - fax
Date Summary Prepared: March 18, 2014
Device Identification:
Trade Name: LifeBorne Infant Resuscitator Common Name: Ventilator, Emergency Gas Powered (Resuscitator) Regulatory Class: II Regulation: 868.5925 Product Code: BTL Panel: Anesthesiology
Predicate Device:
GE - Giraffe and Panda T-Piece Resuscitation System - k070210 Fisher & Paykel - NeoPuff - k892885
Device Description:
The resuscitation system provides the basic equipment required for pulmonary resuscitation of neonatal infants. The LifeBorne Infant Resuscitator is a gas powered emergency resuscitation system. It is intended to be used inside the hospital by trained medical professionals to provide precise FIO2 delivery, manual ventilation, and emergency airway clearance as established by resuscitation guidelines to neonates and infants weighing less than 10 kg (22 lb).
#### Intended Use:
The LifeBorne Infant Resuscitator is intended to provide the basic equipment required for pulmonary resuscitation of neonatal infants. Pulmonary resuscitation includes practices necessary to establish a clear airway and provide oxygen or air/oxygen mixtures and/or manual ventilation to the neonatal infant.
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## Traditional 510(k) Submission LifeBorne Infant Resuscitator - March 18, 2014
### Functional Description and Technological Characteristics:
The LifeBorne Infant Resuscitation System incorporates the following components for neonatal resuscitation:
- Venturi vacuum device for suctioning airways (no 510k) .
- Vacuum gauge for monitoring suction pressures (no 510k) .
- . Medical blender to mix air and oxygen to a precise FIO2 (k883038 or k925982)
- . Flowmeters for the delivery of oxygen or air/oxygen mixtures (no 510k)
- . Peak Inspiratory Pressure (PIP) control to set the maximum pressure delivered during an inspiratory phase of a manual breath (no 510k)
- . Peak End Expiratory Pressure (PEEP) control located on a provided T-piece circuit to set the maximum pressure during the expiratory phase of a manual breath (k093913)
- . An airway pressure manometer to monitor both PIP and PEEP airway pressure (no 510k)
### Substantial Equivalence:
The LifeBorne Infant Resuscitator described in this submission is, in our opinion, substantially equivalent to the predicate device, in regards to intended use and safety and effectiveness. The intended use of the LifeBorne Infant Resuscitator is identical to the intended use of the predicate k070210.
| | Proposed<br>LifeBorne Infant<br>Resuscitator | Predicate<br>k070210 GE Giraffe and Panda | Predicate<br>k892885 F&P NeoPuff |
|---------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------|
| Indications for Use | The LifeBorne Infant<br>Resuscitator is intended<br>to provide the basic<br>equipment required for<br>pulmonary resuscitation<br>of neonatal infants.<br>Pulmonary resuscitation<br>includes practices<br>necessary to establish a<br>clear airway and provide<br>oxygen or air/oxygen<br>mixtures and/or manual<br>ventilation to the<br>neonatal infant. | The T-piece resuscitation<br>system provides the basic<br>equipment required for<br>pulmonary resuscitation of<br>infants. Pulmonary<br>resuscitation includes<br>practices necessary to<br>establish a clear airway and<br>provide oxygen or<br>air/oxygen mixtures and or<br>manual ventilation to the<br>infant. | Manually operated, gas<br>powered resuscitator<br>which provides<br>controlled and accurate<br>resuscitation of newborn<br>babies. |
| Environment for Use | Hospital, delivery suites,<br>nursery, ICU | Hospital, delivery suites,<br>nursery, ICU | Hospital, delivery suites,<br>nursery, ICU |
| Patient Population | Infant < 10 kg | Infant < 10 kg | Infant < 10 kg |
| Patient Connection | Face mask; ET tube | Face mask; ET tube | Face mask; ET tube |
| Air/Oxygen Mixture | 21-100% | 21-100% | Not specified |
| Gas Flow Source | Wall gas or cylinder | Wall gas or cylinder | Wall gas or cylinder |
| Manometer Range | -10 to 80 cm H2O | -10 to 80 cm H2O | -20 to 80 cm H2O |
FDA Submission - Resuscitator
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# Traditional 510(k) Submission LifeBorne Infant Resuscitator - March 18, 2014
| Peak Inspiratory<br>Pressure (PIP) | Max 45 +/- 5 cm H2O | Max 45 +/- 5 cm H2O | 2 – 80 cm H2O |
|-----------------------------------------------|------------------------------------|------------------------------------|---------------------------------------|
| Positive End<br>Expiratory Pressure<br>(PEEP) | 0-6 cm H2O | 0-6 cm H2O | 1-25 cm H2O,<br>depending on flowrate |
| Vacuum Pressure<br>Range | 0 - 150 mmHg, negative<br>pressure | 0 - 150 mmHg, negative<br>pressure | N/A – suction not<br>available |
| Maximum gas flow<br>rate | 15 LPM | 15 LPM | 15 LPM |
| Maximum pressure<br>relief | 55 cm H2O | 55 cm H2O | 40 cm H2O |
| Features: Venturi<br>Vacuum Device | Present, same as<br>predicate | Present | N/A |
| Features: Vacuum<br>gauge | Present, same as<br>predicate | Present | N/A |
| Features: Integrated<br>Medical Blender | Present, same as<br>predicate | Present | Non integrated, but<br>available |
| Features: Flowmeters<br>for delivery of gas | Present, same as<br>predicate | Present | Not integrated, but<br>available |
| Features: PIP control | Present, same as<br>predicate | Present | Present |
| Features: PEEP<br>control | Present, same as<br>predicate | Present | Present |
| Features: Airway<br>pressure manometer | Present, same as<br>predicate | Present | Present |
Performance Testing:
Pulmonary resuscitation of infants includes well established clinical practices; clinical testing is not necessary to support safety and effectiveness. Conformance of the LifeBorne Infant Resuscitation System to performance specifications has been established through bench testing.
| TEST | TEST REQUIREMENTS | SUMMARY OF<br>RESULTS |
|---------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------|
| Valve Function<br>after Vomitus | The proper function of the circuit shall be verified within<br>20 seconds of becoming disabled by vomitus. Function is<br>verified by verifying flow valve accuracy. | Passed. |
| Inspiratory<br>Resistance | Pressure generated at the patient connection port during<br>expiration should not exceed -5 cmH2O with inspiratory<br>airflow set to 6 L/min. | Passed. |
| Expiratory<br>Resistance | Pressure generated at the patient connection port during<br>expiration should not exceed 5 cmH2O with expiratory<br>airflow set to 6 L/min. | Passed. |
| Dead Space | The deadspace volume of the T-Piece circuit should be less<br>than 7 mL. | Passed. |
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# Traditional 510(k) Submission LifeBorne Infant Resuscitator - March 18, 2014
| FIO2 accuracy | The proper function of the FIO2 adjustment knob shall be verified by comparing the FIO2 setting value with the output oxygen concentration. Values shall be within 5%. | Passed. |
|----------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------|
| Primary and<br>Secondary Flow<br>Valve - Peak Flow | The proper function of the primary and secondary flow valves shall be verified by comparing the flow setting with the actual measured output flow. | Passed. |
| Airway Manometer<br>Accuracy | The proper function of the airway manometer shall be verified by comparing the pressure readings with the actual measured output pressure. | Passed. |
| VOC Testing | The device should not add volatile organic compounds (VOCs) to the output gas delivered to the patient. | Passed |
| Particulate<br>Analysis | The output of particulate matter sizes 2.5 microns or less are no more than 12 micrograms/cubic meter of air at one atmospheric pressure. | Passed |
The LifeBorne Infant Resuscitator met all the performance requirements as outlined above and thus can be found to be substantially equivalent to the predicate devices.
### Conclusion:
In regards to intended use and technology the LifeBorne Infant Resuscitator is substantially equivalent to the listed predicates. Any differences between the LifeBorne Infant Resuscitator and the predicates do not raise any new questions of safety and effectiveness.
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Image /page/4/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is an abstract image of an eagle.
#### Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
May 28, 2014
International Biomedical, Ltd. Amy Pieper Director of Regulatory Affairs 8206 Cross Park Drive Austin, TX 78754
Re: K140707
Trade/Device Name: LifeBorne Infant Resuscitator Regulation Number: 21 CFR 868.5925 Regulation Name: Powered emergency ventilator Regulatory Class: Class II Product Code: BTL Dated: March 18, 2014 Received: March 24, 2014
Dear Ms. Pieper:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
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### Page 2 - Amy Pieper
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of 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/Resourcesfor You/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportalProblem/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/Resourcesfor You/Industry/default.htm.
Sincerely vours.
Tejashri Parohit-Sheth, M.D.
Tejashri Purohitt Sheth HD
Chalal Deputy Director
DAGRID/ODE/CDRH FOR
Erin I. Keith, M.S. Acting 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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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
#### Indications for Use
Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below.
510(k) Number (if known)
| Device Name | |
|-------------|--|
|-------------|--|
LifeBorne Infant Resuscitator
Indications for Use (Describe)
The LifeBome Infant Resuscitator is intended to provide the basic equipment required for pulmonary resuscitation of neonatal infants. Pulmonary resuscitation includes practices necessary to establish a clear airway and provide oxygen or air/oxygen mixtures and/or manual ventilation to the neonatal infant.
Type of Use (Select one or both, as applicable)
2 Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.
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FORM FDA 3881 (1/14)
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.