November 6 , 2014 U.S. Department ofTransportation Docket Management System 400 7 1 h Street , S.W. Room PL401 Washington, DC 20591-0001 

### Yes, 

### you can:

Attention: Ms. Jodi L. Baker, Deputy Assistant Manager, Air Transportation Division, AFS-200 Dear Ms. Baker, We received your letter dated October 8 , 2014 denying a perceived petition to add the Invacare XPO 100 and XPO 1 OOB portable oxygen concentrators to the list of approved devices in SFAR No. 106. We believe that there has been a misunderstanding and wish to clarify the purpose of Invacare's August 5 , 2014 submission. Our use of the terms "XP0100 " and " XPOIOOB" may have been confusing. The Invacare® XP0 2 TM Portable Oxygen Concentrator (POC) with Model Name XP02 was added to SFAR No. 106 as published in the Federal Regi s ter on January 15 , 2009: pages 2351 to 2355. Ord ering codes XPO 100 and XPO l OOB include the XP02 portable oxygen concentrator and in fact , they are the only ordering codes for the XP02 portable oxygen concentrator. Both ordering codes were included in the original petition submitted to FAA asking that the XP02 oxygen concentrator be added to SFAR No. 106. When SFAR I 06 was amended on January 15 , 2009 to add the Invacare XP02 POC , only the trade name XP02 was noted in the Federal Register; ordering codes XPO 100 and XPO 1 OOB were not cited. Pl ease see th e letter provided in Attachment A of this submission. Unfortunate ly , a copy of the original letter could not be located so the draft letter written by Mr. Carroll Martin is provided. The FDA 51 O(k) clearance letter, also includ ed in the original FAA petition , notes model number XPOIOO as the same as XP02 (Attachment B of this submission). The XP02 portable oxygen concentrator associated with both of these ordering codes is identical. The only difference is that the order code XPO 1 OOB has a s uppl emental battery. Please refer to the sales brochure provided in Attachment C.

I NVACA RE CO RPORATION One lnvaca rc Wa y P.O. Box 402 8 Elyria. Ohi o 4403 6·2 1 2 5 U SA 440-329-6000 Fax: 866 -4 62-9950 www.inva carc .comThe tabl e b e low is provided to show th e diff e re nces in th e two ordering codes: XPOIOO XPOJOOB XP02 Oxygen**~ ~**  Concentrator Carrying Case**~** 

# " AC Ad ap t e r**~ ~**  DC Adapter 

# " " Accessory Bag,**~ ~**  Supplemental 

# " Battery
The August 5 , 2014letter of notification of improvements a long with the updated RTCA D0- 160 emissions testing data described minor improvements , quality updates and the l atest EMC testing data for the internal and external batteries along with internal circuitry improv e ments of the Model XP02 oxygen concentrator. These are not new model numbers as noted in the third paragraph of the denial letter; these improv eme nts are being made to the existing model numb ers. The information was submitted because we believed that lnvacare was ob ligated to inform the agency that the devices were being updated for quality improvements and to update the RTCA DO-l 

### GO emissions data as posted on the FAA website for the Invacare XP02 POC. We hop e that this clarifies that Invacare is not petitioning the FAA to add any new oxygen concentrators to SF AR No. 106
. The August 2014 submission was inte nded to inform the agency that the XP02 devices were b e ing improved as \.veil as provide an update to the FAA posted emissions testing data. Compliance with FAA regulations is very important to lnvacare. We would appreciate a letter from the agency acknowledging receipt of our RTCA DO- 1 60 e missions t e sting data submission for the purposes of updating the FAA's EMC test data on your website for POC s . We would also appreciate acknowledgement that th e Invacare XP02 POC is already a listed product covered under the SF AR 106 approval dated January 15 , 2009. Please contact us at your earliest convenience if you have any requirements for additional information. Sincerely,

# ~L~~ Carol Vierling 

### V Acting Regulatory Affairs Manager Invacare Corporation On e Invacare Way Elyria, Ohio 44035 Phone: 706-476 -293 8 Email : cvierling@invacarecontractor.com

2

## Attachment A

3[D ate] U
. S. Department ofTransportation Docket Management Sys tem 400 7 111 Street , S. W. Room PL 401 Washington , DC 2059 1-000 I Applicant: Mr. Carroll Martin Regu latory Affa ir s M an age r Jn vacare Co rp o rat ion One In vacare Way Elyria, Ohio 4 4035-4 190 Carroli.Mart in @ invacare.com Phone:440-329-6356 Fax: 440-326

- 3458 Re: Petition to Amend SFAR No. 

### 106 on Portable Oxygen Co nc e ntr ator Devices on Passenger Aircraft Dear S ir or Madam: Please accept this letter as p et ition to amend the Federal Aviation Administration's (FAA) Special Federal Aviation Reg ulation (SFAR) No. I 06 und e r 14 CFR 12 1 that allows for the use of c e rtain portable oxygen concentrator (POC) devic es onboard pa sse n ge r a ircran. lnvacare is specifically requesting that th e FAA amend Section 2 and Section 3(a) of SFAR No. I 06 by adding lnv acare's portable oxyge n concen tr ator, the XP02 ( m ode ls XPOlOO a nd XPO l OO B) , as one ofthe approved POC d ev ices fo r use o n passenger aircraft. Background In vacare Co rporat io n is a manufacturer of home med ica l e quipm ent , w hi ch include s oxygen concentrators. Invacare is cur re ntl y preparing for th e marke t introduction of our XP02, a small, lightwe ight, battery powered POC intended for patie nt s with res piratory di sorders w h o requi re supplementa l oxygen. It is ln vacare's intent to p rovide for th ese p atients an oxygen system that wi ll substant ia ll y improve th ei r quali ty of li fe and to provide an additional choice of p011able oxygen concentrator for those pat ients who require supple mental oxygen and inte nd to use passenger aircraft for trave l.

INVACARE CORPORATION One lnv acar c Way P.O. Box 4028 Elyria, Ohi o 44036-2 125 USA 440-329-6000 Pax: 440-366- 1 R03 www. invacare. co rn 4Invacare 's XP02 provides oxygen by separating oxygen from room air utilizing a molecular sieve and pressure swing adsorption methodology. The resultant concentrated oxygen is direc te d toward an oxygen reservoir for delivery to the patient. The XP02 de livers the oxygen to the patient through the pulse delivery method for maximum effectiveness and operational time. This means that the XP02 de liv ers oxygen only wh e n a breath is detected. If no breath is detected (i.e. the cannula detaches from the device or the patient takes the cannula oft), no oxygen is delivered. This feature of delivering oxygen only when a breath is detected prevents oxygen saturation of the surrounding area or materials when the cannula is not connected to the concentrator or the patient. The U.S. Food and Drug Administration has issued to lnvacare a written determination that th e XP02 is I) substantially equivalent in safety and effectiveness to a device currently on the market (referred to as a predicate device and in this case , the device is the Inogen One Oxygen concentrator , a device the FAA has already granted permission to be us e d onboard passenger aircraft) and 2) the XP02 can be marketed to persons requiring supplemental oxygen (see Exhibit A- please note in this exhibit, the name of the device , The Flyer, Model XPO 100 , is quote d. This is the exact same device that is the subject of this submission.). Invacare's Reques t for PHMSA Letter of Interpretation On January 30, 2008 , Invacare submitted a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) requesting a written interpretation that the XP02 is not subject to the U.S. hazardous material regulations (HMR) pursuant to the requireme nts referenced in 49 CFR 173.115(b)(l) for Class 2, Division 2.2 gases and 49 CFR 173.185(c)(2) for lithium ion batterie s. The Jetter is attached as Exhibit 

### B. We expect confirmation from PHMSA by early April that the XP02 is not subject to the HMR. Pow er Source for the Inv acare XP02 The XP02 device can b e powe red by an internally captive lithium ion battery pack that i s not customer removable or replaceable , an external AC to DC power adapter, an external DC to DC power adapter, or an external accessory lithium ion battery pack. This allows for maximum flexibi lity and operational time with multiple power sources . Recharging of either the internal or external accessory batteri es is on ly available with the use of the Invacare supp li ed AC/DC or DC/DC power adapters. The internally captive lithium ion battery pack (see Exhibit C) consists of 8 cylindrical 2.6 amp-hour lithium ion c e lls (see Exhibits D and E) with a total lithium equivalent content of 6.24 grams of lithium. The internally captive battery pack is not user accessib le and not r e placeable by a patient/user. It is securely captured in the product and has passed all applicable UN Manual of T ests and Criteria requireme nts for li thium battery packs (see Exhibits F and G). The internally captive mechanism of the Invacare XP02 also pre ve nts any user from generating sparks or short-circuiting
I NVA CARE CORPORAT IO N O ne ln vacarc Way P. O
. Box 4028 Elyria. Ohio 44036

- 2125 USA 440-329-6000 Fax : 440-366- 1 803 www.invacarc.com 5as it is not externally accessible. The battery pack terminals are not exposed to any outs ide contact by virtue of being totally integrated into the product (see Exhibit H). The external accessory battery modu le XPO 11 0 (see Exhibit I) for extended operating time i s a self

contained power accessory for the Invacare XP02 device. The external battery module contains a separate li thium battery pack that consists of 8 cylindrical 2.6 amp-hour lithium ion cells with a total lithi u m equ iva lent con t e nt of 6.24 grams of lithium (see Exhi b it 

### J ). The l ithium battery p ack i s not user accessi bl e an d is n o t rep l acea bl e b y a pati e nt/ u ser . 

### It is sec urely cap tu red in the extern a l mod ul e and has passe d a ll app li cab le UN Man ual of T ests and Criter i a req uirements fo r lithiu m batte r y packs (Exhibits rand G). The capti ve mounting mechanism of the externa l bat tery modu le also prevents any user from generating sparks or short-circuiting the lithium battery pack. T he battery pac k termina ls are not exposed to any outside contact as they are connec ted to an interveni n g power switch ing and charging circuit board (see Exhibit K) that interfaces to the I nvacare X P0 2 dev i ce. The external battery module connection cab le (see Exhibit L) contains a connector th at p revents accidental shorting or generat io n of s p a rks duri ng hand li ng or sto rage. l nvacare fee l s that th ese fea tures of the i nterna l cap tive b attery a nd th e extern a l accesso ry b attery modu le meet th e r equ irements co n tai ned in Section 3, prov i sion (b)(6) ofSFAR No. 106
. The Travel Manual wi ll a lso contain detai led instructions on the regulatory requirements for carryi ng these types of batteries onboard commercial aircraft. Instruct ions for Passengers Using the Invacarc XP02 Oxygen System Onboard Co m mercial Passenger Aircraft To mee t FAA's requ iremen ts noted i n SFAR No. 106, J nvacare's T rave l Manual for the X P02 and o ur we b s ite w ill co nt ai n th e follow in g in struc ti ons (see Exhi bi t M as a n examp le) for patients/passengers that intend to u se th e In vacare XP02 onboa r d passe nger a irc raft: I. The user must have a wri tten statement, to be kept i n that person 's possession , signed by a licensed physician , that states: (i). Wheth er the u ser of the Invacare X P 02 has the phys ical and cognitive ability to see, hear and und erstand the dev ice 's aural and visual cautions and warnings and is abl e, wit hout assistance, to take the appropriate action in response to those caut ions and wa rnin gs; (ii )
. Wh e th e r or no t oxyge n u se is med icall y n ecessary fo r a ll or a po r t ion of th e du rat ion of th e t ri p; and (iii). The maximum oxygen flow rate corresponding to t he pressur e in the cab in of the aircraft under normal operating conditions. 2. The user mu s t inform the aircraft operator, pilot in command and crew that the Invacare XP02 may be used o n board t he a irc ra ft and hav e the physician' s s tatement avai lable that specifies the duration of oxygen us e req uired.
INVA C AR E C ORPORATIO N One lnvacarc Way P.O. Box 4028 Elyri a, Ohio 44036-2 125 US/\ 440-329-6000 Fax: 440-366- 1 803 www. invacarc.com 63. If the lnvac a r e XP02 is not in use during moveme nt on the g round , takeoff and landing , it mu s t e ith er be stowed under the seat in front of the u ser or in another approved stowage location so that it does not block the aisle way or th e entryway into the row. 4. Users of the lnvacare XP02 are prohibited from sitting in exit rows. 5. If the user of the Invacare XP02 is not capable of hearing the unit 's alarms, seeing the alarm li ght indicators or have the cognitive ability to tak e th e appropriate action in r esponse to th e various caution and warning alarms and a larm light indicators , they must travel with someone who is capable of performing th ese functions. 6. The user must e nsure the Invacare XP02 is free of oi l, grease or other petroleum products and is in good condition, free from damage or other signs of excess iv e wear or abuse. 7. The user of the Invacare XP02 must ensure that all lotions or salves applied to his/her person are oxygen approved. 8. The u ser whose p h ysic ian statement specifies the duration of oxygen use , must obtain from the a ircraft operator, or by other means, the duration of th e plmmed flight. The user then mu s t car ry on th e flight a sufficient number of batteries to power the Invacare XP02 for the duration of the oxygen use specified in the us e r 's physician state me nt , including a co n servati ve est imate of any unanticipated del ays. 9. Th e user mu st e n sure that the In vaca re XPO 110 external battery modul es carried onb oard the aircraft in c arry-on baggage are packaged in s u c h a way to prevent short circuits or ge neratin g a dangerous quantity of heat and are prot ected from physical damage. 10. If th e user does not intend to use the Invacare XP02 on board during the flight, the ex te rnal battery module must be disconnected and package d separately to prevent accidental operation. II. The user must ensure there is no open flame or smoking within 10 fee t of the seat row where th e portable oxygen concentrator is being u sed. Compliance wi th RTCA/D0-160F The lnvacare XP02 has successfully undergone tes tin g pursuant to the requirements of RTCA/D0- 160F, Section 21, Category M to demonstrate that th e device will not interfere with an aircraft's e lectrical , navigation or communication equipment. A copy of th e tes t repo rt is attached (Exhibit N) a nd th e data wi ll be submitted to air catTiers for verification.

I NVACARE CORPORATION One l nvacarc Way P.O. 13ox 4028 Elyria , Ohio 44036-2125 US/\ 440-329-6000 Fax: 440-366-1803 www.iuvacarc.com 7Summary Invacare believes th e information contained in this petition provides sufficie n t information for the FAA to d etermine that the Invacare XP02 is safe to be carried and used onboard passenger aircraft. We therefore request that Section 2 and Section 3(a) of SFAR No. 106 be amended by adding the Invacare XP02 as an approved POC dev i ce for u se o nb oard passenger aircraft
. S hould you need addi ti ona l information or have any questions regard in g our product, pl ease do not hesitate to ca ll me at the contact inform ation below. Respectfully submitted , Car r o ll 

### L. Martin Regul atory Affairs Manager Invacare Corporation One Inv acare Way Elyria , Ohio 44035 Phone:440-329-6356 Fax: 440 -32 6-3458 E mail : Carroii.Martin @ invacare.com

INVACARE CORPORATION One lnvacarc Way P.O. 13ox 4028 Ely ri a, Ohio 44036-2125 USA 440-329

- 6000 Fax: 440-366- 11"!03 www . in vacarc.com 8

## Attachment B

912 / 13/07 THU 17:32 FAX CDRU FDA ODE

**~001**



# ~

**~~~ ~~**  DEPARTMENT OP HEALTH &.HUMAN SERVICES Public Health Service
Exhibit A Food and Drug Admin i stration 9200 Corporate Boule\lard Rodc'lille MD 20850

Mr. Curroll L. Martin Regulatory Affairs Manager Invacare Corporation One Invacarc Wny P
. O.Box 4028 E lyria, Ohio 44036

- 2125
Re : 1<07 1928 

## DEC 1 2 Z00 7

Trade/Device Name: Invacare Flyer, Model XP<? 100 Regulation Number: 21 CFR 868
. 5440 Regulation Name : Portable Oxygen Generator Regulatory Class: II Product Code: CAW Dated: November 8, 2007 Received: November 9, 2007
Dear Mr. Martin: We have reviewed your Section 510(k) premarket notification of intent to market the device

**referenc~d** above and have determined the device is substantially equivalent (for the indications for use stateq in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medkal Device Amendments, or to devices that have been rec.:lassified in accordance with the prov i sions of the Federal Food, Drug. and Cosmetic Act (Act) that do not requ ire approval of a premarket approval application

**(~MA).** 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 annua l registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. If your device is classified (see above) into either cla s s II (Special Controls) or class III (PMA) , it may be subject to such additiona l controls. Exis ting major regu lations affecting your device can be found in the Code of Federal Reg ulation s , Title 21, Parts 800 to 898. In addition, FQA may publish further announcements concerning your device in the Federa l Regi s ter.

1012/13/07 THU 17:32 FAX CDRII FDA ODE At t achment A Page 2

- Mr. Martin
Please be advised that FDA's issuance of a s ubstantial equivalence determination does not mean that FDA h as made a determination that your device complie s with other requ irements of the Act or any Federal statu tes and regulations admin istered by other Federal agencies. You must c omply with all the Act's requireme nts, including, but not limited to: registration and lis ting (21 CFR Part 807); labeling (21 CFR Part 801); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 829); and if applicable , the electronic product radiation control provisions (Sections 531 -542 of the Act); 21 CFR 1000

- 1050. This letter willullow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of s ub stantial equ iv alence 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 s p ec ific advice for your device on o ur lab eling regulation (21 CFR Part 801). p lease contact th e Office of Compliance at (240) 276

-0115. Also, please note the regulation entitled, ''Misbranding by reference to premarket notification" (21CFR Part 807.97). You may oblain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistnnce at its toll

- free numb er (800) 638

- 2041 or (301) 443-6591 or ut its Internet address http://www
. fda
. gov/cdrhlindustry/supportlindex.html
.

Enclosure Sincerely yours,



# ~_tDffJ; J'4 cu.<'C:::I-t<2l

Director Divis ion of Anesth
. c: s iology,

**Gc:~eral** Hospital, Infection Control and D ental Devices Office of Dev ice Evaluation Center for De vices and Radiological Health @ 002

1112/1 3 / 07 TH U 17 : 32

**F~~** C DRII F D

A ODE

**~00 3**  Attachment A 

## Indications for Use SlO(k) Number (if known): Device Name: Invacare Flyer, Model XPO!OO Indications for Use: The Invacare Fly er (Model XPOIOO) is intended to be used by patients with

**respira~ory** disorders who require supplem!=ntal oxygen . It s uppli es a high concentration of supplem ental oxygen and is used with a nasal cannula to channel oxygen from the concentrator to the patient. The Invacare Flyer can be used in a home, institution, vehicle and various mobile environments. The Invacare Flyer does not nor is it intended to sustain or support life.

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 IF NEEDED)

**~** 

### Conc=ad.Rll , Office of Device Evaluation (ODE)



# ~1 

# .

51 O(k) Number:



# -~K~b~JwlL-q:u:z_::::...;t{~-- Page 1 of
__ 510(k)

**~071928** R es ponse

P:=tnP. 17 1 2

## Attachment C

13INVACARE 0 

# XP02 TM



# ~ PORTABLE OXYGEN CONCENTRATOR Ye s , y ou can:

With t he l nvacare•x ro 2- Po rt a b le C once n t r ator, providers and patients have a choice of ambulatory oxygen systems from lnvacare Corporation, th e world leader in home oxygen equ i pment. Named for its ext reme portab ili ty, t he XP02 concentrator is designed to be lightweigh t , c l inica lly robust and easy to ope rate. The supplemental battery and AC/OC power options make i t easy for patien t s to go just about anywhere without the fear of running out of oxygen . The

**lnvaca e~**  XPOi" concentrator features lnv a c a r ee Sen s i - Pul se - T ec h nology that custom i zes the size of each bo lus of oxygen to meet patient demand. Whether s l ee p i ng, relaxing or exercis in g, Sensi-Pu l se t echnology adapts to the patient' s oxygen needs. Se n siti ve conserver. se nsible design
... Sensi
- Pu l se Technology. Sens i -P ul se technology provi des cons t ant minute-vo l ume. This means that regard l ess of a pat i ent's brea th rat e at an y gi v en se tting. th e same amount of oxygen is provided per minute. A s the breath ra t e decreases. t h e bo l us size increas es.
14

# -- Fe atures P u lse dose settings 1 -5 m ee t t he n ee ds of a broad range of patients Battery, AC or DC operation for pa t ien t convenience No sepa r ate battery re cha r ger; c h arge interna l and external batteries w i th either the AC or DC adapter Supp l e mental battery pa c k allows for exte n ded battery power Sma ll compac t design
HCPCS Code: E 1 390/ E 1392

1
. AC IXP0 1 30) and DC IX P 0 1 4 0 1 powe r adapt e r Provider Benefits Signi f ic an tl y reduces op e ra ti ng costs by virt u ally e li minat i ng cy linde r de l iverie s, w i t h ou t sac rificing patien t care En courages comp li ance w i t h o xygen t h e r apy as pa tie nts have no wo r ries about running o ut of oxyg en S im p l e con t r ol pa n e l is easy fo r patients to us e and unders tan d Pati e nt B e n e fits Small. l igh t weigh t , non -m e dical looki n g package provid es comfor t
. conven i e n ce and increased independence Enjoy l i fe ' s exper i e nces anywhere
. a ny time w i thout heavy cylinders a n d excessive t ubing FAA app rov e d for in-lligh t use. Visi t www .i nvacare . com for a lis t of airlines that a ll ow t he use of t h e XP02 Portable Oxygen Concent ra tor

Av erage Pulse Volume Setting @ 20 BPM 1 15ml 2 23 ml 3 31 ml 4 37 ml 5 42 ml

lnvacare Corporation www . i nva c a

r e. com USA One lnvaca re W a y Elyria. Oh i o 440 35· 4 190 (8 00 ) 333. 6900 Canada 570 Mat heson B lvd
. E
. . Un it 8 2
. Whe ele d ca rt IXP01201 and car rying case IXP0 1 501 M ississauga. Ontar i o L 4Z 4G4 C a

na

da (800)668 - 5324 3
. Suppl e m e nta l batter y (X P 01 1 01 w i th case ( i nc l u ded w ith mode l ff XP01 0 0 B l 4
. Accessory b ag IXP0 1 60 no t p ic tu r ed ! XPOlOOB Conc e nt ra t or. carr ying case. supp l eme n ta l b a

tt e ry. AC ad apte r. DC a d ap t e r and accessor y b ag XP0100 Concentrator. c arr yin g case. AC adapt e r. DC adapt e r and access ory bag 

# 11111111111111

Mod el # Di mensions We ig ht O xyge n Flow O xygen Maxim um DC Power DC Adapt e r Pu ri ty 0 2 capacity I npu t Input XP0100 10'H 61b
. 1·5 Pu l se 95
. 6 o/o -87 o/o 900ML 18VC0 @ 11- 1 6V TW 131b. Setti ngs 3
. 3A 1 2
. 6 V Nom i nal 4'D Batt e!)' 

# IlliG

ACAdapter

In pu t 100.240VAC

50160 H z 1 A @ 120VAC B alle!)' Duration 2
.5 Hou rs@

Sen i n g 2 Recharge Time 3 h rs .'

• Recharge t ime inc r eases if unit is r unnin g while c h a rg i ng. O pera t ing Alt i tude Up To 10,000ft

. Sound Level 45db @ Setti ng 2 FAA Approved

Yes

1\1 ! r

ef

ere n ce:; to !I C PCS c odos- Prov iders are r espon s i b

l e f m det erm i n i rg th e**~p ;;t** **o(1!iaw** brlh og c odes when s u :XOi u iug cla r m

s t

o th e M e

di ca r e program. an d sh ou ld co ns u l t an auomey or a u, er adv i sor t o di sc u ss speci f ic**ions** rn**fu er**  de t ai l
. Limited W arranty 3Year C cncent r a to r 1 2Yea r Com presso r) 1 Y

ea r Sa tt el)'/ Accessories ©2 013 l nvacare Co rpo r a tio n. A

ll ri gh t s re served
. Tradem arks are ident if ie d b y the symbols ru a nd ®
. All trademarks are owned by o r lic ensed to l nvacare Co r porat ion unless o t herwise n o t ed. Spe ci fi ca t ions are s ubj ect to change wi thout no

tifi c at i o n. F orm No
. 07 ·067 R e v . 04/13 130340 

# ClQ}
Ye s , you can : 15