K122252 · Medical Developments International · NVP · Nov 13, 2013 · Anesthesiology
Device Facts
Record ID
K122252
Device Name
SPACE CHAMBER PLUS COMPACT SPACE CHAMBER PLUS
Applicant
Medical Developments International
Product Code
NVP · Anesthesiology
Decision Date
Nov 13, 2013
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 868.5630
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Space Chamber Plus and Compact Space Chamber Plus are intended to be used by patients who are under the care or treatment of a licensed health care provider or physician. The devices are intended to be used by these patients to administer aerosolized medication from most pressurized Metered Dose Inhalers, prescribed by a physician or health care professional. The intended environments for use include home, hospitals and clinics.
Device Story
Space Chamber Plus and Compact Space Chamber Plus are valved holding chambers (VHCs) designed to assist patients in inhaling aerosolized medication from pressurized Metered Dose Inhalers (pMDIs). The device consists of a cylindrical chamber with an inhaler interface at one end and a mouthpiece (optionally used with a mask) at the other. A cross-slit valve system regulates airflow; the valve opens during inhalation and closes during exhalation, allowing the patient to visualize valve movement through the transparent chamber to confirm proper inhalation technique. The device is used by patients in home, hospital, or clinical environments. By providing a holding space for the aerosol, the device improves the respirable fraction of medication delivered to the patient compared to pMDI use alone, facilitating consistent dosing and effective treatment for respiratory conditions.
Clinical Evidence
Bench testing only. Particle size distribution testing (MMAD and respirable fraction) was conducted using three drug classes (ipratropium bromide, albuterol, beclomethasone dipropionate) to compare the subject devices against the predicate. Results showed equivalent respirable fractions and MMAD values with narrow 95% CIs, confirming consistent medication delivery. Additional testing included materials characterization, particulate analysis, drop testing, cleaning validation, and ISO 10993 biocompatibility testing (cytotoxicity, sensitization, irritation, genotoxicity, implantation).
Technological Characteristics
Valved holding chamber; cylindrical form factor; cross-slit valve system; compatible with standard pMDIs; mouthpiece or mask interface; transparent body for visual feedback; biocompatible materials (ISO 10993 compliant).
Indications for Use
Indicated for patients under the care of a licensed healthcare provider to administer aerosolized medication from pressurized Metered Dose Inhalers (pMDIs) in home, hospital, or clinical settings.
Regulatory Classification
Identification
A nebulizer is a device intended to spray liquids in aerosol form into gases that are delivered directly to the patient for breathing. Heated, ultrasonic, gas, venturi, and refillable nebulizers are included in this generic type of device.
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K122252
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Space Chamber Plus Traditional 510(k)
## 510(k) Summary
| Date Prepared:<br>510(k) Owner: | 4 November 2013<br>Medical Developments International Limited<br>7/56 Smith Road<br>Springvale VIC 3171<br>Australia | |
|-----------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------|
| Submitter/ Official<br>Contact: | Maggie Oh - Director, Scientific Affairs<br>7/56 Smith Road<br>Springvale, Victoria 3171<br>Australia | NOV 1 3 2013 |
| | Phone: +61 3 9547 1888<br>Fax: +61 3 9547 0262 | |
| Device Trade Name: | Space Chamber Plus<br>Compact Space Chamber Plus | |
| Device Common /<br>Classification Name: | Spacer / Valved Holding Chamber;<br>Nebulizer (Direct Patient Interface) | |
| Device Classification: | 21 CFR868.5630, Class II | |
| Product Code: | NVP | |
| Predicate: | AeroChamber Plus aVHC with Flow-Vu IFI (K070674) | |
| Description: | The Space Chamber Plus and Compact Space Chamber Plus are devices<br>designed to assist patients with inhaling aerosolized medication dispensed<br>through a Metered Dose Inhaler.<br>The devices consist of a cylindrical chamber with an opening at each end.<br>One opening is for the aerosol medication to be inserted, the other is<br>tapered into a mouthpiece for inhalation. The mouthpiece can be used with<br>or without a mask. | |
| | | |
| | The Compact Space Chamber Plus is a smaller version of the Space<br>Chamber Plus that allows for easier storage and handling. | |
| Intended Use: | The Space Chamber Plus and Compact Space Chamber Plus are intended<br>to be used by patients who are under the care or treatment of a licensed<br>health care provider or physician. The devices are intended to be used by<br>these patients to administer aerosolized medication from most pressurized<br>Metered Dose Inhalers, prescribed by a physician or health care<br>professional. The intended environments for use include home, hospitals<br>and clinics. | |
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Comparison of
Technological Characteristics: Space Chamber Plus Traditional 510(k)
| Technology | Space Chamber<br>Plus and Compact<br>Space Chamber<br>Plus* | AeroChamber<br>Plus Flow-Vu<br>Anti-static valved<br>holding chamber | Comparison |
|--------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Valve | Cross Slit Valve<br>Technology:<br>Confirms a secure<br>seal if the valve<br>opens as the<br>patient inhales<br>and closes as the<br>patient exhales<br>(as observed<br>through the clear<br>transparent body<br>of the spacers)<br>indicating proper<br>inhalation<br>technique. | Flow-Vu indicator:<br>Confirms a secure<br>seal if the<br>indicator moves<br>indicating proper<br>inhalation<br>technique. | Both technologies<br>provide an<br>indication of<br>proper inhalation<br>technique. |
| Inhaler base | The orifice in the<br>overmould<br>component is<br>compatible with<br>all standard types<br>of metered dose<br>inhalers. | Orifice in the<br>backpiece or<br>inhaler base<br>allows insertion<br>of metered dose<br>Inhalers. Flow<br>Signal whistle<br>sound when<br>inhaling too<br>quickly | Patients inhale<br>the amount of<br>drug within the<br>holding chamber.<br>Particle size<br>testing confirms<br>the proposed<br>device delivers an<br>equivalent<br>amount of<br>respirable<br>fraction<br>compared to the<br>predicate (see<br>report in) |
The technological characteristics of the new devices are similar to the legally marketed predicate as summarised below:
The Space Chamber Plus, Compact Space Chamber Plus and the predicate all use a holding chamber and one-way valve system through which metered dose inhaler medication passes to the patient.
Particle size distribution testing confirms the substantial equivalence of respirable dose delivered to the patient between the proposed devices and the predicate.
Clinical Data:
The use of Valved Holding Chambers to assist with the administration of aerosolized medication is proven technology and is well accepted by the medical community. Non-clinical data is sufficient to demonstrate the safety and efficacy of the Space Chamber Plus and Compact Space Chamber Plus devices.
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Space Chamber Plus Traditional 510(k)
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## Non-clinical Performance Data:
Evaluation of the new device and the predicate device was performed in accordance with the relevant sections of the CDRH Guidance Document "Reviewers Guidance for Nebulizers, Metered Dose Inhalers, Spacers and Actuators" (FDA/CDRH/ODF/DCRD/ADDB -1993).
Particle size distribution testing was performed using 3 drug classes ipratropium bromide (anti-cholinergic bronchodilator), albuterol (beta-agonist bronchodilator) and beclomethasone dipropionate (anti-inflammatory) comparing the Space Chamber Plus and Compact Space Chamber Plus with the predicate. The respirable fraction delivered by the spacers is greater than that delivered by the pMDI alone. The respirable fractions delivered by the Space Chamber Plus and Compact Space Chamber Plus are equivalent to those delivered by the predicate, Aerochamber Plus Flow Vu Anti-static. Likewise, the MMAD values obtained with Space Chamber Plus and Compact Space Chamber Plus are comparable to those obtained with Aerochamber Plus Flow Vu Antistatic. The 95% Cl is narrow for both the respirable fraction and MMAD results, indicating that medication doses can be consistently delivered by the spacers. Particle size distribution testing confirms the proposed devices to be substantially equivalent to the predicate device.
| Device | Particle size,<br>Mean MMAD,<br>μm<br>(95% CI) | Mean total<br>respirable dose,<br>μg<br>(95% CI) | Mean respirable<br>fraction<br>PF% 0.5-4.7<br>(95% CI) |
|-----------------------------------------|------------------------------------------------|--------------------------------------------------|--------------------------------------------------------|
| Albuterol | | | |
| Albuterol pMDI | 2.6 (0.11) | 347.1 (43.3) | 79.7 (3.3) |
| Space Chamber Plus | 2.5 (0.04) | 286.9 (36.3) | 86.1 (0.9) |
| Compact Space<br>Chamber Plus | 2.3 (0.05) | 253.4 (38.7) | 88.0 (0.6) |
| Aerochamber Plus<br>Flow Vu Anti-static | 2.4 (0.03) | 292.2 (19.2) | 87.6 (0.7) |
| Ipratropium Bromide | | | |
| Ipratropium<br>Bromide pMDI | 0.72 (0.06) | 51.14 (2.8) | 54.7 (1.7) |
| Space Chamber Plus | 0.93 (0.05) | 85.26 (3.3) | 65.3 (0.9) |
| Compact Space<br>Chamber Plus | 0.80 (0.02) | 65.19 (2.1) | 61.9 (0.7) |
| Aerochamber Plus<br>Flow Vu Anti-static | 0.76 (0.05) | 55.28 (3.0) | 60.0 (1.8) |
| Beclomethasone Dipropionate | | | |
| Beclomethasone<br>Dipropionate pMDI | 1.4 (0.07) | 218.12 (16.3) | 77.3 (2.4) |
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| Space Chamber Plus | 1.3 (0.02) | 328.05 (9.9) | 82.7 (0.8) |
|-----------------------------------------|------------|---------------|------------|
| Compact Space<br>Chamber Plus | 1.3 (NA^) | 308.29 (12.7) | 83.7 (1.0) |
| Aerochamber Plus<br>Flow Vu Anti-static | 1.3 (0.03) | 316.25 (17.6) | 83.9 (1.1) |
^ Not applicable (NA) when results for each individual run is the same
Particle size distribution testing was repeated post-cleaning. Performance testing demonstrates that the post-washed Space Chamber Plus and Compact Space Chamber Plus remain equivalent to the pre-washed devices and to the predicate device.
Other performance testing includes materials characterization, particulate analysis, drop test and cleaning validation.
ISO 10993 testing has been performed on the Space Chamber Plus components, including Cytotoxicity, Sensitization, Irritation, Genotoxicity and Implantation tests. The Space Chamber Plus and Compact Space Chamber Plus devices are made of identical materials; the Compact Space Chamber Plus is a smaller version of the Space Chamber Plus that allows for easier storage and handling.
Non-clinical and performance testing demonstrates that the Space Chamber Plus and Compact Space Chamber Plus devices raise no new issues of safety or effectiveness compared to the legally marketed predicate device.
Substantial Equivalence Conclusion:
The new devices, the Space Chamber Plus and Compact Space Chamber Plus, are considered to be substantially equivalent to the predicate device based on the following:
- . they have the same intended use and are indicated for the same user population:
- they have equivalent technological characteristics to the predicate: ●
- they do not raise any new questions of safety or effectiveness; .
- they are at least as safe and effective as the predicate. .
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## DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
November 13, 2013
Medical Developments International Limited Maggie Oh Director, Scientific Affairs 7/56 Smith Road Springvale Victoria 3171 Australia
Re: K122252
Trade/Device Name: Space Chamber Plus Compact Space Chamber Regulation Number: 21 CFR 868.5630 Regulation Name: Nebulizer Regulatory Class: Class II Product Code: NVP Dated: November 8, 2013 Received: November 12, 2013
Dear Ms. Oh:
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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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 Small Manufacturers, International and Consumer Assistance at its tollfree 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/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance 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 yours.
MarySTBmer -S
Kwame Ulmer M.S. Acting Division Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control and Dental Devices Office of Evaluation Center for Device and Radiological Health
Enclosure
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## Indications for Use
510(k) Number (if known): KIZZZZZ
Device Name: Space Chamber Plus
Indications for Use:
The Space Chamber Plus is intended to be used by patients who are under the care or treatment of a licensed health care provider or physician. The device is intended to be used by these patients to administer aerosolized medication from most pressurized Metered Dose Inhalers, prescribed by a physician or health care professional. The intended environments for use include home, hospitals and clinics.
Device Name: Compact Space Chamber Plus
Indications for Use:
The Compact Space Chamber Plus is intended to be used by patients who are under the care or treatment of a licensed health care provider or physician. The device is intended to be used by these patients to administer aerosolized medication from most pressurized Metered Dose Inhalers, prescribed by a physician or health care professional. The intended environments for use include home, hospitals and clinics.
Prescription Use (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Image /page/6/Picture/13 description: The image shows the text "Nayan J. Patel - S" in the top row. Below that, the text "2013.11.13 12:03:43 -05'00'" is displayed. The text appears to be a timestamp or a date and time record, possibly extracted from a document or a system log.
Page 1 of 1
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.