(245 days)
Siren ePCR Suite™ is intended for the collection, storage and printing of patient data that is entered by a user (paramedic), or captured from specified medical devices, and integrated into a patient care report (patient electronic medical record). Siren ePCR Suite™ is intended for use by qualified medical personnel providing direct patient care in the pre-hospital environment to document the care provided. Siren ePCR Suite™ is indicated for use by health care providers whenever there is a need for generation of a patient record.
Siren ePCR Suite™ is a software-only product. Siren ePCR Suite™ is a medical data collection system used to collect, store and print patient data that is entered by a user (caregiver), or captured from specified medical devices, and is integrated into a patient care report (patient electronic medical record). Siren ePCR Suite™ is non-alarming software that runs on a variety of commercial off-the-shelf hardware.
The provided text describes a 510(k) premarket notification for the "Siren ePCR Suite™" device. It focuses on establishing substantial equivalence to a predicate device ("RescueNet ePCR"). This type of submission generally does not include detailed performance studies with acceptance criteria, sample sizes, or expert adjudication in the way that an AI/ML device would be proven to meet performance claims.
Based on the provided text, the device is a software-only product classified as a "Medical Cathode-ray Tube Display" (regulatory class II) with the product codes DXJ and NSX. Its intended use is for the collection, storage, and printing of patient data entered by paramedics or captured from specified medical devices, integrated into a patient care report in a pre-hospital environment.
Here's an analysis of the provided text in relation to your questions:
1. A table of acceptance criteria and the reported device performance
The document does not provide a table with specific quantitative acceptance criteria (e.g., sensitivity, specificity, accuracy targets) against which the device's performance was measured for clinical effectiveness. The "reported device performance" is primarily framed around the comparison of technological characteristics to a predicate device and the successful completion of non-clinical software testing.
The acceptance criteria mentioned are general:
- "The software was tested against the established Software Design Specifications for each of the test plans to assure the device performs as intended."
- "The testing results supports that all specifications have met the acceptance criteria of each module and interaction of processes."
- "Siren ePCR Suite™ device passed all testing and supports the claims of substantial equivalence and safe operation."
2. Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)
Not applicable. This was a non-clinical software verification and validation study, not a clinical study involving patient data with a test set in the conventional sense of AI/ML performance evaluation. The "test set" refers to software testing scenarios, not a dataset of patient cases.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g., radiologist with 10 years of experience)
Not applicable. Given that this was a functional software verification and validation, ground truth would be established by reference to the software design specifications and expected system behavior, rather than expert consensus on medical cases.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set
Not applicable. No mention of an adjudication method for a test set, as no clinical test set for diagnostic or predictive performance was used.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
No. The document explicitly states: "There was no clinical testing required to support the medical device as the indications for use is equivalent to the predicate device." This device is a data collection and storage system, not an AI/ML device designed to assist human readers or perform diagnostic interpretations.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
No. The device is a "software-only product" for data collection, storage, and printing, running on commercial off-the-shelf hardware. Its function is to facilitate the documentation of care by qualified medical personnel, not to provide standalone analytical performance in the way an AI/ML algorithm would.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
For the non-clinical testing, the "ground truth" was the device's "established Software Design Specifications." The software was tested to ensure it performed as intended according to these specifications and to mitigate identified hazards.
8. The sample size for the training set
Not applicable. This device is not an AI/ML product developed using a training set.
9. How the ground truth for the training set was established
Not applicable. As there was no training set, there was no ground truth for a training set.
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Image /page/0/Picture/0 description: The image contains the logos of the Department of Health and Human Services and the Food and Drug Administration (FDA). The Department of Health and Human Services logo is on the left, and the FDA logo is on the right. The FDA logo includes the letters "FDA" in a blue square, followed by the words "U.S. Food & Drug Administration" in blue text.
Medusa Medical Technologies Inc. c/o Dr. Diane Sudduth Senior Consultant QA Emergo Group, Inc. 816 Congress Ave., Suite 1400 Austin. Texas 78701
September 1, 2023
Re: K131272
Trade/Device Name: Siren ePCR Suite™ Regulation Number: 21 CFR 870.2450 Regulation Name: Medical Cathode-ray Tube Display Regulatory Class: Class II Product Code: DXJ
Dear Dr. Diane Sudduth:
The Food and Drug Administration (FDA) is sending this letter to notify you of an administrative change related to your previous substantial equivalence (SE) determination letter dated January 3, 2014. Specifically, FDA is updating this SE Letter to remove the secondary product code NSX as an administrative correction.
Please note that the 510(k) submission was not re-reviewed. For questions regarding this letter, please contact Aneesh Deoras, OHT2: Office of Cardiovascular Devices, 240-402-4363, Aneesh.Deoras@fda.hhs.gov.
Sincerely,
Aneesh S. Deoras -S
for
Jennifer Shih Kozen Assistant Director Division of Cardiac Electrophysiology, Diagnostics, and Monitoring Devices Office of Cardiovascular Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/1/Picture/1 description: The image shows the seal of the Department of Health & Human Services - USA. The seal is circular and contains the department's logo in the center. The logo consists of a stylized caduceus, a symbol often associated with medicine and healthcare. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged around the perimeter of the circle.
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
January 3, 2014
Medusa Medical Technologies, Incorporated C/O Dr. Diane Sudduth Senior Consultant, QA Emergo Group, Incorporated 816 Congress Avenue, Suite 1400 Austin, TX 78701
Re: K131272
Trade/Device Name: Medical Technologies, Inc. Siren ePCR Suite Regulation Number: 21 CFR 870.2450 Regulation Name: Medical Cathode-Ray Tube Display Regulatory Class: II Product Code: DXJ, NSX Dated: November 18, 2013 Received: November 19, 2013
Dear Dr. Sudduth:
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. 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.
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... .. ..
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 requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours,
Mary S. Runner -S
Erin I. Keith, M.S. Acting Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Indications for Use Statement
510(k) Number (if known): K131272
Device Name: Siren ePCR Suite™
Indications for Use:
Siren ePCR Suite™ is intended for the collection, storage and printing of patient data that is entered by a user (paramedic), or captured from specified medical devices, and integrated into a patient care report (patient electronic medical record). Siren ePCR Suite™ is intended for use by qualified medical personnel providing direct patient care in the pre-hospital environment to document the care provided. Siren ePCR Suite™ is indicated for use by health care providers whenever there is a need for generation of a patient record.
Prescription Use_ ਮ (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)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Digitally signed by Richard C. Chapman Date: 2014.01.02 1 1:33:26 -05'00'
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Medusa Medical Technologies Inc. Traditional 510(k) Premarket Submission Siren ePCR Suite™
EMERGO GROUP
510(k) Summary
1. Submission Sponsor
Medusa Medical Technologies Inc. Suite 140-36 Solutions Dr Halifax, Nova Scotia B3S 1N2 Canada Phone: (902) 429-1200 Fax: (902) 484-5583 Contact: Craig Fraser, VP of Sales and Product Management
2. Submission Correspondent
Emergo Group, Inc. 816 Congress Avenue, Suite 1400 Austin, TX 78701 Cell Phone: (561) 305-5075 Office Phone: (512) 327-9997 Fax: (512) 327-9998 Contact: Diane Sudduth, Senior Consultant, QA Email: project_management@emergogroup.com
3. Date Prepared
May 2, 2013
4. Device Identification
Medusa Medical Technologies, Inc. Siren ePCR Suite™ Trade/Proprietary Name: Common/Usual Name: Siren ePCR Display, Cathode Ray Tube, Medical Classification Name: Classification Regulation: 870.2450 DX1: NSX Product Code: Device Class: Class II Classification Panel: Cardiovascular; General Hospital
5. Predicate Devices
K103473 Zoll Medical Corporation - RescueNet ePCR
6. Device Description
Siren ePCR Suite™ is a software-only product. Siren ePCR Suite™ is a medical data collection system used to collect, store and print patient data that is entered by a user (caregiver), or captured from specified medical devices, and is integrated into a patient care report (patient
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electronic medical record). Siren ePCR Suite™ is non-alarming software that runs on a variety of commercial off-the-shelf hardware.
7. Intended Use
Siren ePCR Suite™ is intended for the collection, storage and printing of patient data that is entered by a user (paramedics), or captured from specified medical devices, and integrated into a patient care report (patient electronic medical record). Siren ePCR Suite™ is intended for use by qualified medical personnel providing direct patient care in the pre-hospital environment to document the care provided. Siren ePCR Suite™ is indicated for use by health care providers whenever there is a need for generation of a patient record.
8. Comparison of Technological Characteristics
The following table compares the Siren ePCR Suite™ to the predicate device with respect to intended use, overall technological and functional characteristics, providing more detailed information regarding the basis for the determination of substantial equivalence.
The Siren ePCR Suite™ is similar in design and function to the predicate device for the modes of operation and use.
| Manufacturer | Zoll Medical Corporation | Medusa Medical Technologies Inc. |
|---|---|---|
| Trade Name | PredicateRescueNet ePCR | New DeviceSiren ePCR Suite™ |
| 510(k) Number | K103473 | Not assigned |
| Product Code | DJXNSX | DJXNSX |
| Regulation Number | 870.2450Null | 870.2450Null |
| Regulation Name | Display, Cathode Ray Tube,Medical | Display, Cathode RayTube, Medical |
| Indications for Use | Software, Transmission andStorage, Patient DataRescueNet ePCR is intended forthe collection, storage andprinting of patient data that isentered by a user (caregiver), orcaptured from specified medicaldevices, and integrated into apatient care report (patientelectronic medical record). | Software, Transmission andStorage, Patient DataSiren ePCR Suite™ is intendedfor the collection, storage andprinting of patient data that isentered by a user (paramedic),or captured from specifiedmedical devices, and integratedinto a patient care report(patient electronic medical record). |
| Manufacturer | Zoll Medical Corporation | Medusa Medical Technologies Inc. |
| Trade Name | PredicateRescueNet ePCR | New DeviceSiren ePCR Suite™ |
| RescueNet ePCR is intended for useby qualified medical personnel providing directpatient care in the pre-hospital environment to document thecare provided. RescueNet ePCRis indicated for use by healthcare providers whenever thereis a need for generation of apatient record. | record). Siren ePCR Suite™ isintended for use by qualifiedmedical personnel providingdirect patient care in the pre-hospital environment todocument the care provided.Siren ePCR Suite™ is indicatedfor use by health care providerswhenever there is a need forgeneration of a patient record. | |
| Material | Software | Software |
| System Requirements | ||
| Compatible operatingsystem (software only) | Windows XP Professional | Field User: Windows XP or XPTablet Edition SP3 or Windows7 SP1; SQL Express 2005 SP3Server: Windows Server 2003R2 SP3; SQL Server 2005 SP3 /SQL Server 2008 SP3.NET Framework |
| Web-Based Application(Locally installed vs.vendor server based) | WebPCR module provides aweb based access whenconnected to web browser orWebPCR server. | Web based Administration andWorkflow. Store and forwardcommunication from tablet toserver. |
| Hardware | ||
| Compatibility and systemrequirements | ||
| Desktop PC | Yes | Yes |
| Tablet PC | Yes | Yes |
| Pocket PC/Palm devicecompatible | Yes | No |
| Internet connectionrequired at all time oronly during data sync | Only during data sync frommobile devices | Only during data sync frommobile devices |
| Printer compatibility | Yes, can print locally or across anetwork | Yes, can print locally or across anetwork |
| Wireless access supported(ie Verizon/sprint WWAN) | Yes | Yes |
| Manufacturer | Zoll Medical Corporation | Medusa Medical Technologies Inc. |
| Trade Name | PredicateRescueNet ePCR | New DeviceSiren ePCR Suite™ |
| Security | ||
| Data encryption | Yes | Yes |
| Ability to lock PCR once completed | Yes | Yes |
| Tracks changes to module databases, including date, time, computer and user who made the change | Yes | Yes |
| Data Exchange | ||
| Interface to server (Data synchronization) | Yes, wireless or hard wired | Over internet connection |
| Interface with CAD/Dispatch | Yes | Yes |
| Interface with Hospitals (Fax, email/etc., direct sync, etc.) | Yes | Yes |
| Interface with Hospital Pre-Alert | Yes | Yes |
| Interface with Billing | Yes | Yes |
| Interface with Medical Equipment | Physio-ControlLifePak 11 monitor/defibrillator,LifePak 12/15monitor/defibrillator,LifePak 500monitor/defibrillator;PhilipsHeartStart MRx;Zoll1600,AED Plus/AED Pro,M Series/E Series | Physio-ControlLifePak 12/15monitor/defibrillatorPhilipsHeartStart MRxZollM Series/E Series |
| EKG Integration | Yes | Yes |
| Mobile-to-mobile data transfer | Yes | Yes |
| Interfaces to electronic record (EHR) / HL7 | Yes | Yes |
| Manufacturer | Zoll Medical Corporation | Medusa Medical TechnologiesInc. |
| Trade Name | Predicate | New Device |
| RescueNet ePCR | Siren ePCR Suite™ | |
| Additional Features | ||
| Electronic SignatureSupport | Yes | Yes |
| Ability to link referencedocuments (protocols) | Yes | Yes |
| Ability to populate patientinfo from previous patientcontact | Yes | Yes |
| Drug Monographdatabase | No | Yes via integration with existingcommercial drug monographproviders (MicroMedix) |
| Use environment | EMT, paramedic | EMT, paramedic |
| Intended users(target population) | Professional Users | Professional Users |
Table 5A - Comparison of Characteristics
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Medusa Medical Technologies Inc. Traditional 510(k) Premarket Submission Siren ePCR Suite™
EMERGO G GROUP
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9. Non-Clinical Testing
The device's software development, verification and validation have been carried out in accordance with the FDA's guidance documents. The software was tested against the established Software Design Specifications for each of the test plans to assure the device performs as intended.
The device Hazard analysis was completed and risk control implemented to mitigate hazards. The testing results supports that all specifications have met the acceptance criteria of each module and interaction of processes. Siren ePCR Suite™ device passed all testing and supports the claims of substantial equivalence and safe operation.
10. Clinical Testing
There was no clinical testing required to support the medical device as the indications for use is equivalent to the predicate device. These types of devices, including the predicate devices, have been on the market for many years with a proven safety and efficacy for the use of the device. The non-clinical testing detailed in this submission supports the substantial equivalence of the device.
11. Statement of Substantial Equivalence
By definition, a new device is substantially equivalent to a predicate device when the device has the same intended use as the previously cleared predicate device and either (i) the same technological characteristics as the predicate, or (ii) if the new device has different
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technological characteristics, then those differences raise no new issues regarding the safety or effectiveness of the new device.
It has been shown in this 510(k) submission that Siren ePCR Suite™ has the same intended use as the predicate device and that any technological differences between the Siren ePCR Suite™ software and the predicate device do not raise any questions regarding Siren ePCR Suite™'s safety and effectiveness. Performance testing and compliance with voluntary standards demonstrate that Siren ePCR Suite™ software is substantially equivalent to the relevant aspects of the predicate device in terms of design, principals of operation, performance characteristics, and intended use. The Siren ePCR Suite™ software, as designed and manufactured, is determined to be substantially equivalent to the referenced predicate devices.
§ 870.2450 Medical cathode-ray tube display.
(a)
Identification. A medical cathode-ray tube display is a device designed primarily to display selected biological signals. This device often incorporates special display features unique to a specific biological signal.(b)
Classification. Class II (performance standards).