(183 days)
The M Series with Real CPR Help is intended to provide visual and audio feedback to encourage rescuers to perform chest compressions at the AHA/ERC recommended rate of 100 compressions per minute. Voice and visual prompts encourage the compression depth of greater than 1.5 to 2 inches for adult patients. The CPR monitoring function is not intended for use on paients under 8 years of age
The ZOLL M Series with Real CPR Help™ provides 'real-time' user CPR assistance when used in conjunction with ZOLL CPR-D-padz™ and CPR Stat-padz™ Multi-function Electrodes. CPR feedback is provided via ZOLL's unique sensor assembly that relays user compression data to the ZOLL. M Series. The ZOLL M Series with Real CPR Help™ provides a metronome to encourage rescuers to perform CPR at the AHA/ECR recommended rate of 100 compressions per minute (CPM). The ZOLL M Series additionally provides chest compression performance feedback to the user through displayed symbols, text messages and voice prompts.
The ZOLL M Series Defibrillator is indicated for the defibrillation, Noninvasive Transcutaneous Pacing, multi-parameter monitoring of patient vital signs, including: ECG Monitoring, Pulse Oximetry, end tidal CO2, 12-Lead ECG monitoring, non-invasive blood pressure measurement, CPR performance and data printing and recording for resting patients in critical care and transport.
The provided text describes ZOLL M Series with Real CPR Help™ and its functionalities but does not contain detailed information about acceptance criteria and a specific study proving the device meets those criteria, as typically presented in a scientific publication or a dedicated performance evaluation section.
Instead, the document is a 510(k) summary, which focuses on demonstrating substantial equivalence to a legally marketed predicate device rather than presenting a detailed performance study with specific metrics, acceptance criteria, and ground truth establishment as would be found in a clinical trial report.
However, based on the intended use and description of the device, we can infer some implicit performance goals and how the provided text generally addresses them.
Inferred Acceptance Criteria and Reported Device Performance
| Criteria Category | Specific Criteria (Inferred from Intended Use) | Reported Device Performance (from text) |
|---|---|---|
| CPR Rate Guidance | Accurately provides metronome/feedback for 100 compressions per minute (CPM). | "The ZOLL M Series with Real CPR Help™ provides a metronome to encourage rescuers to perform CPR at the AHA/ECR recommended rate of 100 compressions per minute (CPM)." "The ZOLL M Series with Real CPR Help™ is intended to provide visual and audio feedback to encourage rescuers to perform chest compressions at the AHA/ERC recommended rate of 100 compressions per minute." |
| CPR Depth Guidance | Accurately provides feedback for a compression depth of 1.5 to 2 inches (3.8 to 5.0 cm) for adult patients. | "Voice and visual prompts encourage a compression depth of 1.5 to 2 inches (3.8 to 5.0 cm) for adult patients." "Voice and visual prompts encourage the compression depth of greater than 1.5 to 2 inches for adult patients." |
| CPR Feedback Mechanism | Provides clear visual symbols, text messages, and voice prompts for CPR performance. | "The ZOLL M Series additionally provides chest compression performance feedback to the user through displayed symbols, text messages and voice prompts." "The acquired depth and rate signals are used to provide CPR compression performance feedback to the user through displayed symbols, text messages and voice prompts which are equivalent to other ZOLL defibrillators with user CPR feedback." |
| Safety & Functional Integrity | Device modifications do not degrade or impact other product features, functions, or performance specifications. Compliance with applicable industry and safety standards. | "Extensive performance testing ensures that the ZOLL M Series with Real CPR Help™ performs as well as the indicated predicate devices and meets all of its functional requirements and performance specifications. Safety testing assures the device complies with applicable sections of recognized industry and safety standards." "Functional testing of the device's features and functions was conducted to ensure that the modifications to the software did not degrade or impact other product features, functions or performance specifications." |
| Substantial Equivalence | The device performs equivalently to previously marketed ZOLL defibrillators with CPR feedback. | "The characteristics, features and functions of the Real CPR Help™ are substantially equivalent to other ZOLL Defibrillators equipped with CPR Feedback." "Performance and safety testing of the ZOLL M Series with Real CPR Help™ demonstrates that its features and functions are substantially equivalent to those of the indicated commercially distributed predicate device with regard to performance, safety and effectiveness." |
Missing Information (Not provided in the document for a typical performance study):
The document does not detail a specific "study" in the traditional sense of a clinical trial or a statistically powered performance evaluation with primary and secondary endpoints, sample sizes, and ground truth methodologies that are usually associated with AI/ML device performance descriptions. Here's why and what's missing:
- Sample size used for the test set and the data provenance: This information is not provided. The document mentions "extensive performance testing" and "functional testing" but does not specify sample sizes (e.g., number of compressions evaluated, number of subjects, or data points) or the origin of any data used for these tests.
- Number of experts used to establish the ground truth for the test set and the qualifications of those experts: This information is not provided. The device provides feedback based on AHA/ERC guidelines, which are expert-derived, but the document doesn't describe an independent expert ground truth establishment for testing the Real CPR Help's accuracy in delivering those prompts. The "ground truth" here is implied to be the established AHA/ERC guidelines themselves for target rate and depth.
- Adjudication method (e.g., 2+1, 3+1, none) for the test set: Not applicable based on the provided text, as no expert adjudication for ground truth is described.
- 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: This is not provided and is not applicable in the context of this device. The device assists rescuers (not "readers") in performing CPR. The document states its intended use is to "encourage rescuers to perform chest compressions" at recommended rates and depths. It doesn't present an effectiveness study to quantify how much rescuers improve with the device vs. without it.
- If a standalone (i.e., algorithm only without human-in-the-loop performance) was done: The "Real CPR Help" feature is the algorithm, and its performance is inherently tied to providing feedback to a human-in-the-loop. The textual performance descriptions ("provides metronome," "provides feedback," "acquires signals") relate to its standalone function of processing data and generating prompts. However, a formal standalone performance study with specific metrics (e.g., accuracy of rate detection, accuracy of depth detection against a gold standard sensor) is not detailed.
- The type of ground truth used (expert consensus, pathology, outcomes data, etc.): The "ground truth" for the feedback mechanism is the AHA/ERC recommended guidelines for CPR rate (100 CPM) and depth (1.5-2 inches). The accuracy of the device would then be measured by how well its internal sensors and algorithms detect and report these parameters, and how effectively its prompts align with these guidelines. The document does not describe the specific methodology for establishing measurement ground truth (e.g., using a high-precision force/motion sensor as a gold standard to validate the device's sensor readings).
- The sample size for the training set: This information is not provided. Given the nature of medical device 510(k) submissions for non-AI/ML systems, details about "training sets" are often not explicitly mentioned. The device's functionality likely relies on established signal processing and measurement techniques rather than a "trained" machine learning model in the contemporary sense.
- How the ground truth for the training set was established: This information is not provided. Again, for a traditional medical device (before the widespread use of deep learning), a "training set" doesn't typically exist in the same way as an AI/ML model. The device is engineered to meet specific physical and physiological parameters based on established guidelines.
In summary, the provided document is a regulatory submission demonstrating substantial equivalence, not a detailed scientific paper on device performance. It attests to the device's functional integrity and adherence to intended physiological targets (AHA/ERC guidelines) through general claims of "extensive performance testing" and "functional testing" but lacks the granular data and methodological details requested for a comprehensive performance study description.
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Image /page/0/Picture/0 description: The image shows a handwritten alphanumeric string. The string appears to be "K062537". The characters are written in black ink on a white background. The handwriting is somewhat stylized, with the numbers being slightly slanted.
Image /page/0/Picture/1 description: The image shows the word "ZOLL" in large, bold letters at the top. Below the word, the phrase "Advancing Resuscitation. Today." is written in a smaller font. The text is black and the background is white.
ZOLL Medical Corporation
Worldwide Headquarters 269 Mill Road Chelmsford, MA 01824-4 U.S.A
978 421-9655
978 421-0025 Main Fax
510(k) Summary:
Submitter's Name and Address:
ZOLL Medical Corporation 269 Mill Road Chelmsford, MA 01824-4105 (978) 421-9655
Contact Person:
Sean Reynolds
(978) 421-9655, Ext. 9386
Date Summary Prepared:
August 1, 2006
Device:
ZOLL M Series with Real CPR Help™
Classification:
Automactic External Defibrillators: Class III (21 CFR 870,5310)
Cardiopulmonary Resuscitation Aid: Class III (21 CFR 870.5200)
Description:
The ZOLL M Series with Real CPR Help™ provides 'real-time' user CPR assistance when used in conjunction with ZOLL CPR-D-padz™ and CPR Stat-padz™ Multi-function Electrodes. CPR feedback is provided via ZOLL's unique sensor assembly that relays user compression data to the ZOLL. M Series. The ZOLL M Series with Real CPR Help™ provides a metronome to encourage rescuers to perform CPR at the AHA/ECR recommended rate of 100 compressions per minute (CPM). The ZOLL M Series additionally provides chest compression performance feedback to the user through displayed symbols, text messages and voice prompts.
The ZOLL M Series Defibrillator is indicated for the defibrillation, Noninvasive Transcutaneous Pacing, multi-parameter monitoring of patient vital signs, including: ECG Monitoring, Pulse Oximetry, end tidal CO2, 12-Lead ECG monitoring, non-invasive blood pressure measurement, CPR performance and data printing and recording for resting patients in critical care and transport. The ZOLL M Series is intended for use by qualified medical personnel who are trained and authorized to respond to medical emergencies, to facilitate the ability
FEB 2 8 2007
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to monitor and assess the physiological characteristics of the indicated patient populations in a critical care environment. The device is light weight and easy to carry for transport.
The device is capable of providing Basic Life-Saving (BLS) personnel the option of analyzing a patient's ECG signal via the Advisory feature on the device. The Advisory Algorithm will determine if the acquired heart rhythm is shockable or non-shockable and will prompt the end-user to provide therapy in the event of a shock advised determination. The user will be prompted to re-assess the patient in the event a no shock advised determination is returned.
Intended Use:
The M Series with Real CPR Help™ provides visual and audio feedback designed to encourage rescuers to perform chest compressions at the AHA/ERC recommended rate of 100 compressions per minute. Voice and visual prompts encourage a compression depth of 1.5 to 2 inches (3.8 to 5.0 cm) for adult patients.
The CPR monitoring function is not intended for use on patients under 8 years of age.
Substantial Equivalence:
The features and functions of the ZOLL M Series with Real CPR Help™ are identical to those of the M Series Defibrillator, with the exception of the incorporation of Real CPR Help™. The characteristics, features and functions of the Real CPR Help™ are substantially equivalent to other ZOLL Defibrillators equipped with CPR Feedback.
Comparison of Technological Characteristics
The ZOLL M Series with Real CPR Help™ acquires compression depth and rate signals from the CPR sensor incorporated in the currently marketed ZOLL CPR-D.padz™ and CPR Stat padz™ Multi-function Electrodes. The acquired depth and rate signals are used to provide CPR compression performance feedback to the user through displayed symbols, text messages and voice prompts which are equivalent to other ZOLL defibrillators with user CPR feedback.
Performance Testing:
Extensive performance testing ensures that the ZOLL M Series with Real CPR Help™ performs as well as the indicated predicate devices and meets all of its functional requirements and performance specifications. Safety testing assures the device complies with applicable sections of recognized industry and safety standards.
Functional testing of the device's features and functions was conducted to ensure that the modifications to the software did not degrade or impact other product features, functions or performance specifications.
Conclusion
Performance and safety testing of the ZOLL M Series with Real CPR Help™ demonstrates that its features and functions are substantially equivalent to those of the indicated commercially distributed predicate device with regard to performance, safety and effectiveness.
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SECTION 4 - INDICATIONS FOR USE
510(k) Number (if known):
ZOLL M Series Device Name:
Defibrillator Function
Intended Use - Manual Operation
Use of the M Series products in the manual mode for defibrillation is indicated on victims of cardiac arrest where there is apparent lack of circulation as indicated by:
- Unconsciousness .
- . Absence of breathing
- . Absence of pulse.
This product should be used only by qualified medical personnel for converting ventricular fibrillation and rapid ventricular tachycardia to sinus rhythm or other cardiac rhythms capable of producing hemodynamically significant heart beats.
Intended Use - Semiautomatic Operation (AED)
The M Series products are designed for use by emergency care personnel who have completed training and certification requirements applicable to the use of a defibrillator where the device operator controls delivery of shocks to the patient.
They are specifically designed for use in early defibrillation programs where the delivery of a defibrillator shock during resuscitation involving CPR, transportation, and definitive care are incorporated into a medically-approved patient care protocol.
The M Series products must be prescribed for use by a physician or medical advisor of an emergency response team.
Use of the device in the Semiautomatic mode for defibrillation is indicated on victims of cardiac arrest where there is apparent lack of circulation as indicated by:
- Unconsciousness .
- t Absence of breathing
- . Absence of pulse
Specifications for the ECG rhythm analysis function are provided at the end of this section
(continued on next page)
Prescription Use X (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
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External Pacemaker (Pacer Version Only)
Intended Use -- Pacemaker
This product may be used for temporary external cardiac pacing in conscious or unconscious patients as an alternative to endocardial stimulation.
Note: This device must not be connected to internal pacemaker electrodes.
The purposes of pacing include:
Resuscitation from standstill or bradycardia of any etiology:
Noninvasive pacing has been used for resuscitation from cardiac standstill, reflex vagal standstill, drug induced standstill (due to procainamide, quinidine, digitalis, b- blockers, verapamil, etc.) and unexpected circulatory arrest (due to anesthesia, surgery, angiography, and other therapeutic or diagnostic procedures). It has also been used for temporary acceleration of bradycardia in Stokes-Adams disease and sick-sinus syndrome. It is safer, more reliable, and more rapidly applied in an emergency than endocardial or other temporary electrodes.
As a standby when standstill or bradycardia might be expected:
Noninvasive pacing may be useful as a standby when cardiac arrest or symptomatic bradycardia might be expected due to acute myocardial infarction, drug toxicity, anesthesia or surgery. It is also useful as a temporary treatment in patients awaiting pacemaker implants or the introduction of transvenous therapy. In standby pacing applications, noninvasive pacing may provide an alternative to transvenous therapy that avoids the risks of displacement, infection, hemorrhage, embolization, perforation, phlebitis and mechanical or electrical stimulation of ventricular tachycardia or fibrillation associated with endocardial pacing.
Suppression of tachycardia:
Increased heart rates in response to external pacing often suppress ventricular ectopic activity and may prevent tachycardia.
Pediatric Pacing
Pacing can be performed on pediatric patients weighing 33lbs / 15kg or less using special ZOLL. pediatric MFE Pads. Prolonged pacing (in excess of 30 minutes), particularly in neonates, could cause burns. Periodic inspection of the underlying skin is recommended.
Image /page/3/Figure/14 description: The image shows the text "Intended Use - Real CPR Help™". The text is black and appears to be part of a document or label. A partial circle is drawn around the text.
The ZOLL M Series with Real CPR Helo™ is intended to provide visual and audio feedback to encourage rescuers to perform chest compressions at the AHA/ERC recommended rate of 100 compressions per minute. Voice and visual prompts encourage a compression depth of greater than 1.5 to 2 inches (3.8 to 5.0 cm) for adult patients.
The CPR monitoring function is not intended for use on patients under 8 years of age.
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Image /page/4/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo features a stylized eagle with three lines forming its body and wings. The eagle faces to the right. The text "DEPARTMENT OF HEALTH AND HUMAN SERVICES USA" is arranged in a circular pattern around the eagle.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
FEB 2 8 2007
Zoll Medical Corporation C/O Sean Reynolds Regulatory Affairs Engineer 269 Mill Road Chelmsford, MA 01824
Re: K062537 Trade/Device Name: M Series with Real CPR Help Regulation Number: 21 CFR 870.5310 Regulatory Class: Class III Product Code: MKJ Dated: February 16, 2007 Received: February 16, 2007
Dear Mr. Reynolds:
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.
If your device is classified (sec 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 complics with other requirements of the Act
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Page 2 - Mr. Reynolds
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 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 (240) 276-0120. 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 from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely yours.
Blymmman for
Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known):_K062537
Device Name:__M Series with Real CPR Help
Indications For Use: The M Series with Real CPR Help is intended to provide visual and audio feedback to encourage rescuers to perform chest compressions at the AHA/ERC recommended rate of 100 compressions per minute. Voice and visual prompts encourage the compression depth of greater than 1.5 to 2 inches for adult patients. The CPR monitoring function is not intended for use on paients under 8 years of age
Prescription Use AND/OR Over-The-Counter Use X (Part 21 CFR 801 Subpart D) (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Bhumima
§ 870.5310 Automated external defibrillator system.
(a)
Identification. An automated external defibrillator (AED) system consists of an AED and those accessories necessary for the AED to detect and interpret an electrocardiogram and deliver an electrical shock (e.g., battery, pad electrode, adapter, and hardware key for pediatric use). An AED system analyzes the patient's electrocardiogram, interprets the cardiac rhythm, and automatically delivers an electrical shock (fully automated AED), or advises the user to deliver the shock (semi-automated or shock advisory AED) to treat ventricular fibrillation or pulseless ventricular tachycardia.(b)
Classification. Class III (premarket approval)(c)
Date PMA or notice of completion of PDP is required. A PMA will be required to be submitted to the Food and Drug Administration by April 29, 2015, for any AED that was in commercial distribution before May 28, 1976, or that has, by April 29, 2015, been found to be substantially equivalent to any AED that was in commercial distribution before May 28, 1976. A PMA will be required to be submitted to the Food and Drug Administration by April 29, 2015, for any AED accessory described in paragraph (a) that was in commercial distribution before May 28, 1976, or that has, by April 29, 2015, been found to be substantially equivalent to any AED accessory described in paragraph (a) that was in commercial distribution before May 28, 1976. Any other AED and AED accessory described in paragraph (a), shall have an approved PMA or declared completed PDP in effect before being placed in commercial distribution.