K Number
K043074
Device Name
LIBERTY SYSTEM
Date Cleared
2005-02-22

(106 days)

Product Code
Regulation Number
870.2340
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Liberty System, when used with Audicor Sensors on the chest wall, is intended for use in acquiring, analyzing and reporting ECG and heart sound data and to provide interpretation of the data in an integrated COR report for consideration by physicians. The Liberty System can be used as an add-on device to work in conjunction with select cardiographs, defibrillators, and patient monitors; or as a stand-alone electrocardiograph. The interpretations of ECG and heart sound data offered by the device are only significant when used in conjunction with physician over read as well as consideration of other relevant patient data. The device is intended for use only under the direct supervision of a physician, and is for use on adults (>= 18 years).
Device Description
The Liberty System is a pocket PC-based device that that can be used to allow clinicians access to the COR (correlated audioelectric cardiography) report including graphical display of MI, Ischemia, and LVH conditions as well as display of heart sound waveforms and identification of S3 and S4 heart sounds.
More Information

Not Found

No
The document explicitly states "Mentions AI, DNN, or ML: Not Found" and does not describe any AI/ML-specific features or performance metrics.

No
The device is intended for acquiring, analyzing, and reporting ECG and heart sound data for diagnostic purposes, not for treating a condition.

Yes

The "Intended Use / Indications for Use" section states that the device is intended for "acquiring, analyzing and reporting ECG and heart sound data and to provide interpretation of the data in an integrated COR report for consideration by physicians." Furthermore, the "Summary of Performance Studies" indicates compliance with "ANSI/AAMI EC-11 Standard for Diagnostic Electrocardiographic Devices," explicitly classifying it as a diagnostic device.

No

The device description explicitly states it is a "pocket PC-based device" and the intended use mentions "Audicor Sensors on the chest wall," indicating hardware components beyond just software. The performance studies also reference standards for hardware like ECG cables and leadwires.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD definition: In vitro diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections.
  • Device function: The Liberty System acquires, analyzes, and reports ECG and heart sound data directly from the patient's chest wall using sensors. This is a non-invasive procedure that does not involve testing samples taken from the body.
  • Intended Use: The intended use clearly describes the acquisition and analysis of physiological signals (ECG and heart sounds) from the patient's body.

Therefore, the Liberty System falls under the category of a medical device that performs physiological measurements and analysis, rather than an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

The Liberty System, when used with Audicor Sensors on the chest wall, is intended for use in acquiring, analyzing and reporting ECG and heart sound data and to provide interpretation of the data in an integrated COR report for consideration by physicians.

The Liberty System can be used as an add-on device to work in conjunction with select cardiographs, defibrillators, and patient monitors; or as a stand-alone electrocardiograph. The interpretations of ECG and heart sound data offered by the device are only significant when used in conjunction with physician over read as well as consideration of other relevant patient data.

The device is intended for use only under the direct supervision of a physician, and is for use on adults (> 18 years).

Product codes

DPS

Device Description

The Liberty System is a pocket PC-based device that that can be used to allow clinicians access to the COR (correlated audioelectric cardiography) report including graphical display of MI, Ischemia, and LVH conditions as well as display of heart sound waveforms and identification of S3 and S4 heart sounds.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

chest wall

Indicated Patient Age Range

adults (> 18 years)

Intended User / Care Setting

only under the direct supervision of a physician

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

The Liberty System was tested to the applicable requirements of the following standards, and shown to comply.
• ANSI/AAMI EC-11 Standard for Diagnostic Electrocardiographic Devices
• ANSI/AAMI EC 53 ECG Cables and Leadwires
• EN 60601-1-2 Standard for Medical Electrical Equipment Part 1-2: General Requirements for Safety - Collateral Standard: Electromagnetic Compatibility – Requirements and Tests
• IEC 60601-2-25 Medical Electrical Equipment Part 2: Particular requirements for the safety of electrocardiographs
• UL 60601-1 Standard for Medical Electrical Equipment: General Requirements for Safety

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K032145, K031182

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 870.2340 Electrocardiograph.

(a)
Identification. An electrocardiograph is a device used to process the electrical signal transmitted through two or more electrocardiograph electrodes and to produce a visual display of the electrical signal produced by the heart.(b)
Classification. Class II (performance standards).

0

.

Summary of Safety and Effectiveness

Summary of Safety and Effectiveness
As required by 21 CFR, part 807.92
Submitted By:Inovise Medical, Inc.
10565 SW Nimbus Ave, Suite 100
Portland, OR 97233-4311
Phone 503-431-3837
Fax 503-431-3801
Contact:Steve Hesler
Director, Quality and Regulatory
Date Prepared:November 4, 2004
Proprietary
Name:Liberty System
Common/ Usual
Name:Electrocardiograph
Classification:870.2340, 74 DPS
Performance
Standards:AANSI/AAMI EC 11
Intended Use:The Liberty System, when used with Audicor Sensors on the chest wall, is
intended for use in acquiring, analyzing and reporting ECG and heart sound data
and to provide interpretation of the data in an integrated COR report for
consideration by physicians.
The Liberty System can be used as an add-on device to work in conjunction with
select cardiographs, defibrillators, and patient monitors; or as a stand-alone
electrocardiograph. The interpretations of ECG and heart sound data offered by
the device are only significant when used in conjunction with physician over read
as well as consideration of other relevant patient data.
The device is intended for use only under the direct supervision of a physician, and
is for use on adults (> 18 years).
Device
Description:The Liberty System is a pocket PC-based device that that can be used to allow
clinicians access to the COR (correlated audioelectric cardiography) report
including graphical display of MI, Ischemia, and LVH conditions as well as display
of heart sound waveforms and identification of S3 and S4 heart sounds.
Test Summary &
Conclusion:The Liberty System was tested to the applicable requirements of the following
standards, and shown to comply.
• ANSI/AAMI EC-11 Standard for Diagnostic Electrocardiographic Devices
• ANSI/AAMI EC 53 ECG Cables and Leadwires
• EN 60601-1-2 Standard for Medical Electrical Equipment Part 1-2: General
Requirements for Safety - Collateral Standard: Electromagnetic Compatibility –
Requirements and Tests
• IEC 60601-2-25 Medical Electrical Equipment Part 2: Particular requirements for
the safety of electrocardiographs
• UL 60601-1 Standard for Medical Electrical Equipment: General Requirements
for Safety
Substantial
Equivalence:The Inovise Medical Liberty System is substantially equivalent to the Audicor
Cardiograph Expansion system (K032145) and the Mortara Instrument ELI 200+

:

:

1

Liberty Modification to Audicor™ 510(k) Submission

with Audicor Electrocardiograph (K031182).

Technological Characteristics: The Liberty System and the predicate device are technologically equivalent in that both acquire 12 lead ECG and heart sounds data from adult patients then present the data in the COR report format which includes graphic display of MI and LVH conditions along with detection and display of S3 and S4 heart sounds.

2

Image /page/2/Picture/2 description: The image shows the seal of the Department of Health & Human Services (HHS). The seal features a stylized eagle with three stripes representing the department's mission. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular pattern around the eagle.

FEB 2 2 2005

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

Inovise Medical, Inc. c/o Mr. Steve C. Hesler Director, Quality and Regulatory 10565 SW Nimbus Avenue, Suite 100 Portland, OR 97223-4311

Re: K043074

Trade Name: Liberty System Regulation Number: 21 CFR 870.2340 Regulation Name: Electrocardiograph Regulatory Class: Class II (two) Product Code: DPS Dated: February 17, 2005 Received: February 18, 2005

Dear Mr. Hesler:

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, IDrug, 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.

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); labeling (21 CFR Part 801); good manufacturing practice requirements as set

3

Page 2 -- Mr. Steve C. Hesler

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. This letter will allow you to begin marketing your device as described in your Section 510(k) 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 the 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) 594-4646. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97) you may obtain. 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 (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html

Sincerely yours,

Brimima for

Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

4

Indications for Use

510(k) Number (if known): ____________________________________________________________________________________________________________________________________________________

Device Name: _________________________________________________________________________________________________________________________________________________________________

Indications For Use:

The Liberty System, when used with Audicor Sensors on the chest wall, is intended for use in acquiring, analyzing and reporting ECG and heart sound data and to provide interpretation of the data in an integrated COR report for consideration by physicians.

The Liberty System can be used as an add-on device to work in conjunction with select cardiographs, defibrillators, and patient monitors; or as a stand-alone electrocardiograph. The interpretations of ECG and heart sound data offered by the device are only significant when used in conjunction with physician over read as well as consideration of other relevant patient data.

The device is intended for use only under the direct supervision of a physician, and is for use on adults (≥ 18 years).

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)

Concurrence of CDRH, Office of Device Evaluation (ODE)

Bimmana
Divisio

Sign-Off

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