(65 days)
Detection of fetal life, detection of multiple pregnancies, fetal screens from early gestation through delivery and general indication of fetal well being. Verify fetal heart viability following patient trauma.
The Echo Sounder ES-101EX Single-handed Fetal Doppler system utilizes the well understood principle of Doppler shift of an ultrasound signal to detect the flow of blood within the fetal heart wall motion and arteries. The unit amplifies the high frequency oscillation output and then supplies this to the transmitter transducer. The high frequency voltage is converted to ultrasound by the transducer and is transmitted to external objects. The ultrasound transmitted by the transducer movers straight through biophysical object(s), and is reflected by the moving object (fetal heartbeat etc.). The reflected ultrasound is received by the receiving transducer and is converted into electronic signals again. The converted electronic signals are amplified and then are detected. After removing unnecessary noise signals and improving S/N ratio at the filter circuit, the Doppler shift signals are amplified and are converted to audible sound pressure through a speaker or a headset. Simultaneously the signals are applied to the heart rate LCD display.
Here's an analysis of the provided text regarding the acceptance criteria and study for the Echo Sounder ES-101EX:
Summary of Device Acceptance Criteria and Performance:
Based on the provided 510(k) submission summary, the Echo Sounder ES-101EX Fetal Doppler is cleared through a substantial equivalence pathway. This means its acceptance criteria are primarily met by demonstrating that it is as safe and effective as a legally marketed predicate device, rather than through independent studies proving specific performance metrics against pre-defined thresholds.
The crucial statement is: "The conclusion drawn from these tests is that the Echo Sounder ES-101EX Singlehanded Fetal Doppler device is equivalent in safety and efficacy to its predicated device."
Therefore, the "acceptance criteria" are implicitly tied to the safety and efficacy profile of the predicate device (K023143, Echo Sounder, Model ES-102EX Fetal Doppler). The submission doesn't define specific numerical performance targets for sensitivity, specificity, accuracy, or other quantitative metrics that are often seen in AI/CADe device submissions.
1. Table of Acceptance Criteria and Reported Device Performance:
| Acceptance Criteria | Reported Device Performance |
|---|---|
| Safety | The device complies with applicable industry and safety standards, as assessed through safety tests. Appropriate safeguards have been incorporated. |
| Efficacy | The device is equivalent in efficacy to the predicate device (K023143, Echo Sounder, Model ES-102EX Fetal Doppler) based on extensive performance tests. |
| Functional Requirements & Performance Specifications | The device meets all of its functional requirements and performance specifications, as assessed through various performance tests. |
| Indications for Use | The device performs for: Detection of fetal life, detection of multiple pregnancies, fetal screens from early gestation through delivery and general indication of fetal well being, and verifying fetal heart viability following patient trauma. This is equivalent to the predicate device. |
2. Sample Size Used for the Test Set and Data Provenance:
The document does not specify a separate "test set" in the context of an AI/algorithm-driven device. The testing described is for the device itself (hardware and its inherent functionality), not for an algorithm that processes external data.
The text states: "The Echo Sounder ES-101X Single-handed Fetal Doppler device has been subjected to extensive safety, performance, and validations prior to release. Final testing for the system includes various performance tests designed to ensure that the device meets all of its functional requirements and performance specifications."
No details are provided regarding:
- The number of cases or subjects used in these "performance tests."
- The country of origin of any data (if human subjects were involved in testing).
- Whether the data would be considered retrospective or prospective.
3. Number of Experts Used to Establish Ground Truth and Qualifications:
This information is not applicable/not provided. The device is a traditional fetal Doppler, not an AI or imaging device where expert interpretation or "ground truth" derived from expert consensus would typically be established for performance evaluation. The "ground truth" for a fetal Doppler is the presence or absence of a fetal heartbeat, which is directly detected by the device's physical principle.
4. Adjudication Method:
This information is not applicable/not provided. Adjudication methods (like 2+1, 3+1) are typically used in studies involving human interpretation of complex data (e.g., medical images) where an algorithm's output is compared to a consensus reading. This device directly detects a physical signal.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
No, an MRMC comparative effectiveness study was not performed, nor is it applicable for this device. This type of study involves assessing how human readers' performance (e.g., diagnostic accuracy) changes with or without AI assistance. The Echo Sounder ES-101EX is a standalone diagnostic tool, not an AI-assistant for human interpretation.
6. Standalone Performance (Algorithm Only):
The device itself operates in a standalone manner to detect fetal heart sounds and display heart rate. However, the term "standalone performance" in the context of AI/CADe usually refers to the algorithm's performance independent of human input. Since this device is a physical diagnostic instrument and not an AI algorithm performing image analysis or similar tasks, the concept of a separate "algorithm only" performance is not directly applicable in the AI/CADe sense. The "performance tests" mentioned in the submission assess the device's ability to accurately detect and display the fetal heart rate, which is its primary function.
7. Type of Ground Truth Used:
The type of ground truth for a fetal Doppler is the actual presence or absence of fetal heart activity and its corresponding rate. This is a physiological signal, not a pathology finding from a biopsy or an outcome derived from long-term follow-up. The device directly measures this physical phenomenon.
8. Sample Size for the Training Set:
This information is not applicable/not provided. The Echo Sounder ES-101EX is a hardware device based on the established principles of Doppler ultrasound. It does not use machine learning or AI, and therefore, there is no "training set" in the computational sense.
9. How the Ground Truth for the Training Set Was Established:
This information is not applicable/not provided for the same reasons mentioned above. There is no training set for this type of device.
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KO31504
510(k) Submission, Echo Sounder ES-101EX Koven Technology, Inc., St. Louis, MO 63141
Summary
This summary of 510(k)-safety and effectiveness information is being submitted in accordance with the requirements of 21 CFR Part 807.92
Company making the submission: 1.
| Name:Address: | Company making submission:Koven Technology, Inc.12125 Woodcrest Executive Dr.Suite 220St. Louis, MO 63141 | or | Correspondent (contract):Delphi Consulting Group11874 South Evelyn CircleHouston, Texas 770713404 |
|---|---|---|---|
| Telephone:Fax:Contact: | 1-314-542-21011-314-542-6020Paul G. KovenPresident | 1-713-723-40801-775-429-9524J. Harvey KnaussConsultant | |
| E-mail: | Koven@koven.com | harvey@delphiconsulting.com |
2. Device:
| Proprietary Name: | Echo Sounder ES-102EX Single-handed FetalDoppler |
|---|---|
| Common Name: | Ultrasonic Fetal Monitor |
| Classification Name: | Fetal ultrasonic monitor and accessories |
| Manufactured by: | Hayashi Denki Co., Ltd., Japan |
3. Predicate Device(s):
K023143, Echo Sounder, Model ES-102EX Fetal Doppler.
Classifications Names & Citations: 4.
Class II per 21 CFR 2660, Fetal ultrasonic monitor and accessories.
ട. Description:
The Echo Sounder ES-101EX Single-handed Fetal Doppler system utilizes the well understood principle of Doppler shift of an ultrasound signal to detect the flow of blood within the fetal heart wall motion and arteries.
The unit amplifies the high frequency oscillation output and then supplies this to the transmitter transducer. The high frequency voltage is converted to ultrasound by the transducer and is transmitted to external objects. The ultrasound transmitted by the transducer movers straight through biophysical object(s), and is reflected by the moving object (fetal heartbeat etc.). The reflected ultrasound is received by the receiving transducer and is converted into electronic signals again.
370 ES 101EX summary
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The converted electronic signals are amplified and then are detected. After removing unnecessary noise signals and improving S/N ratio at the filter circuit, the Doppler shift signals are amplified and are converted to audible sound pressure through a speaker or a headset. Simultaneously the signals are applied to the heart rate LCD display.
6. Indications for use:
Detection of fetal life, detection of multiple pregnancies, fetal screens from early gestation through delivery and general indication of fetal well being. Verify fetal heart viability following patient trauma.
7. Contra-indications:
None known at this time.
8. Comparison:
The Echo Sounder ES-101EX Single-handed Fetal Doppler has the same device characteristics as the predicate device.
9. Test Data:
The Echo Sounder ES-101X Single-handed Fetal Doppler device has been subjected to extensive safety, performance, and validations prior to release. Final testing for the system includes various performance tests designed to ensure that the device meets all of its functional requirements and performance specifications. Safety tests have further been performed to ensure the device complies with applicable industry and safety standards.
The Echo Sounder ES-101EX Single-handed Fetal Doppler device labeling includes instructions for safe and effective use. It includes Warning, Cautions, and quidance for use.
10. Literature Review:
A review of literature pertaining to the safety of Doppler Blood Flowmeters has been conducted. Appropriate safeguards have been incorporated in the design of the Echo Sounder ES-101EX Single-handed Fetal Doppler.
11. Conclusions:
The conclusion drawn from these tests is that the Echo Sounder ES-101EX Singlehanded Fetal Doppler device is equivalent in safety and efficacy to its predicated device.
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Image /page/2/Picture/1 description: The image shows the seal of the Department of Health & Human Services (HHS) of the USA. The seal features a stylized eagle with its wings spread, superimposed over a wavy line. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular pattern around the eagle.
Public Health Service
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
JUL 1 8 2003
Mr. Paul Koven President Koven Technology, Inc. 12125 Woodcrest Executive Drive, Ste. 220 ST LOUIS MO 63141
Re: K031504
Trade Name: Echo Sounder, Single-handed ES-101EX Regulation Number: 21 CFR 884.2660 Regulation Name: Fetal ultrasonic monitor and accessories Regulatory Class: II Product Code: 85 KNG Dated: May 12, 2003 Received: June 3, 2003
Dear Mr. Koven:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and we 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). 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.
This determination of substantial equivalence applies to the following transducers intended for use with the Echo Sounder, Single-handed ES-101EX, as described in your premarket notification:
Transducer Model Number
2.25 MHz
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807);
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labeling (21 CFR Part 801); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
This determination of substantial equivalence is granted on the condition that prior to shipping the first device, vou submit a postclearance special report. This report should contain complete information, including acoustic output measurements based on production line devices, requested in Appendix G, (enclosed) of the Center's September 30, 1997 "Information for Manufacturers Seeking Marketing Clearance of Diagnostic Ultrasound Systems and Transducers." If the special report is incomplete or contains unacceptable values (e.g., acoustic output greater than approved levels), then the 510(k) clearance may not apply to the production units which as a result may be considered adulterated or misbranded.
The special report should reference the manufacturer's 510(k) number. It should be clearly and prominently marked "ADD-TO-FILE" and should be submitted in duplicate to:
Food and Drug Administration Center for Devices and Radiological Health Document Mail Center (HFZ-401) 9200 Corporate Boulevard Rockville, Maryland 20850
This letter will allow you to begin marketing your device as described in your premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus permits your device to proceed to market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801, please contact the Office of Compliance at (301) 594-4591. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also. please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or at (301) 443-6597 or at its Internet address "http://www.fda.gov/cdrh/dsmamain.html".
If you have any questions regarding the content of this letter, please contact Rodrigo C. Perez at (301) 594-1212.
Sincerely yours,
David H. Lyman
Nancy C. Brogdon Director, Division of Reproductive, Abdominal and Radiological Devices Office of Device Evaluation
Center for Devices and Radiological Health
Enclosure(s)
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K 21567
Transducer (Probe): 2.25 MHz Transducer
Intended use: Diagnostic ultrasound imaging or fluid flow analysis of the human body as follows:
| Clinical Application | Mode of Operation | |||||||||
|---|---|---|---|---|---|---|---|---|---|---|
| A | B | M | PWD | CWD | ColorDoppler | AmplitudeDoppler | ColorVelocityImaging | Combined(specify) | Other | |
| Ophthalmic | ||||||||||
| Fetal | P | |||||||||
| Abdominal | ||||||||||
| Intraoperative (specify) | ||||||||||
| Intraoperative Neurological | ||||||||||
| Pediatric | ||||||||||
| Small Organ (specify) | ||||||||||
| Neonatal Cephalic | ||||||||||
| Adult Cephalic | ||||||||||
| Cardiac | ||||||||||
| Transesophageal | ||||||||||
| Transrectal | ||||||||||
| Transvaginal | ||||||||||
| Transurethral | ||||||||||
| Intravascular | ||||||||||
| Peripheral Vascular | ||||||||||
| Laparoscopic | ||||||||||
| Musculo-skeletalConventional | ||||||||||
| Musculo-skeletal Superficial | ||||||||||
| Other (specify) |
N = new indication, P = previously cleared by FDA, E = added under Appendix E
Additional comments: The above is a 2.25 MHz unfocused CW transducer for fetal heart rate detection. Released to market K915550.
(Please do not write below this line - continue on another page if needed) Concurrence of CDRH, Office of Device Evaluation (ODE)
David A. Symm
(Division Sign-Off) Division of Reproductive, and Radiological D 510(k) Number
| Prescription Use | |
|---|---|
| ------------------ | ---------------------------- |
Section 5
370 ES 101EX summary page 4
Page 4
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-3 C
510(k) Submission, Echo Sounder ES-101EX Koven Technology, Inc., St. Louis, MO 63141
Echo sounder ES-101EX System
Intended use: Diagnostic ultrasound imaging or fluid flow analysis of the human body as follaw:
| Clinical Application | Mode of Operation | |||||||||
|---|---|---|---|---|---|---|---|---|---|---|
| A | B | M | PWD | CWD | ColorDoppler | AmplitudeDoppler | ColorVelocityImaging | CombinedCapacity | Other | |
| Ophthalmic | ||||||||||
| Fetal | N | |||||||||
| Abdominal | ||||||||||
| Intraoperative (specify) | ||||||||||
| Intraoperative Neurological | ||||||||||
| Pediatric | ||||||||||
| Small Organ (specify) | ||||||||||
| Neonatal Cephalic | ||||||||||
| Adult Cephalic | ||||||||||
| Cardiac | ||||||||||
| Transesophageal | ||||||||||
| Transrectal | ||||||||||
| Transvaginal | ||||||||||
| Transurethral | ||||||||||
| Intravascular | ||||||||||
| Peripheral Vascular | ||||||||||
| Laparoscopic | ||||||||||
| Musculo skeletalConventional | ||||||||||
| Musculo skeletal Superficial | ||||||||||
| Other (specify) |
N .. now indication, P . previously cleaned by I DA, I - : sidded under Appondix F
(Pleasan do not wate below this line - continuo on another pagu it nouded) Concurrence of CDRH, Office of Device Evaluation (ODE)
David R. Hayson
(Division Sign-Off) Division of Reproductive. and Radiological D 510(k) Nur
Prescription Use /
370.1.2.1011-X: summary page 5
Section 5 Page S
19A
§ 884.2660 Fetal ultrasonic monitor and accessories.
(a)
Identification. A fetal ultrasonic monitor is a device designed to transmit and receive ultrasonic energy into and from the pregnant woman, usually by means of continuous wave (doppler) echoscopy. The device is used to represent some physiological condition or characteristic in a measured value over a period of time (e.g., perinatal monitoring during labor) or in an immediately perceptible form (e.g., use of the ultrasonic stethoscope). This generic type of device may include the following accessories: signal analysis and display equipment, electronic interfaces for other equipment, patient and equipment supports, and component parts. This generic type of device does not include devices used to image some relatively unchanging physiological structure or interpret a physiological condition, but does include devices which may be set to alarm automatically at a predetermined threshold value.(b)
Classification. Class II (performance standards).