An example report, for a made-up over-the-counter pulse oximeter. The PDF is what arrives by email. Get one for your device.
Pathway report
A fingertip pulse oximeter sold over the counter at pharmacies and online. Adults with COPD use it at home to spot-check their blood oxygen level and pulse rate, and call their doctor if the reading drops. Two AAA batteries, reusable, no alarms, no app.
Draft Prepared by software from FDA records on 2026-09-24 and read by a second model. It proposes; a regulatory professional decides. Not regulatory advice.
You show FDA the device is substantially equivalent to one already on the market: the same intended use, and technology that raises no new questions of safety and effectiveness.
Small business rate. Qualify first, then pay: send FDA Form 3602N with your latest tax return (and any affiliates') through the CDRH Portal. FDA aims to decide within 60 days, and the status lasts one fiscal year, to September 30, so apply in the year you submit. How to apply
Sources: FDA user fees for FY2027 (Federal Register, July 30, 2026), MDUFA V performance goals, FDA small business program.
We assumed: The stated spot-check use is intermittent rather than continuous monitoring. The device measures oxygen saturation optically through a fingertip, as is inherent in the described pulse oximeter type.
4 facts could change this report. Answer any of them, in any order, and send: we email you an updated report.
High could change the product code or the pathwayMedium could change the devices to compare with, the standards or the testsLow fills in a detail
MediumWhat oxygen-saturation accuracy will you claim, and over what range?
Within 2% from 70 to 100% · Within 3% from 70 to 100% · Not decided yet
MediumWhat ages will the label say it is for?
Adults 18 and over · Adults and teenagers 12 and over · Anyone over 30 kg
MediumWill the label claim anything beyond spot checks and calling a doctor?
Spot checks only · Spot checks and tracking trends over time · Spot checks during exercise or at altitude
LowWhat does the screen show besides the two numbers?
Only SpO2 and pulse rate · The numbers and a signal-strength bar · The numbers and a low-battery sign
On your own report, you can add what was left out here and get an updated report.
The first 3 of 13 checks a regulatory consultant would make, in the order of the report.
OLK (pulse oximeter for over-the-counter use) specifically covers a non-wearable fingertip pulse oximeter used OTC for non-continuous monitoring, matching the stated device and use. High
| Code | Device name | Fits? | What distinguishes it |
|---|---|---|---|
| QWE | Hyperoxia Monitoring Device Adjunct To Pulse Oximetry21 CFR 870.2720 · Class 2 · 510(k) | no | QWE (hyperoxia monitoring device adjunct to pulse oximetry) monitors elevated hemoglobin oxygen saturation as an adjunct, while this device spot-checks oxygen saturation and pulse rate. High |
| QYU | Infant Pulse Rate And Oxygen Saturation Monitor For Over-The-Counter Use21 CFR 870.2705 · Class 2 · 510(k) | no | QYU (infant pulse rate and oxygen saturation monitor for OTC use) is intended for infants, while the stated users are adults with COPD. High |
| OLK | Pulse Oximeter For Over-The-Counter Use21 CFR 870.2700 · Class 2 · 510(k) | yes | The proposed code, for the reason above. High |
| MUD | Oximeter, Tissue Saturation21 CFR 870.2700 · Class 2 · 510(k) | no | MUD (oximeter, tissue saturation) is exemplified by devices measuring regional tissue saturation, while this device is described as measuring blood oxygen saturation at a fingertip. High |
| QVT | Monitor For Opioid Induced Impairment Of Oxygenation21 CFR 868.2250 · Class 2 · 510(k) | no | QVT (monitor for opioid induced impairment of oxygenation) detects desaturations resulting from opioid overdose, a purpose not stated for this COPD spot-check device. High |
| OUW | Infant Positioner, Rx, Use In Highly Monitored Setting21 CFR 880.5680 · Class 1 · 510(k) | no | OUW (infant positioner, Rx, use in highly monitored setting) is an infant positioning device rather than an oximeter. High |
| MMA | Oximeter, Fetal PulseClass 3 · PMA | no | MMA (oximeter, fetal pulse) concerns fetal oxygen saturation monitoring, while the stated users are adults. High |
| NMD | Oximeter, Tissue Saturation, Reprocessed21 CFR 870.2700 · Class 2 · 510(k) | no | NMD (oximeter, tissue saturation, reprocessed) is for reprocessed devices, and this product is described as a reusable device rather than a reprocessed device. High |
| PGJ | Oximeter, Wellness21 CFR 870.2700 · Class 2 · Enforcement discretion | no | PGJ (oximeter, wellness) is for wellness use, while this device is intended for adults with COPD to monitor blood oxygen and contact their doctor when a reading drops. High |
| DQA | Oximeter21 CFR 870.2700 · Class 2 · 510(k) | maybe | DQA (oximeter) is a broader oximeter code that covers related pulse oximeters, but OLK is preferred because its definition specifically matches OTC fingertip, non-continuous use. High |
| QEM | Cerebral Oximeter21 CFR 870.2700 · Class 2 · 510(k) | no | QEM (cerebral oximeter) measures cerebral tissue saturation, not fingertip blood oxygen saturation. High |
| KLK | Monitor, Oxygen, Cutaneous, For Infant Not Under Gas Anesthesia21 CFR 868.2500 · Class 2 · 510(k) exempt | no | KLK (monitor, oxygen, cutaneous, for infant not under gas anesthesia) uses a heated skin sensor to monitor cutaneous oxygen tension, not fingertip pulse oximetry. High |
| CCE | Analyzer, Gas, Oxygen, Partial Pressure, Blood-Phase, Indwelling21 CFR 868.1200 · Class 2 · 510(k) | no | CCE (indwelling blood oxygen partial pressure analyzer) measures in-vivo blood oxygen partial pressure with a catheter-tip transducer, not fingertip oxygen saturation. High |
| NLF | Oximeter, Reprocessed21 CFR 870.2700 · Class 2 · 510(k) | no | NLF (oximeter, reprocessed) is for reprocessed oximeters, whereas the description does not identify this product as reprocessed. High |
| DQE | Catheter, Oximeter, Fiber-Optic21 CFR 870.1230 · Class 2 · 510(k) | no | DQE (fiberoptic oximeter catheter) estimates blood oxygen saturation using a catheter, unlike this external fingertip device. High |
| OCH | Oximeter, Infrared, Sporting, Aviation21 CFR 870.2700 · Class 2 · Enforcement discretion | no | OCH (oximeter, infrared, sporting, aviation) is solely for sporting and aviation activities, while this product is intended for home medical monitoring by adults with COPD. High |
Proposed: 510(k). OLK is Class II and not 510(k) exempt, and its definition expressly covers OTC fingertip pulse oximetry for non-continuous monitoring; the described medical use falls within that intended-use category. High
| If | Then |
|---|---|
| The labeled use were limited to wellness without a medical purpose. | Reassess whether the product is a medical device and whether PGJ (oximeter, wellness) is the relevant reference. Medium |
| The device were intended for continuous monitoring or for a different patient population or clinical purpose. | Reassess whether OLK still covers the intended use and whether another product code is more appropriate. Medium |
Ranked by closeness of intended use, then technology and recency; kept predicates have summaries in the FDA records. K211498 and K214115 are OLK OTC fingertip spot-check predicates, while the DQA examples provide related technical and safety comparisons. The summaries for K211498, K214115, K252805 and K252448 are available; no higher-ranked candidate lacks a summary.
| # | Device, as named in the record | Why kept |
|---|---|---|
| 1 | K211498 Nonin OTC Pulse Oximeter Model 3250Nonin Medical, Inc. · 2024-11-13 · Cleared · Summary | Nonin Model 3250 OTC Pulse Oximeter (K211498) is an OTC fingertip pulse oximeter for adult spot-checking of SpO2 and pulse rate and is the closest match to the described intended use. High |
| 2 | K214115 MightySat -OTCMasimo Corporation · 2024-01-31 · Cleared · Summary | MightySat-OTC (K214115) is a fingertip device for OTC spot-checking of SpO2 and pulse rate in adults, with no-motion use specified. High |
| 3 | K252805 YUWELL® Finger Pulse Oximeter (YX105, YX106, YX110, YX310)Jiangsu Yuyue Medical Equipment & Supply Co., Ltd. · 2026-02-17 · Cleared · Summary | YUWELL® Finger Pulse Oximeter (K252805) is a reusable fingertip spot-check device for home and professional settings, though its stated population includes adults and children and its description does not establish the same OTC indication. High |
| 4 | K252448 AViTA Pulse Oximeter (SP61)Avita Corporation · 2026-02-27 · Cleared · Summary | AViTA Pulse Oximeter (K252448) is a spot-check device for SpO2 and pulse rate in home and professional settings, but its summary states prescription use and a broader age group. High |
| Device | Why set aside |
|---|---|
K234021 Masimo StorkMasimo Corporation · 2024-05-03 · Cleared · Summary | Masimo Stork (K234021) is a wearable infant and neonatal monitor for spot-checking and continuous monitoring, not an adult fingertip spot-check device. High |
K243324 Masimo O3 Regional OximeterMasimo Corporation · 2025-07-17 · Cleared · Summary K254129 Spectrum-2Neko Health AB · 2026-05-22 · Cleared · Summary K214072 Masimo O3 Regional Oximeter SystemMasimo Corporation · 2022-05-06 · Cleared · Summary | The listed MUD examples concern regional or tissue oxygenation, not fingertip measurement of arterial hemoglobin oxygen saturation. High |
K201976 SnapshotNIRKent Imaging · 2020-11-10 · Cleared · Summary K211561 INVOS PM7100 Patient Monitor, INVOS Pediatric rSO2 Sensor, INVOS Infant Regional Saturation Sensor (also referred to as OxyAlert NIRSensor)Covidien, LLC · 2021-12-05 · Cleared · Summary | These MUD examples concern tissue oximetry systems or sensors rather than the described OTC fingertip device. High |
K172962 Nurture RestNeonatal Loving Kare, Inc. · 2018-01-18 · Cleared · Summary | Nurture Rest (K172962) is a positioner for premature infants receiving monitored care, not an oximeter predicate. High |
K111007 MIDWEST REPROCESSING CENTER REPROCESSED LNCS SESSORS; MIDWEST REPROCESSING CENTER REPROCESSED OXIMAX SENSORS; MIDWEST REMidwest Reprocessing Center, LLC · 2011-06-08 · Cleared · Summary | The NMD clearance concerns reprocessed oximetry sensors, while this description concerns a reusable fingertip device and does not identify reprocessing. High |
K252655 Pulse Oximeter (PO-A2AO, PO-A2AT, PO-A3AO, PO-H1AO, PO-B1AO, PO-C5AO, PO-C5AT, PO-C6AO, PO-C6AT)Shenzhen Imdk Medical Technology Co., Ltd. · 2026-05-11 · Cleared · Summary K250837 Pulse OximeterShanghai Berry Electronic Tech Co., Ltd. · 2025-09-25 · Cleared · Summary K252448 AViTA Pulse Oximeter (SP61)Avita Corporation · 2026-02-27 · Cleared · Summary | These DQA clearances are less suitable than the kept OTC fingertip predicates because their summaries do not establish the same OTC intended use or, for K252448, expressly state prescription use. High |
K241758 Reprocessed RD SET Adt Pulse Oximeter Sensor (4000); Reprocessed RD SET Pdt Pulse Oximeter Sensor (4001); Reprocessed RD SET Inf Pulse Oximeter Sensor (4002); Reprocessed RD SET Adt Pulse Oximeter Sensor (4003)Stryker Sustainability Solutions · 2024-10-22 · Cleared · Summary K222019 Reprocessed RD SET Adt Pulse Oximeter Sensor (4000), Reprocessed RD SET Pdt Pulse Oximeter Sensor (4001), Reprocessed RD SET Inf Pulse Oximeter Sensor (4002), Reprocessed RD SET Adt Pulse Oximeter Sensor (4003)Stryker Sustainability Solutions · 2022-12-04 · Cleared · Summary | These NLF clearances concern reprocessed pulse oximeter sensors for continuous monitoring in hospitals and hospital-type facilities. High |
K172423 PediaSat Oximetry Catheter, PreSep Oligon Oximetry Catheter, Edwards Oximetry Central Venous Catheter (previously PreSep Oximetry Catheter)Edwards Lifescience, LLC · 2018-02-20 · Cleared · Summary K160645 PreSep Oligon Oximetry CatheterEdwards Lifesciences, LLC · 2016-06-16 · Cleared · Summary | These DQE clearances concern oximetry catheters rather than external fingertip pulse oximeters. High |
The DQA MAUDE records include reports of incorrect readings, low readings, display problems and device malfunctions, but reports are not incidence estimates and many describe bedside or neonatal use rather than OTC adult spot-checking. DQA recalls also include pulse oximeter reports involving alarms, device power cycling and display problems; those hazards merit review, but their products and use conditions are not necessarily the same as this device. Medium
Reports are what was reported, not how often problems occur. openFDA's disclaimer applies to every number.
| Record | What it says |
|---|---|
| 2936999-2026-00302MAUDE report | A report describes an abnormal SpO2 and pulse reading despite stopped breathing; the relationship to the reported death was unknown. High |
| 1282497-2026-00039MAUDE report | A report describes a newborn for whom no valid SpO2 reading was obtained for more than ten minutes despite sensor and monitor changes, which is not the stated adult use. High |
| 96862Recall | The recall concerns bedside SpO2 system alarms not heard or recognized, with potential treatment delay and patient harm; this device is described as having no alarms and for spot-check use. High |
| 94170Recall | The recall reports a potential for a pulse oximeter to power off and on, resulting in loss of monitoring. High |
| 71583Recall | The recall reports potentially missing display segments that could result in data misinterpretation. High |
| Code | Event types | Top device problems | Recalls |
|---|---|---|---|
| DQA | Malfunction 12826, Injury 585, Death 360, Other 166, (blank) 66 | Incorrect Measurement 2325, No Audible Alarm 1392, Display or Visual Feedback Problem 1110, Device Operates Differently Than Expected 825, Low Readings 753 | 16 of 128 on file shown in the trail |
Source: FDA's MAUDE and recall databases, as of the openFDA export. Recalls citing any kept 510(k): 21.
Predicate columns are included only for kept devices with summaries in the FDA records; K211498 is the primary predicate because it is the closest OTC adult fingertip spot-check match. The user-device cells are blank where the description supplies no specification; inferred optical operation is marked as such. Comparisons refer to the primary predicate and identify differences that may need validation rather than asserting substantial equivalence.
| Attribute | Your device | Primary predicateNonin OTC Pulse Oximeter Model 3250K211498 | PredicateMightySat -OTCK214115 | PredicateYUWELL® Finger Pulse OximeterK252805 | PredicateAViTA Pulse OximeterK252448 | Comparison with the primary |
|---|---|---|---|---|---|---|
| General | ||||||
| Product code and regulationHigh | Proposed OLK; 21 CFR 870.2700. | Nonin Model 3250 OTC Pulse Oximeter; the summary describes an OTC finger pulse oximeter. | MightySat-OTC; the summary describes an OTC fingertip pulse oximeter. | DQA; 21 CFR 870.2700, Class II. | DQA; 21 CFR 870.2700, Class II. | Same The proposed OLK classification is consistent with the OTC fingertip use of the primary predicate; DQA is a broader code. |
| Intended useMedium | Intermittent home spot-checking of blood oxygen and pulse rate by adults with COPD, with a doctor contacted if the reading drops. | Measures and displays functional arterial hemoglobin oxygen saturation and pulse rate for medical use without a prescription; not for diagnosis or screening of lung disease or treatment decisions. | Spot-checking of functional arterial hemoglobin oxygen saturation and pulse rate; treatment decisions should only be under healthcare-provider advice. | Reusable spot-checking device that measures and displays SpO2 and pulse rate; not suitable for continuous monitoring. | Spot-check monitoring of SpO2 and pulse rate in home and professional healthcare settings. | Different The COPD-specific user description and instruction to contact a doctor if readings drop are not stated in the primary predicate's indication; confirm that labeling does not add diagnosis or treatment-decision claims. |
| Indications for useMedium | Spot-check blood oxygen and pulse rate at home; the user contacts a doctor if the reading drops. | Spot-checking of adults 18 years and older under no-motion conditions; not intended for diagnosis or screening of lung disease or treatment decisions. | Spot-checking of individuals 18 years and older under no-motion conditions; not intended for diagnosis or screening of lung disease. | Spot-checking of adults and children weighing more than 30 kg in professional and home settings; unsuitable for continuous monitoring, motion or low perfusion. | Spot-check monitoring of adults, adolescents and children in home and professional settings under no-motion conditions. | Different The user's description adds COPD as the user population and a doctor-contact action, so the intended labeling and risk communication require review. |
| Patient populationHigh | Adults with COPD. | Individuals 18 years and older. | Individuals 18 years and older. | Adults and children weighing more than 30 kg. | Adults, adolescents and children. | Different Adults with COPD are a narrower population than the primary predicate's adult population; confirm that performance evidence supports the intended population. |
| Use environmentMedium | Home. | Spot-checking for medical use; home healthcare requirements are reported in testing. | The stated indication specifies spot-checking but does not specify a use environment in the excerpt. | Professional and home settings. | Home and professional healthcare facility settings. | Same The stated home setting is consistent with the primary predicate's home-healthcare testing and OTC use. |
| Prescription or over-the-counterHigh | Sold over the counter. | Medical use without a prescription. | Over-the-counter use. | The excerpt identifies professional and home settings but does not specify prescription status. | Prescription only. | Same OTC status matches the primary predicate; the prescription-only K252448 is a less close comparator. |
| Technology | ||||||
| Principle of operationMedium | Fingertip pulse oximetry; optical measurement is inferred from the described device type. | The summary describes a digit pulse oximeter with an SpO2 sensor and algorithm. | The summary describes a fingertip pulse oximeter using Masimo SET technology. | Red and infrared light and a photodetector measure SpO2; pulse rate is derived from the detected signal. | Red and infrared light pass through pulsatile tissue and are analyzed to determine SpO2 and pulse rate. | Same The described fingertip pulse oximeter use is consistent with the primary predicate, but the founder has not specified the optical architecture or algorithm. |
| Key componentsHigh | Two AAA batteries; fingertip device; other components not stated. | Battery-operated finger pulse oximeter with a sensor activated by insertion of a digit and a display; includes Bluetooth radio. | Fingertip pulse oximeter with a reusable sensor; the excerpt describes a color display. | LEDs and photodetector on opposite sides of the probe, with a display and two AAA alkaline batteries. | Non-invasive pulse oximeter with a display and battery power; its summary comparison lists an AAA alkaline battery. | Not stated The user description states two AAA batteries but does not specify the sensor, display or other components. |
| Performance specifications | ||||||
| SpO2 display rangeHigh | not stated | not found | not found | 0%–100%. | not found | Not stated The description gives no display range. |
| SpO2 measurement rangeHigh | not stated | not found | not found | 70%–100%. | not found | Not stated The description gives no measurement range. |
| SpO2 accuracyHigh | not stated | not found | not found | ±2% for 70%–100%; no definition below 70%. | not found | Not stated The description gives no accuracy specification. |
| SpO2 resolutionHigh | not stated | not found | not found | 1%. | not found | Not stated The description gives no resolution specification. |
| PR display rangeHigh | not stated | not found | not found | 25–250 bpm. | not found | Not stated The description gives no pulse-rate display range. |
| PR measurement rangeHigh | not stated | not found | not found | 25–250 bpm. | not found | Not stated The description gives no pulse-rate measurement range. |
| PR accuracyHigh | not stated | not found | not found | ±1% or ±1 bpm, whichever is greater. | not found | Not stated The description gives no pulse-rate accuracy specification. |
| PR resolutionHigh | not stated | not found | not found | 1 bpm. | not found | Not stated The description gives no pulse-rate resolution specification. |
| Safety and standards | ||||||
| Electrical safety and EMCHigh | not stated | The summary reports compliance with IEC 60601-1-2:2014 and home healthcare requirements under IEC 60601-1-11:2015. | not found | The summary reports IEC 60601-1, IEC 60601-1-2 and IEC 60601-1-11 testing. | The summary reports electrical safety and EMC testing and states IEC 60601-1, IEC 60601-1-2 and IEC 60601-1-11 were relied upon from K223399. | Not stated No safety or EMC testing is stated for the user's device. |
| Biocompatibility and patient-contact materialsHigh | not stated | The summary reports ISO 10993-1:2018. | not found | The summary reports ISO 10993-1:2018 and cytotoxicity, irritation and sensitization testing; it describes a fingertip cushion made of medical silicone gel. | The excerpt does not report biocompatibility results. | Not stated The device's contact materials and biocompatibility information are not stated. |
| SoftwareHigh | not stated | The summary reports ANSI AAMI IEC 62304:2006/A1:2016. | not found | The summary reports software verification and validation and Basic Documentation Level. | The excerpt does not report software testing. | Not stated The description does not state whether software is present or provide software documentation. |
| Features and design | ||||||
| PowerHigh | Two AAA batteries. | Battery operated. | not found | Two AAA alkaline batteries. | Battery powered; the summary comparison lists an AAA alkaline battery. | Different The user's two-cell configuration differs from the one AAA cell stated for K252805 and K252448; this design difference may require power and battery-safety evaluation. |
| Display and user interfaceHigh | not stated | The device displays numerical SpO2 and pulse rate. | The excerpt describes a color display. | Displays SpO2 and pulse rate on an LED/OLED screen with a visual pulse indicator. | not found | Not stated The description does not state display type or interface details. |
| ConnectivityHigh | No app; connectivity is not otherwise stated. | Includes a Bluetooth radio. | Connectivity is not stated in the excerpt. | YX110 models can transfer data wirelessly to a mobile device; the summary describes different models. | Connectivity is not stated in the excerpt. | Different The description states no app, unlike the Bluetooth-equipped K211498; the lack of connectivity does not change the described spot-check intended use. |
| Sterility and reuseMedium | Reusable. | not found | The summary describes a reusable sensor. | Non-invasive, non-sterile and reusable. | not found | Same The described reuse is consistent with K252805's reusable device and K214115's reusable sensor; sterility is not stated for the user's device. |
Blanks are blanks. Nothing in this table is guessed.
What the closest cleared devices tested, from their 510(k) summaries: a starting list for your own test plan.
| Test and standard | Reported by | What the summaries report |
|---|---|---|
| SpO2 laboratory and clinical hypoxia accuracyISO 80601-2-61:2017 | K211498 Nonin OTC Pulse Oximeter Model 3250 | The summary reports laboratory and clinical hypoxia accuracy testing and says clinical performance testing was provided; numerical results are not included in the excerpt. High |
| Clinical SpO2 accuracy and usabilityISO 80601-2-61:2017 | K211498 Nonin OTC Pulse Oximeter Model 3250 | The summary says clinical accuracy testing and user usability testing were identical to testing for its reference device and describes studies used to substantiate performance across skin pigmentation. High |
| Home healthcare electrical safety and essential performanceIEC 60601-1-11:2015 | K211498 Nonin OTC Pulse Oximeter Model 3250 | The summary reports compliance with the home healthcare collateral standard. High |
| BiocompatibilityISO 10993-1:2018 | K211498 Nonin OTC Pulse Oximeter Model 3250 K252805 YUWELL® Finger Pulse Oximeter | K211498 reports ISO 10993-1:2018; K252805 reports ISO 10993-1:2018 and cytotoxicity, irritation and sensitization testing. High |
| Electrical safety and electromagnetic compatibilityIEC 60601-1-2:2014 | K211498 Nonin OTC Pulse Oximeter Model 3250 K252805 YUWELL® Finger Pulse Oximeter K252448 AViTA Pulse Oximeter | The summaries report EMC testing or compliance; K252448 states IEC 60601-1-2 was relied upon from K223399. High |
| Pulse oximeter performance bench testingISO 80601-2-61:2017 | K252805 YUWELL® Finger Pulse Oximeter K252448 AViTA Pulse Oximeter | K252805 reports performance bench testing; K252448 reports laboratory bench testing of SpO2 and pulse-rate measurement accuracy. High |
| Software verification and validationANSI AAMI IEC 62304:2006/A1:2016 | K211498 Nonin OTC Pulse Oximeter Model 3250 K252805 YUWELL® Finger Pulse Oximeter | K211498 reports compliance with the software life-cycle standard; K252805 reports software verification and validation and Basic Documentation Level. High |
| Usability and human factorsIEC 60601-1-6:2013 | K211498 Nonin OTC Pulse Oximeter Model 3250 | The summary reports usability testing participation by users and lists the usability collateral standard. High |
| Wireless testingIEC 60601-1-2:2014 | K252805 YUWELL® Finger Pulse Oximeter | The summary includes a wireless testing section; the excerpt does not give the results or specific wireless standard. Medium |
These are candidate recognized standards based on the fingertip pulse oximeter, home use, battery power and predicate testing. Standards for wireless connectivity, medical-image systems, unrelated oximeter technologies and secondary batteries are not included as applicable because the description states no app or connectivity and specifies AAA batteries.
| Rec. no. | Standard | Applies | Why |
|---|---|---|---|
| 1-139 | ISO 80601-2-61 Second edition 2017-12 (Corrected version 2018-02) Medical electrical equipment - Part 2-61: Particular requirements for basic safety and essential performance of pulse oximeter equipmentRecognized: Partial | yes | ISO 80601-2-61 is the pulse oximeter particular standard and is reported in the OTC predicate summaries. High |
| 19-49 | IEC 60601-1 Edition 3.2 2020-08 CONSOLIDATED VERSION Medical electrical equipment - Part 1: General requirements for basic safety and essential performance - Note: This standard is recognized with relevant US national differences applied see references #1 and #2 in the Relevant FDA Guidance and/or Supportive Publication section below.Recognized: Complete | Depends | IEC 60601-1 is relevant to basic safety and essential performance of the powered medical device; confirm applicability to the final design. Medium |
| 19-36 | ANSI AAMI IEC 60601-1-2:2014 [Including AMD 1:2021] Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances - Requirements and tests [Including Amendment 1 (2021)]Recognized: Partial | Depends | IEC 60601-1-2 addresses EMC and is reported for pulse oximeter predicates; assess for the final device. High |
| 19-38 | IEC 60601-1-11 Edition 2.1 2020-07 CONSOLIDATED VERSION Medical electrical equipment - Part 1-11: General requirements for basic safety and essential performance - Collateral Standard: Requirements for medical electrical equipment and medical electrical systems used in the home healthcare environmentRecognized: Partial | yes | IEC 60601-1-11 addresses home healthcare equipment, matching the stated home use. High |
| 2-258 | ISO 10993-1 Fifth edition 2018-08 Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management processRecognized: Partial · transition expires 07/01/2029 | Depends | ISO 10993-1 is relevant if the fingertip-contacting materials require biological evaluation; patient-contact materials are not stated. Medium |
| 2-245 | ANSI AAMI ISO 10993-5:2009/(R)2014 Biological evaluation of medical devices - Part 5: Tests for in vitro cytotoxicityRecognized: Complete | Depends | ISO 10993-5 cytotoxicity may apply depending on the risk-based biocompatibility evaluation of contact materials. Medium |
| 2-291 | ISO 10993-23 First edition 2021-01 Biological evaluation of medical devices - Part 23: Tests for irritationRecognized: Partial | Depends | ISO 10993-23 irritation may apply depending on the risk-based evaluation of fingertip-contacting materials. Medium |
| 2-296 | ISO 10993-10 Fourth edition 2021-11 Biological evaluation of medical devices - Part 10: Tests for skin sensitizationRecognized: Partial | Depends | ISO 10993-10 skin sensitization may apply depending on the risk-based evaluation of fingertip-contacting materials. Medium |
| 13-79 | ANSI AAMI IEC 62304:2006/A1:2016 Medical device software - Software life cycle processes [Including Amendment 1 (2016)]Recognized: Complete | Depends | IEC 62304 is relevant if software is part of the device; the description does not state the software architecture. Medium |
| 5-129 | ANSI AAMI IEC 62366-1:2015+AMD1:2020 (Consolidated Text) Medical devices Part 1: Application of usability engineering to medical devices including Amendment 1Recognized: Complete | Depends | IEC 62366-1 is relevant to usability engineering for a lay-operated home device. Medium |
| 5-125 | ANSI AAMI ISO 14971: 2019 Medical devices - Applications of risk management to medical devicesRecognized: Complete | yes | ISO 14971 provides a risk-management framework relevant to the device's measurements and lay use. Medium |
| 19-54 | IEC 60086-5 Edition 5.0 2021-09 Primary batteries - Part 5: Safety of batteries with aqueous electrolyte [Including: Corrigendum 1 (2022)]Recognized: Complete | Depends | IEC 60086-5 addresses safety of primary batteries with aqueous electrolyte; confirm its applicability to the specified AAA batteries. Medium |
| 13-122 | IEC 81001-5-1 Edition 1.0 2021-12 Health software and health IT systems safety effectiveness and security - Part 5-1: Security - Activities in the product life cycleRecognized: Complete | no | IEC 81001-5-1 addresses health software and health IT security; no app or connectivity is described. High |
| 13-134 | ISO IEEE 11073-10404 Second edition 2022-12 Health informatics - Personal health device communication - Part 10404: Device specialization - Pulse oximeterRecognized: Complete | no | ISO IEEE 11073-10404 concerns communication with personal health devices; no communication function is described. High |
Source: FDA recognized consensus standards register, exported 2026-09-13. Recognized is FDA's extent of recognition.
A 510(k) is the proposed premarket pathway, and the list below summarizes submission and ongoing obligations supported by the supplied regulation text.
The proposed OLK pathway is 510(k); the submission should identify the device, intended use and basis for substantial equivalence and support the comparison with appropriate testing.
21 CFR 807.81 21 CFR 807.87 21 CFR 807.92 FDA guidance: Pulse Oximeters - Premarket Notification Submissions [510(k)s]
Plan performance, electrical safety, EMC, home-use and usability evidence appropriate to the final device and claims; the OTC predicate summaries report pulse oximeter accuracy and home-use testing.
FDA guidance: Pulse Oximeters - Premarket Notification Submissions [510(k)s] Standard 1-139 Standard 19-36 Standard 19-38
21 CFR 820.10(a) requires a documented quality management system that complies with the applicable requirements of ISO 13485; 21 CFR 820.1(a) applies it to all finished devices.
Name and place of business (21 CFR 801.1) and adequate directions for use (21 CFR 801.5). Over-the-counter devices carry a statement of identity on the principal display panel (21 CFR 801.61).
FDA guidance: Labeling - Regulatory Requirements for Medical Devices (FDA 89-4203)
The label of every device bears a UDI (21 CFR 801.20) that meets 21 CFR 830.20; the labeler submits device data to GUDID (21 CFR 830.300).
FDA guidance: Global Unique Device Identification Database (GUDID)
Required of anyone who manufactures or develops specifications for a device made by a second party (21 CFR 807.20), filed electronically (21 CFR 807.21) within 30 days of starting and updated annually (21 CFR 807.22).
Complaint handling feeding medical device reporting: reports to FDA within 30 calendar days of a death, serious injury or reportable malfunction (21 CFR 803.50); reports of corrections and removals (21 CFR 806.10).
2 checks for this section are under What to confirm next
A quality system is where this list lives. Cove QMS builds one for companies at this stage: coveqms.com.
What to test, what FDA will expect in the 510(k), what to ask FDA first, and a rough budget and timeline. It builds on the equivalence table, the standards and the obligations without repeating them.
Rough planning total
$70K to $167K or more
FDA fee at the small business rate $7,163 plus testing that applies $63K to $160K or more.
FDA aims to decide within 60 days; the status lasts to September 30, so apply again each fiscal year, before you pay the fee.
Written answers within 70 days of FDA accepting the request; a meeting, if you ask for one, around day 70 to 75.
No public source states a lab lead time: ask each lab when you ask for its quote.
No public source states how long a study takes.
FDA's user fee is due with the submission; the small business rate needs the status above.
FDA's goal is a decision within 90 FDA days; days waiting on your answers do not count.
You may sell once FDA decides and you have registered.
Within 30 days of starting, then every year; FDA has no small business rate for it.
The amounts above, less the lines not in the total.
About 5 to 6 months from sending the Pre-Sub to FDA's decision, counting only the Pre-Sub and FDA's review goal, one after the other; testing, and any time FDA waits on you, come on top.
Counted: Electrical safety and EMC, biocompatibility. Applies but has no public figure, so not in the range: performance bench testing, software verification and validation, human factors; ask labs to quote.
Not included: consultants and your quality system. For scale, one firm's 2024 price sheet lists $17,500 to prepare a 510(k) or De Novo and $5,000 for a Pre-Sub. The sheet.
A rough planning number from public industry ranges, not a quote.
FDA's fee and review goal are its figures for the route proposed in section 1, shown in full under “What this means” in the summary at the top.
| Test | Kind | Standard to test to | Rough cost of the kind | Predicates that ran it |
|---|---|---|---|---|
| SpO2 laboratory and clinical hypoxia accuracy Supports the reading a COPD patient acts on at home: SpO2 accuracy is shown in people taken down through a range of oxygen levels. High | Clinical data | 1-139 ISO 80601-2-61 Second edition 2017-12 (Corrected version 2018-02) | $250K to $2.5M | Nonin OTC Pulse Oximeter Model 3250 K211498 |
| Pulse oximeter performance bench testing Verifies SpO2 and pulse-rate accuracy on a simulator and the display's behaviour at the limits of the range. High | Performance bench testing | 1-139 ISO 80601-2-61 Second edition 2017-12 (Corrected version 2018-02) | No public figure | YUWELL® Finger Pulse Oximeter K252805 AViTA Pulse Oximeter K252448 |
| Electrical safety and electromagnetic compatibility A battery-powered medical electrical device is tested for basic safety and for interference in the home. High | Electrical safety and EMC | 19-36 ANSI AAMI IEC 60601-1-2:2014 [Including AMD 1:2021] | $50K to $60K | Nonin OTC Pulse Oximeter Model 3250 K211498 YUWELL® Finger Pulse Oximeter K252805 AViTA Pulse Oximeter K252448 |
| Home healthcare electrical safety and essential performance Over-the-counter home use brings in the home healthcare collateral standard. High | Electrical safety and EMC | 19-38 IEC 60601-1-11 Edition 2.1 2020-07 CONSOLIDATED VERSION | $50K to $60K | Nonin OTC Pulse Oximeter Model 3250 K211498 |
| Biocompatibility The finger chamber touches intact skin at every reading, so its materials need cytotoxicity, sensitization and irritation results. High | Biocompatibility | 2-258 ISO 10993-1 Fifth edition 2018-08 | $13K to $100K or more | Nonin OTC Pulse Oximeter Model 3250 K211498 YUWELL® Finger Pulse Oximeter K252805 |
| Software verification and validation The firmware computes and displays SpO2 and pulse rate. High | Software verification and validation | 13-79 ANSI AAMI IEC 62304:2006/A1:2016 | No public figure | Nonin OTC Pulse Oximeter Model 3250 K211498 YUWELL® Finger Pulse Oximeter K252805 |
| Usability and human factors Lay users with COPD read the display and decide whether to call a doctor, so the use-related risks need a usability evaluation. High | Human factors | 5-129 ANSI AAMI IEC 62366-1:2015+AMD1:2020 (Consolidated Text) | No public figure | Nonin OTC Pulse Oximeter Model 3250 K211498 |
Rough public industry ranges for a whole kind of testing, not a quote: a lab usually quotes a kind as one program, so the budget counts each kind once. Read on 2026-09-26.
| Part | Applies | Why |
|---|---|---|
| Device description and intended use | yes | Every 510(k) describes the device and its intended use: intermittent home spot checks by adults with COPD. High |
| Indications for use | yes | The indications must state over-the-counter adult spot-check use at home, as OLK clearances such as K211498 do. High |
| Substantial-equivalence comparison | yes | The 510(k) compares the device with the kept predicates, as the equivalence table in section 3 lays out. High |
| Labeling | yes | Over-the-counter labeling must let a lay user act on a low reading safely, including when to contact a doctor. High |
| Performance bench testing | yes | SpO2 and pulse-rate accuracy on a simulator and display behaviour are verified before the clinical study. High |
| Electrical safety and EMC | yes | A battery-powered device used at home is tested to 19-49, 19-36 and the home healthcare standard 19-38. High |
| Biocompatibility | yes | The finger chamber contacts intact skin at every use. High |
| Sterility and shelf life | no | A reusable device on intact skin is not sold sterile, and no shelf-life claim is stated. Medium |
| Software documentation | yes | Firmware computes the readings; Basic documentation level fits, since a failure gives a wrong reading that the labeling tells the user to confirm, and K252805 reports Basic. Medium |
| Cybersecurity | no | The description rules out an app and any connection, so the device is not a cyber device. Medium |
| Human factors | yes | Lay users acting on a reading at home make use errors a critical task, and K211498 reports usability testing with users. Medium |
| Clinical data | yes | SpO2 accuracy is shown in a controlled desaturation study in people, including people with darker skin pigmentation. High |
A Pre-Submission is free: FDA charges no fee. FDA answers in writing within 70 days of accepting the request and, if you ask for a meeting, meets you around day 70 to 75. FDA's Q-Submission guidance.
A disease-specific indication at home is the claim closest to the edge of OLK.
The clinical accuracy study is the largest cost and the longest lead time in the plan.
The answer decides whether a human factors study with at least 15 users is in the budget.
The predicates reported older editions than the ones recognized now.
Public programs to check, not advice: Cove has no part in them, and each program decides who qualifies. Pediatric programs appear when the description mentions children, defense programs when it mentions military use. Read on 2026-09-26.
| Program | Typical award |
|---|---|
| NIH SBIR and STTR Research and development grants from the National Institutes of Health to US small businesses, medical devices among them. | Phase I about $323,090 over 6 months to 2 years; Phase II about $2,153,927 over 1 to 3 years; some topics allow more by waiver. |
| NSF SBIR and STTR (America's Seed Fund) National Science Foundation grants for startups in most technology areas, medical devices included; you keep full ownership of the company and its IP. | Phase I up to $305,000; Phase II up to $1,250,000 over 24 months. |
| ARPA-H SBIR and STTR Small business awards from the Advanced Research Projects Agency for Health on set topics, open for a limited time (the 2026 topics close in September and October 2026). | Phase I up to $600,000; Phase II up to $3.5 million. |
| MedTech Innovator An accelerator for medical device, diagnostic and digital health companies that have raised up to a Series C, with mentors from its corporate partners. | Early-stage (pre-Series B) companies compete for up to $500,000 in funding (2026 cohort). |
| Program | Typical award |
|---|---|
| Kentucky SBIR/STTR Matching Funds Matches a federal SBIR or STTR award for a for-profit company based in Kentucky or willing to move there. | Up to $100,000 for Phase I and up to $150,000 for Phase II. |
| Kansas SBIR/STTR Matching Program Helps a small business headquartered in Kansas prepare a federal SBIR or STTR proposal and matches a Phase I award. | Up to $3,000 for proposal development (a 50% match); up to $25,000 to match a Phase I award. |
Other states run similar matching programs; your state's economic development office will know.
Every claim about the device in this report comes from these public FDA sources; web search was not a source. The report reads a dated copy of each, so every run can be checked against the same records; the links go to the live versions, where you can look up the same information.
The rough costs and timings in section 6 are not FDA records about the device: they are public figures, added the same way to every report, each with the day it was read.
The programs this report lists, each from its own public page.
Each record looked up and each decision. Codes, 510(k) numbers and regulations link to FDA's own pages.