THE BREATHER INSPIRATORY/EXPIRATORY MUSCLE TRAINER

K972824 · Pn Medical · BWF · Apr 3, 1998 · Anesthesiology

Device Facts

• Record ID: K972824
• Device Name: THE BREATHER INSPIRATORY/EXPIRATORY MUSCLE TRAINER
• Applicant: Pn Medical
• Product Code: BWF · Anesthesiology
• Decision Date: Apr 3, 1998
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 868.5690
• Device Class: Class 2
• Attributes: Therapeutic

Indications for Use

The new intended use of this product is to assist the patient in the coordination of breathing during nebulization treatments via hooking the device up with medication delivery systems. i.e., metered dose inhalers, electronic nebulization therapy. It is to be used in addition to and not in place of the delivery device provided by the manufacturer.

Device Story

The Breather is an accessory device designed to assist patients in coordinating breathing during nebulization therapy. It connects to medication delivery systems, such as metered dose inhalers or electronic nebulizers, to facilitate proper inhalation technique. The device is intended for use in conjunction with, not as a replacement for, the manufacturer-provided delivery system. It serves as a respiratory aid to improve the efficacy of medication delivery by ensuring better patient-device synchronization during treatment.

Clinical Evidence

No clinical data provided; bench testing only.

Technological Characteristics

Mechanical respiratory training/coordination device. Connects to standard medication delivery systems (metered dose inhalers, electronic nebulizers). No electronic components, software, or power source.

Indications for Use

Indicated for patients requiring assistance with breathing coordination during nebulization treatments using metered dose inhalers or electronic nebulization therapy.

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.

Predicate Devices

• The Breather (K944412)

Submission Summary (Full Text)

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Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

APR - 3 1000

Ms. Peggy Nicholson PN Medical, Inc. 214 N. Goldenrod Road, Suite 6 Orlando, FL 32807

Re: K972824 The Breather (Inspiratory/Expiratory Muscle Trainer Regulatory Class: II (two) Product Code: 73 BWF Dated: January 9, 1998 Received: January 12, 1998

Dear Ms. Nicholson:

We have reviewed your Section 510(k) notification of intent to market the device referenced above and we have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.

If your device is classified (see above) into either class II (Special Controls) or class III (Premarket Approval), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 A substantially equivalent determination assumes compliance to 895. with the current Good Manufacturing Practice requirements, as set forth in the Quality System Regulation (QS) for Medical Devices: General regulation (21-CFR-Part 820) and that, through periodic (QS) ========================================================================================================= inspections, the Food and Drug Administration (FDA) will verify such assumptions. Failure to comply with the GMP regulation may result in requlatory action. In addition, FDA may publish further announcements concerning your device in the Federal Register. Please note: this response to your premarket notification submission does not affect any obligation you might have under sections 531 through 542 of the Act for devices under the Electronic Product Radiation Control provisions, or other Federal laws or regulations.

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## Page 2 - Ms. Peggy Nicholson

This letter will allow you to begin marketing your device as described in your 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at [phone]. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at [phone]. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers Assistance at its toll-free number [phone] or [phone] or at its internet address "http://www.fda.gov/cdrh/dsmamain.html".

Sincerely yours,

sincerely yours,

Thomas J. Callahon

Thomas J. Callahan, Ph.D. Director Division of Cardiovascular, Respiratory, and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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| 510(k) Number (if known): | Seeking new # - Original # K944412 |
|---------------------------|------------------------------------|
| Device Name: | The Breather |

Indications For Use:

The new intended use of this product is to assist the patient in the coordination of breathing during nebulization treatments via hooking the device up with medication delivery systems. i.e., metered dose inhalers, electronic nebulization therapy. It is to be used in addition to and not in place of the delivery device provided by the manufacturer.

(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

| (Division Sign-Off) | |
|-------------------------------------------------------------------|---------|
| Division of Cardiovascular, Respiratory, and Neurological Devices | |
| 510(k) Number | K972824 |

| Prescription Use (Per 21 CFR 801.109) | |
|---------------------------------------|--|
|---------------------------------------|--|

OR

| Over-The-Counter Use | |
|----------------------|--|
|----------------------|--|

(Optional Formal 1-2-96)

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