DreamStation 2 System, DreamStation 2 Advanced System
Applicant
Respironics, Inc.
Product Code
BZD · Anesthesiology
Decision Date
Jul 10, 2020
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 868.5905
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The DreamStation 2 CPAP/DreamStation 2 Auto CPAP system delivers positive airway pressure therapy for the treatment of Obstructive Sleep Apnea in spontaneously breathing patients weighing over 30 kg (66 lbs). It is for use in the home or hospital/institutional environment.
Device Story
Microprocessor-controlled blower system; treats Obstructive Sleep Apnea (OSA) via CPAP or Auto CPAP therapy. Inputs: patient breathing signals; device detects apneas/hypopneas to adjust pressure automatically (Auto CPAP mode). Outputs: positive airway pressure delivered to patient via mask/tubing. Used in home or hospital/institutional settings; operated by patient or clinician. Features include Ramp Plus, pressure relief (FLEX), EZ-Start, Opti-Start, and humidification. Integrated Bluetooth/cellular connectivity transfers patient compliance data to Care Orchestrator software. Output allows clinicians to monitor therapy adherence and adjust settings; benefits patient by maintaining airway patency during sleep.
Clinical Evidence
No clinical data. Safety and effectiveness established via non-clinical bench testing, including software verification/validation (IEC 62304), biocompatibility (ISO 10993-1, ISO 18562-1), electrical safety/EMC (IEC 60601 series), and human factors/usability engineering (IEC 62366-1).
Technological Characteristics
Microprocessor-controlled blower; CPAP/Auto CPAP modes; 4-20 cm H2O pressure range. Connectivity: Bluetooth, cellular. Power: AC (100-240 VAC) or battery pack. Standards: ISO 80601-2-70, ISO 80601-2-74. Software: Moderate level of concern. Biocompatible materials per ISO 10993-1/ISO 18562-1.
Indications for Use
Indicated for treatment of Obstructive Sleep Apnea (OSA) in spontaneously breathing patients weighing >30 kg (66 lbs).
Regulatory Classification
Identification
A noncontinuous ventilator (intermittent positive pressure breathing-IPPB) is a device intended to deliver intermittently an aerosol to a patient's lungs or to assist a patient's breathing.
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July 10, 2020
Respironics, Inc. Andy Zeltwanger Director, Regulatory Affairs 1740 Golden Mile Highway Monroeville, Pennsylvania 15146
Re: K200480
Trade/Device Name: DreamStation 2 System Regulation Number: 21 CFR 868.5905 Regulation Name: Noncontinuous Ventilator (IPPB) Regulatory Class: Class II Product Code: BZD Dated: June 12, 2020 Received: June 12, 2020
Dear Andy Zeltwanger:
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 statutes and regulations administered by other Federal agencies. You must comply with all the Act's
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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 (OS) 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 mediation-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 Michael Ryan 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 Quality Center for Devices and Radiological Health
Enclosure
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## Indications for Use
510(k) Number (if known) K200480
Device Name DreamStation 2 System
Indications for Use (Describe)
The DreamStation 2 CPAP/DreamStation 2 Auto CPAP system delivers positive airway for the treatment of Obstructive Sleep Apnea in spontaneously breathing patients weighing over 30 kg (66 lbs). It is for use in the home or hospital/institutional environment.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------|-------------------------------------|
| Prescription Use (Part 21 CFR 801 Subpart D) | <input checked="" type="checkbox"/> |
| Over-The-Counter Use (21 CFR 801 Subpart C) | <input type="checkbox"/> |
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### Section 5: 510(k) Summary
Pursuant to the requirements of 21 CFR Section 807.92(c), this 510(k) summary is being provided as part of the DreamStation 2 System 510(k) Premarket Notification.
### Submitter
| 510(k) Owner | Respironics, Inc.<br>1001 Murry Ridge Lane<br>Murrysville, PA 15668 |
|---------------------------------------|------------------------------------------------------------------------------------------------------|
| Official Correspondent | Andy Zeltwanger<br>Director, Regulatory Affairs<br>P: 724-579-6095<br>E: andy.zeltwanger@philips.com |
| Date of Preparation | 26 February 2020 |
| Device | |
| Proprietary/Trade Name: | DreamStation 2 System |
| Common/Usual Name: | CPAP System |
| Device Classification: | II |
| Classification Name/<br>Product Code: | Ventilator, Non-Continuous (Respirator), 21 CFR 868.5905<br>BZD |
| Primary Predicate Device: | REMSTAR AUTO A-FLEX HT (K131982) |
Secondary Predicate Device: REMSTAR SE (K130077)
Submission Reason: New Device
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### Device Description
The DreamStation 2 System uses a microprocessor-controlled blower to treat patients with Obstructive Sleep Apnea (OSA). There are 2 models:
- DreamStation 2
- . DreamStation 2 Advanced
Both aforementioned models will be available in two therapy modes: CPAP only and Auto CPAP. With CPAP therapy, the device provides a continuous positive airway pressure throughout the entire therapy session. With Auto CPAP therapy, the device provides a positive airway pressure that automatically adjusts to the patient's needs as various breathing events are detected, such as apneas and hypopneas.
In addition to the therapy modes, the DreamStation 2 System provides several optional features to aid with patient comfort. These patient comfort features include: Ramp Plus, adjustable pressure relief (FLEX), EZ-Start, Opti-Start, and humidification (adaptive and adaptive with heated tube). Note: some of the features are only available in the DreamStation 2 Advanced model.
The DreamStation 2 device also features integrated Bluetooth and cellular technology for the transfer of patient management data between the therapy device and Respironics proprietary compliance software, Care Orchestrator.
### Indications for Use
The DreamStation 2 CPAP/DreamStation 2 Auto CPAP system delivers positive airway pressure therapy for the treatment of Obstructive Sleep Apnea in spontaneously breathing patients weighing over 30 kg (66 lbs). It is for use in the home or hospital/institutional environment.
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# Comparison of Technological Characteristics with the Predicate Device(s)
| | Table 5-1. High-Level Comparison of DreamStation 2 Device to Primary and Secondary Predicates | |
|--|-----------------------------------------------------------------------------------------------|--|
| | | |
| Feature/Function | Device Predicate 1:<br>REMstar Auto A-<br>Flex HT (K131982) | Device Predicate 2:<br>REMstar SE<br>(K130077) | Subject Device:<br>DreamStation 2<br>CPAP/Auto CPAP | Subject Device:<br>DreamStation 2<br>Advanced<br>CPAP/Auto CPAP | Similarities and/or<br>Differences |
|---------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------|
| Intended Use | For the treatment of | For the treatment of | For the treatment of | For the treatment of | Same. |
| | Obstructive Sleep | Obstructive Sleep | Obstructive Sleep | Obstructive Sleep | |
| | Apnea (OSA) | Apnea (OSA) | Apnea (OSA) | Apnea (OSA) | |
| Patient | Spontaneously | Spontaneously | Spontaneously | Spontaneously | Same. |
| Population (age, | breathing patients | breathing patients | breathing patients | breathing patients | |
| gender, etc.) | >30 kg (66 lbs) | >30 kg (66 lbs) | >30 kg (66 lbs) | >30 kg (66 lbs) | |
| Principle of | Microprocessor | Microprocessor | Microprocessor | Microprocessor | Same. |
| Operation | controlled motor | controlled motor | controlled motor | controlled motor | |
| | blower design | blower design | blower design | blower design | |
| Product Specific | ISO 17510-1 | ISO 17510-1 | ISO 80601-2-70 | ISO 80601-2-70 | Same. |
| Performance | ISO 8185 | ISO 8185 | ISO 80601-2-74 | ISO 80601-2-74 | |
| Standards | | | Note: ISO 80601-2-70<br>has since replaced<br>ISO 17510-1 and ISO<br>80601-2-74 has since<br>replaced ISO 8185. | Note: ISO 80601-2-70<br>has since replaced<br>ISO 17510-1 and ISO<br>80601-2-74 has since<br>replaced ISO 8185. | |
| Therapy<br>Algorithm and<br>Flex Waveform<br>Comparison | Substantially<br>Equivalent Results | Not Available | Substantially<br>Equivalent Results | Substantially<br>Equivalent Results | Same. |
| Energy Delivered | Continuous Positive<br>Airway Pressure<br>(CPAP) | Continuous Positive<br>Airway Pressure<br>(CPAP) | Continuous Positive<br>Airway Pressure<br>(CPAP) | Continuous Positive<br>Airway Pressure<br>(CPAP) | Same. |
| Feature/Function | Device Predicate 1:<br>REMstar Auto A-<br>Flex HT (K131982) | Device Predicate 2:<br>REMstar SE<br>(K130077) | Subject Device:<br>DreamStation 2<br>CPAP/Auto CPAP | Subject Device:<br>DreamStation 2<br>Advanced<br>CPAP/Auto CPAP | Similarities and/or<br>Differences |
| Energy Source | External Switching<br>Power Supply<br>AC Power (Input):<br>100 – 240 VAC<br>DC Power (Output):<br>12 VDC | External Switching<br>Power Supply<br>AC Power (Input):<br>100 – 240 VAC<br>DC Power (Output):<br>12 VDC | External Switching<br>Power Supply<br>AC Power (Input):<br>100 – 240 VAC<br>DC Power (Output):<br>12 VDC<br>Battery Pack<br>Voltage Range<br>(Input): 11.0-14.4<br>VDC<br>Voltage Range<br>(Output): 11.0-15.0<br>VDC | External Switching<br>Power Supply<br>AC Power (Input):<br>100 – 240 VAC<br>DC Power (Output):<br>12 VDC<br>Battery Pack<br>Voltage Range<br>(Input): 11.0-14.4<br>VDC<br>Voltage Range<br>(Output): 11.0-15.0<br>VDC | Similar. Subject<br>device includes<br>additional power<br>source via a battery<br>pack. |
| Modes of<br>Operation | • CPAP<br>• Auto CPAP<br>o Split<br>Night with<br>Auto<br>CPAP<br>o Auto-Trial<br>o CPAP-<br>Check | • CPAP | • CPAP<br>• Auto CPAP | • CPAP<br>• Auto CPAP<br>o Auto-Trial<br>o CPAP-<br>Check | Similar. Varies<br>depending on model. |
| Pressure | 4 to 20 cm H2O | 4 to 20 cm H2O | 4 to 20 cm H2O | 4 to 20 cm H2O | Same. |
| Feature/Function | Device Predicate 1:<br>REMstar Auto A-<br>Flex HT (K131982) | Device Predicate 2:<br>REMstar SE<br>(K130077) | Subject Device:<br>DreamStation 2<br>CPAP/Auto CPAP | Subject Device:<br>DreamStation 2<br>Advanced<br>CPAP/Auto CPAP | Similarities and/or<br>Differences |
| Pressure<br>Accuracy (Static) | $\pm$ 0.5 cm H2O | $\pm$ 1.0 cm H2O | For 15mm and 22mm<br>tubing:<br>$\pm$ 0.5 cm H2O<br><br>For 12mm tubing:<br>$\pm$ 1.0 cm H2O for<br>12mm tubing. | For 15mm and 22mm<br>tubing:<br>$\pm$ 0.5 cm H2O<br><br>For 12mm tubing:<br>$\pm$ 1.0 cm H2O for<br>12mm tubing. | Same.<br>15mm is same as<br>Primary Predicate<br>(K131982).<br>12mm is same as<br>Secondary Predicate<br>(K130077). |
| Pressure<br>Accuracy<br>(Dynamic) | $\pm$ 1.0 cm H2O of the<br>pressure values<br>established during<br>verification of the<br>Static Pressure<br>accuracy | Device:<br>$\pm$ 2.0 cm H2O<br><br>Device w/ Humidifier<br>(22mm Tubing):<br>$\pm$ 2.0 cm H2O<br><br>Device w/ Humidifier<br>(15mm Tubing):<br>+ 2.5 cm H2O | For 15mm and 22mm<br>tubing:<br>$\pm$ 1.0 cm H2O<br><br>For 12mm tubing:<br>$\pm$ 2.0 cm H2O | For 15mm and 22mm<br>tubing:<br>$\pm$ 1.0 cm H2O<br><br>For 12mm tubing:<br>$\pm$ 2.0 cm H2O | Same.<br>15mm is the same as<br>Primary Predicate<br>(K131982).<br>12mm the same<br>Secondary Predicate<br>(K130077). |
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# Section 5: 510(k) Summary
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# Section 5: 510(k) Summary
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# Section 5: 510(k) Summary
| Feature/Function | Tube Predicate:<br>REMstar Auto A-Flex HT<br>(K131982) | Subject Device:<br>15mm Heated Tube and 12mm<br>Heated Tube | Similarities and/or<br>Differences |
|------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------|
| Intended Use | The heated tube is used, along<br>with the heated humidifier, to<br>control the provided<br>humidification. This is<br>accomplished by controlling the<br>temperature of the air in order to<br>ensure that it does not cool down<br>prior to reaching the mask. | The heated tube is used, along<br>with the heated humidifier, to<br>control the provided<br>humidification. This is<br>accomplished by controlling the<br>temperature of the air in order to<br>ensure that it does not cool down<br>prior to reaching the mask. | Same. |
| Target Patient<br>Population | Patients weighing more than 66<br>lb (30 kg) | Patients weighing more than 66<br>lb (30 kg) | Same. |
| Energy Used or<br>Delivered | Due to the wire resistance, heat is<br>dissipated through the wall of the<br>tube construction into the air<br>flow in the lumen of the tubing.<br>As a result, the air passing<br>through the tubing is warmed to<br>or above the dew point (of the air<br>existing the humidifier) reducing<br>or eliminating water<br>condensation and/or pooling of<br>water in the breathing circuit.<br>The raising of the gas<br>temperature does not exceed | Due to the wire resistance, heat is<br>dissipated through the wall of the<br>tube construction into the air<br>flow in the lumen of the tubing.<br>As a result, the air passing<br>through the tubing is warmed to<br>or above the dew point (of the air<br>existing the humidifier) reducing<br>or eliminating water<br>condensation and/or pooling of<br>water in the breathing circuit.<br>The raising of the gas<br>temperature does not exceed | Same. |
| Feature/Function | Tube Predicate:<br>REMstar Auto A-Flex HT<br>(K131982) | Subject Device:<br>15mm Heated Tube and 12mm<br>Heated Tube | Similarities and/or<br>Differences |
| | 41°C. | 41°C. | |
| Mode of Action | Applied voltage through heating wires | Applied voltage through heating wires | Same. |
| Power Source | Power supplied by attached therapy device | Power supplied by attached therapy device | Same. |
| Tube Diameter (inner) | 15 mm | 15mm and 12mm | Similar.<br>Modification:<br>Addition of 12mm<br>Tubing (Heated and<br>Non-Heated) |
Table 5-2. High-Level Comparison of Subject Heated Tube (15mm and 12mm) to Predicate Device
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# Section 5: 510(k) Summary
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### Performance Testing Data
### Non-Clinical Tests
### Performance Testing
Appropriate testing was completed on the DreamStation 2 System to address: all device requirements, any mitigations required per the risk assessment, to show substantial equivalence to the predicate(s), and lastly to provide reasonable assurance of safety and efficacy.
### Software Testing
The DreamStation 2 software was developed following IEC 62304:2015, "Medical Device Software - Software Life Cycle Processess". Software verification and validation testing was performed on the DreamStation 2 System based on the product requirements. Testing was conducted and documentation has been provided, as recommended by FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices", issued May 2005.
This software is considered to have a "Moderate" level of concern, since prior to mitigation of hazards, a failure of the device could potentially result in minor injury to patient or user of the device. Additionally, a malfunction of, or a latent design flaw in the device, could lead to a delay of appropriate medical care that could potentially lead to a minor injury.
The testing included system level testing to verify all required functionality of the DreamStation 2 System.
### Biocompatibility Testing
The biocompatibility evaluation, for the DreamStation 2 System, was conducted in accordance with FDA Guidance, "Use of International Standard ISO 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process",ISO 10993-1 "Biological Evaluation of Medical Devices – Part 1: Evaluation and Testing within a Risk Management Process", and ISO 18562-1 "Biocompatibility Evaluation of Breathing Gas Pathways in Healthcare Applications – Part 1: Evaluation and Testing within a Risk Management Process", as recognized by FDA. The DreamStation 2 System has proven to be biocompatible when tested in its final, finished, form to both ISO 10993-1:2018 and ISO 18562-1:2017.
### General Safety, Electrical Safety and Electromagnetic Compatibility (EMC)
General Safety, Electrical Safety, and Electromagnetic Compatibility testing was conducted on the DreamStation 2 System. The system complies with the following standards:
- AAMI/ANSI/ES 60601-1:2005/A1:2012
- IEC 60601-1-2:2014
- IEC 60601-1-6:2013
- IEC 60601-1-11:2015
- · ISO 80601-2-61: 2011
- ISO 80601-2-70: 2015
- ISO 80601-2-74: 2017
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### Human Factors/Usability
The DreamStation 2 System has been found to be safe and effective for the intended users, uses, and use environments. The Human Factors/Usability Engineering process, followed for the development of this device, aligns with IEC 62366-1: 2015. "Medical Devices - Part 1: Application of Usability Engineering to Medical Devices", and the latest applicable FDA guidance, "Applying Human Factors and Usability Engineering to Medical Devices", issued February 2016.
Results of following this process, in particular the results of the human factors validation study, indicate that intended users can operate the device safely and effectively, and that residual risk associated with use of the device is acceptable.
### Clinical Tests
Clinical tests were not required to demonstrate the safety and effectiveness of the DreamStation 2 System. Safety and efficacy of the DreamStation 2 System has been established via nonclinical tests.
### Substantial Equivalence Conclusion
Based upon the intended use, design, materials, function, side by side analysis with its predicates, and verification and validation testing, it is concluded that the DreamStation 2 System is substantially equivalent to the aforementioned predicate devices. The modifications between the DreamStation 2 System and its predicate devices do not raise any new questions regarding the safety and effectiveness.
This "510k Notification" demonstrates that the DreamStation 2 System is substantially equivalent to its predicate devices, which are currently marketed under the Federal Food, Drug, and Cosmetic Act.
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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.