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Sleep Apnea Notification Feature (SANF)

Apple Inc. • Anesthesiology • 09/13/2024

510(k)IEC 62304 Class C
FDA Summary PDF

Device Purpose

The Apple Sleep Apnea Notification Feature (SANF) is an over-the-counter, software-only mobile medical application designed for risk assessment of moderate-to-severe sleep apnea in undiagnosed adults aged 18 and over, utilizing Apple Watch sensor data. Its methodology involves analyzing sensor patterns for breathing disturbances, with its scientific validation based on a clinical study demonstrating specific sensitivity and specificity metrics, and it operates under an FDA-approved predetermined change control plan.

Summary

On September 13, 2024, the U.S. Food & Drug Administration completed its review of Apple Inc.'s Sleep Apnea Notification Feature (SANF), an over-the-counter software-only mobile medical application intended to assess the risk of moderate-to-severe sleep apnea. Determined to be substantially equivalent to previously marketed devices, SANF analyzes Apple Watch sensor data to identify breathing disturbance patterns, providing notifications to users aged 18 and over who have not been previously diagnosed. It is crucial to note that the feature is not intended for the diagnosis, treatment, or management of sleep apnea, serving solely as a risk assessment tool. The FDA's determination was based on comprehensive non-clinical and clinical testing, including software verification and validation, cybersecurity evaluations, human factors validation, and platform compatibility. A prospective clinical study involving 1,499 subjects validated the feature's performance, demonstrating a sensitivity of 66.3% and a specificity of 98.5% for detecting moderate-to-severe sleep apnea. The review also encompassed approval of a Predetermined Change Control Plan, which outlines a framework for future software modifications—such as algorithm adjustments or notification logic changes—without requiring a new submission, provided they adhere to defined protocols and do not alter the device's safety, effectiveness, or intended use.

AI Regulatory Concerns

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Jev reads the full FDA letter and returns calibrated concern probabilities per regulatory category. These are AI estimates, not regulatory advice.

Keywords

Sleep Apnea Notification FeatureApple Inc.FDA reviewSubstantial equivalenceMobile medical applicationApple Watch sensor dataModerate-to-severe sleep apneaClinical studySensitivity and specificityPredetermined Change Control Plan

Device Metadata

Submission Number
K240929
Company
Apple Inc.
Panel
Anesthesiology
Product Code
N/A
Data Type
Signals
Clinical Function
Assessment
AI Function
Analysis
AI Subclass
diagnosis

Relevant Clinical Questions

  • Q1. Given the device's 'risk assessment' purpose and specific performance metrics, what are the recommended clinical pathways for users who receive a notification of potential moderate-to-severe sleep apnea?; How does the SANF algorithm specifically process Apple Watch sensor data to identify patterns indicative of breathing disturbances, and what specific physiological parameters are prioritized?; What are the potential implications of the 66.3% sensitivity on false negatives, and how might this impact individuals who truly have sleep apnea but are not notified?; Does the Predetermined Change Control Plan include provisions for re-validating the algorithm's performance if there are significant changes in Apple Watch hardware or new sensor capabilities?; Are there any plans for post-market surveillance or real-world evidence collection to assess the long-term impact of SANF on user behavior, diagnostic rates, or overall public health outcomes related to sleep apnea?

Risk Classification

ESL Analysis
FDA Device ClassII

FDA Class II via 510(k) pathway; IEC 62304 Class C (software safety classification); Post-§524B but no clear network capability detected

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Cybersecurity Evidence

Powered by SBOMator™

Based on AI-generated device summaries, not the full FDA submission. Items not detected here may still be present in the complete submission package.

Cyber Score50/100
SBOM Evidence⚠ Not in summary - likely in full submission per §524B
Cyber Risk Assessment✓ Detected in Summary
Postmarket Plan✓ Detected in Summary
§524B ApplicableYes

Supply Chain BOM Evidence

Based on the CycloneDX / OWASP ECMA-424 xBOM ecosystem. Detection is from the AI-generated summary.

SBOMSoftware Bill of Materials
- Not detected
ML-BOMMachine Learning Bill of Materials(algorithm)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials(platform)
✓ Detected
HBOMHardware Bill of Materials(hardware, sensor)
✓ Detected
CBOMCryptography Bill of Materials
- Not detected
VDR/VEXVulnerability Disclosure Report / Vulnerability Exploitability eXchange
- Not detected
OBOMOperations Bill of Materials
- Not detected

Analysis:

• Analysis is based on the AI-generated device summary, not the full FDA submission package. Click "Analyze Full FDA PDF" below to scan the actual submission document.

• Evidence of ML-BOM, SaaSBOM, HBOM detected in AI-generated device summary.

• SBOM not mentioned in AI-generated device summary. Under §524B (effective Oct 2023), cyber devices must provide a SBOM.

• Not detected in AI-generated device summary: SBOM, CBOM, VDR/VEX, OBOM. These may be present in the full FDA submission.

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Sleep Apnea Notification Feature (SANF) - Apple Inc. | ESL FDA AI Device Intelligence