The Hudson RCI Voldyne Volumetric Exerciser is intended as an inspiratory deep breathing positive exerciser for adult and pediatric (above 5 yrs) patients. It is a single patient, multi-use device used in hospital or home care setting.
Device Story
The Hudson RCI Voldyne Volumetric Exerciser is a mechanical incentive spirometer used in hospitals or home care settings. The device consists of a housing with two chambers (flow chip and piston), tubing, and a mouthpiece. The patient inhales through the mouthpiece, creating negative pressure that causes the flow chip and piston to rise. The piston chamber is graduated (250-2,500 ml or 500-4,000 ml) to provide visual feedback on breathing volume and flow. The device serves as an exercise incentive for patients requiring sustained maximal inspiration (SMI). Healthcare providers use the device to encourage deep breathing, which can benefit patients by promoting lung expansion. The device is non-sterile and intended for single-patient, multi-use.
Clinical Evidence
Bench testing only. No clinical data provided. Testing included shelf-life, cleaning validation, ISO 5356-1:2015 (conical connectors), and biocompatibility per ISO 10993-1:2009 (cytotoxicity, sensitization, irritation, and systemic toxicity).
Technological Characteristics
Mechanical volumetric incentive spirometer. Components: housing, piston, tubing, mouthpiece. Materials evaluated per ISO 10993-1:2009. Conical connectors comply with ISO 5356-1:2015. Non-sterile, single-patient, multi-use. No software or electronic components.
Indications for Use
Indicated for adult and pediatric patients (above 5 years) requiring inspiratory deep breathing exercise (sustained maximal inspiration). No contraindications.
Regulatory Classification
Identification
An incentive spirometer is a device that indicates a patient's breathing volume or flow and that provides an incentive to the patient to improve his or her ventilation.
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July 1, 2019
Teleflex Medical, Inc Sirisha Kommana Regulatory Affairs Specialist 3015 Carrington Mill Blvd, Suite 600 North Morrisville, North Carolina 27560
Re: K182847
Trade/Device Name: Hudson RCI® Voldyne® Volumetric Exerciser Regulation Number: 21 CFR 868.5690 Regulation Name: Incentive Spirometer Regulatory Class: Class II Product Code: BWF Dated: May 22, 2019 Received: May 23, 2019
Dear Sirisha Kommana:
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.
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
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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 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 (1-800-638-2041 or 301-796-7100).
Sincerely,
for James J. Lee, PhD Assistant Director DHT1C: Division of ENT, Sleep Disordered Breathing, Respiratory and Anesthesia Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health
Enclosure
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#### Indications for Use
Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2020 See PRA Statement below.
510(k) Number (if known) K182847
Device Name Hudson RCI® Voldyne® Volumetric Exerciser
Indications for Use (Describe)
The Hudson RCI Voldyne Volumetric Exerciser is intended as an inspiratory deep breathing positive exerciser for adult and pediatric (above 5 yrs) patients. It is a single patient, multi-use device used in hospital or home care setting.
| Type of Use (Select one or both, as applicable) |
|-------------------------------------------------|
|-------------------------------------------------|
X Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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#### 510(k) SUMMARY (K182847)
#### A. Name, Address, Phone and Fax Number of Applicant
Teleflex Medical, Inc. 3015 Carrington Mill Blvd Morrisville, NC 27560 Phone: 919-433-4831 Fax: 919-361-3939
#### B. Contact Person
Sirisha Kommana Regulatory Affairs Specialist, Respiratory Division
#### C. Date Prepared
July 1, 2019
#### D. Device Name
| Trade Name: | Hudson RCI® Voldyne® Volumetric Exerciser |
|-----------------------|-------------------------------------------|
| Common Name: | Incentive Spirometer |
| Product Code: | BWF |
| Regulation Number: | 868.5690 |
| Classification: | II |
| Classification Panel: | Anesthesiology |
#### E. Predicate Device
This submission demonstrates substantial equivalence to Besmed Volumetric Incentive Spirometer (K141355).
### F. Device Description
The Hudson RCI® Voldyne® Volumetric Exerciser ("Voldyne") is a volumetric incentive spirometer. It is a single patient multi-use device. The primary interface of the user with the device is through a mouthpiece.
The device contains two chambers; one for the flow chip, and one for the piston. The piston chamber is marked with a graduation from 500 ml to 4,000 ml (for the Voldyne 4000) or 250 ml to 2,500 ml (for the Voldyne 2500 and Voldyne Pediatric) on the front and the back of the main housing. The flow chip chamber for the device is marked with a happy face symbol with arrows pointing to the optimum position of the Voldyne Pediatric version includes a sticker sheet with clouds and trees graphics, which can be placed onto the device.
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When the patient inhales the flow chip and piston rise due to the negative pressure created; this indicates breathing volume and flow, while the device provides an exercise incentive to patients who require sustained maximal inspiration (SMI).
### G. Indications for Use
The Hudson RCI Voldyne Volumetric Exerciser is intended as an inspiratory deep breathing positive exerciser for adult and pediatric (above 5 yrs) patients. It is a single patient, multiuse device used in hospital or home care setting.
#### H. Contraindications
None
### l. Substantial Equivalence
The proposed device is substantially equivalent to the predicate device.
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# Comparison of Predicate vs. Proposed Device
| Features | Teleflex Medical<br>Hudson RCI® Voldyne®<br>Volumetric Exerciser<br>(K182847) | Besmed Volumetric<br>Incentive Spirometer<br>(Predicate Device-<br>K141355) |
|----------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Classification Name | Spirometer, Therapeutic<br>(Incentive) | Spirometer, Therapeutic<br>(Incentive) |
| Product Code | BWF | BWF |
| Class | II | II |
| Regulation Number | 868.5690 | 868.5690 |
| Single Patient use<br>only | Yes | Yes |
| Usability | Multi-use | Multi-use |
| Patient Population | Adults and Pediatric<br>patients (above 5 years) | Patients requiring<br>inspiratory exercise |
| Prescription Only | Yes | Yes |
| Environments of<br>use | Home care settings and<br>hospitals | Home care settings and<br>hospitals |
| Volume | 2500 and 4000 cc | 2500 and 5000 cc |
| Sterile | No | No |
| Indication for Use | The Hudson RCI Voldyne<br>Volumetric Exerciser is<br>intended as an inspiratory<br>deep breathing positive<br>exerciser for adult and<br>pediatric (above 5 yrs)<br>patients. It is a single<br>patient, multi-use device<br>used in hospital or home<br>care setting. | The Besmed Volumetric<br>Incentive Spirometer is<br>intended as an<br>inspiratory deep breathing<br>positive exerciser.<br>Intended for single-patient,<br>multi-use in a hospital or<br>home care setting. |
| Contraindications | None | None |
| Basic Components | Housing<br>1 ball / piston<br>Tubing<br>Mouthpiece | Housing<br>1 ball / piston<br>Tubing<br>Mouthpiece |
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| Patient Interface | Mouthpiece | Mouthpiece |
|-------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------|
| Materials<br>Evaluation | The materials used in the<br>construction of Voldyne<br>were evaluated per ISO<br>10993-1:2009 | The materials used in the<br>construction of predicate<br>were evaluated per ISO<br>10993-1:2009 |
| Shelf-life | 1 Year | Not specified |
| Accuracy | Equivalent | $\pm$ 15% |
| Performance<br>Testing | Age testing (Pre and Post<br>Aging)<br>Mouthpiece and Tubing<br>Engagement TestTubing and Housing<br>Engagement TestCollapsible Tubing<br>Leakage TestVolume Accuracy TestFlow Chip and Piston<br>OperationSlide Operation | Age Testing<br>-Pre and post-exposure |
### J. Comparison to the Predicate
The basic technological and operating principles are for both devices. Both the predicate and subject device have similar indications for use. Both the subject and predicate device are intended for similar patient populations. Both the subject and predicate device are intended to be used in home care and hospital settings. Both the subject and predicate devices are disposable, non-sterile, single patient use devices. The proposed Voldyne® Volumetric Exerciser is substantially equivalent to the predicate device.
### K. Performance Data
Teleflex performed a number of tests to demonstrate that the Voldyne® Volumetric Exerciser meets its performance specifications and that it is substantially equivalent to the predicate Besmed Volumetric Incentive Spirometer (K141355).
The following tests were performed on the proposed devices:
- Shelf Life
- Cleaning validation
- ISO 5356-1:2015- Anaesthetic and respiratory equipment -- Conical connectors -Part 1: . Cones and sockets, applicable sections
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- Biocompatibility: The Hudson RCI® Voldyne® Volumetric Exerciser is an externally ● communicating tissue contact, limited duration device (<24 hours).
- ISO 10993-1:2009 Biological Evaluation of Medical Devices Part 1: Evaluation and o Testing Within a Risk Management Process
- ISO 10993-5: 2009 Biological Evaluation of Medical Devices Part 5: Tests for In o Vitro Cytotoxicity
- ISO 10993:10: 2010 Biological Evaluation of Medical Devices Part 10: Tests for O Irritation and Skin Sensitization
- ISO 10993:11: 2017 Biological Evaluation of Medical Devices Part 11: Tests for o Systemic Toxicity
The proposed devices were tested to the requirements of ISO 5356-1:2015. Cytotoxicity, Sensitization, Irritation and Systemic Toxicity were performed to demonstrate biocompatibility of the patient contacting materials to the requirements of ISO 10993-1:2009. Overall, the results are comparable to the predicate and support a determination of substantial equivalence.
## L. Conclusion
The Voldyne® Volumetric Exerciser has similar indication for use and technological characteristics as its predicate. The device data and test results demonstrate that the device meets the applicable standards for Voldyne® Volumetric Exerciser and is substantially equivalent to the predicate device.
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.