K Number
K100266
Manufacturer
Date Cleared
2010-04-29

(90 days)

Product Code
Regulation Number
870.2800
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Actiwave Recorder is an ambulatory, body-worn, dermally-affixed, physiological signal and activity recorder. Actiwave is indicated for use in recording physiological waveforms and activity as part of a physiological recording system. The subject is not restricted to a medical environment. The subject may participate in normal activities while the Actiwave recorder is in place. Actiwave is a multi-use recorder. Actiwave may be used wherever quantifiable measurement of human physiological signal waveforms and/or activity are needed. Actiwave may be used in a clinical setting or in basic scientific research under the supervision of a trained clinician.

Device Description

Activave is a compact, ambulatory, battery-operated physiological signal recorder. Actiwave is commonly known as an Ambulatory Electrocardiograph. Because of its small size and battery operation, Actiwave may be used in a clinical or non-clinical setting to record physiological signal waveforms while the patient is unattended. The device obtains its signal from the skin surface through the use of standard gel-type signal electrodes. Actiwave may be worn during daily activities and is fully ambulatory due to its small size and its battery-operated power source. Recorded data may be transferred later to a personal computer for storage and archiving. Actiwave does not provide any data viewing or data analysis functions.

AI/ML Overview

Here's a breakdown of the acceptance criteria and the study details for the Actiwave™ device based on the provided text:

1. Table of Acceptance Criteria and Reported Device Performance

Acceptance Criteria CategoryReported Device Performance
Input dynamic rangeMeets test criteria in the Special Control
Input ImpedanceMeets test criteria in the Special Control
Gain StabilityMeets test criteria in the Special Control
System noiseMeets test criteria in the Special Control
Multichannel crosstalkMeets test criteria in the Special Control
Frequency responseMeets test criteria in the Special Control
Timing accuracyMeets test criteria in the Special Control
Temporal alignmentMeets test criteria in the Special Control
Electrical safetyTested according to internationally recognized standards; raised no issues.
Electromagnetic interferenceTested according to internationally recognized standards; raised no issues.

2. Sample Size Used for the Test Set and Data Provenance

The provided text does not specify a sample size for a test set involving human subjects or data. The performance testing described is focused on the device's technical specifications and adherence to "Special Control" criteria. It is a non-clinical performance assessment.

  • Sample Size (Test Set): Not specified (non-clinical performance testing).
  • Data Provenance: Not applicable in the context of human data. The testing was a non-clinical assessment of the device's adherence to specific technical performance standards.

3. Number of Experts Used to Establish Ground Truth for the Test Set and Their Qualifications

The provided text does not mention the use of experts to establish ground truth for a test set. The performance evaluation was based on predetermined technical criteria defined in a "Special Control."

4. Adjudication Method for the Test Set

The provided text does not describe any adjudication method. The assessment was against predefined technical specifications, not human interpretation.

5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

No, an MRMC comparative effectiveness study was not done. The submission is for a device that records physiological signals and activity; it does not perform analysis or diagnosis, which would typically involve human readers. The performance evaluation was a non-clinical assessment of the device's technical specifications when compared to a predicate device.

6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

The device itself is a standalone recorder. The performance testing was of this standalone device's technical specifications. However, the term "standalone" in the context of AI performance usually refers to an algorithm's diagnostic or analytical capability. The Actiwave does not perform data viewing or data analysis functions; it is solely a recorder. Therefore, while the device's physical and electronic performance was assessed in a standalone manner (without a human interpreting its output), it's not a standalone AI algorithm performance study as commonly understood in this context.

7. The Type of Ground Truth Used

The "ground truth" for the performance testing of the Actiwave device was the technical specifications and test criteria outlined in the Special Control for this device type. This is a form of engineering or design "ground truth" rather than clinical ground truth (e.g., pathology, expert consensus on patient data).

8. The Sample Size for the Training Set

The provided text does not indicate a training set sample size. This device is a physiological signal recorder, not an AI algorithm that would typically require a training set of data. Its function is to acquire and log data based on established scientific principles of signal recording.

9. How the Ground Truth for the Training Set Was Established

Since there is no mention of a training set for an AI algorithm, there is no information on how ground truth for a training set was established. The device relies on fundamental scientific and engineering principles for signal acquisition and recording, not on machine learning from a data-driven training set.

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510(k) Premarket Notification Actiwave™M

5.0 510(K) SUMMARY

APR 2 9 2010

5.1 Summary information

5.1.1 Submitter's name and address

Howard Smith, Engineering Director CamNtech, UK, Ltd. Upper Pendrill Court Ermine Street North Papworth Everard Cambridge, United Kingdom CB233UY Tel: 011-44-1480-831223 011-44-1480-831733 Fax:

Date summary was prepared: 01/25/2010

5.1.2 Name of device

Trade Name:ActiwaveTM
Common Name:Digital Ambulatory Monitor
Classification Name:Electrocardiograph, Ambulatory (Without
Analysis)
Product Regulation:21 CFR 870.2800

Product Code:

MWJ

5.1.3 Identification of predicate device

SEER Light Compact Digital Holter Recorder, 510(k) Number : K021470

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K100266 P2/4

510(k) Premarket Notification Actiwave™M

5.2 Device description

5.2.1.1 Functions of the device

Activave is a compact, ambulatory, battery-operated physiological signal recorder. Actiwave is commonly known as an Ambulatory Electrocardiograph. Because of its small size and battery operation, Actiwave may be used in a clinical or non-clinical setting to record physiological signal waveforms while the patient is unattended. The device obtains its signal from the skin surface through the use of standard gel-type signal electrodes. Actiwave may be worn during daily activities and is fully ambulatory due to its small size and its battery-operated power source. Recorded data may be transferred later to a personal computer for storage and archiving. Actiwave does not provide any data viewing or data analysis functions.

5.2.1.2 Basic scientific concepts

The Actiwave device acquires and logs digital data whose values represent the amplitude-varying physiological waveform signal voltages at progressive time intervals. The scientific concepts and technologies that are used to sense the signals are summarized in Table 5.1.

Physiological ParameterRecorder UsedTechnologyValue Obtained
Physiological waveformActiwave1-, 2-, and 4-channel recorders andActiwave CardioAmplifier senses andamplifies voltage signal.Digital valuecorresponding toinstantaneous signalvoltage.
ActivityActiwave CardioSignal from accelerometeramplifier is digitized andrecorded.Digital valuecorresponding to ActivityCounts or acceleration.

TABLE 5.1: BASIC TECHNOLOGIES USED FOR PHYSIOLOGICAL SIGNAL RECORDING IN ACTIWAVE RECORDERS

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510(k) Premarket Notification Actiwave™e™

5.2.1.3 Physical characteristics of Recorder

Pertinent physical characteristics of the Actiwave Recorder are shown in Table 5.2.

TABLE 5.2: PHYSICAL CHARACTERISTICS OF ACTIWAVE

RECORDER

ParameterValueCondition/Note
SizeActiwave 1-channel: 19x27x9 mmActiwave 2-channel: 25x27x9 mmActiwave 4-channel: 37x27x9 mmActiwave Cardio: 32diam x 10 mmOuter dimensions
Weight1-channel: 5 gm2-channel: 6 gm4-channel: 9 gmCardio: 10 gmWith no electrodesattached
Case materialPolycarbonate/ABS
Attachment typeStainless steel snap connector orstandard no-touch connectors
Battery type3.0 volt lithium rechargeableNot user replaceable
IndicatorsNone

5.3 Statement of the intended use of the device

The Actiwave Recorder is an ambulatory, body-worn, dermally-affixed, physiological signal and activity recorder having 1, 2, or 4 channels of physiological waveform storage. Actiwave is indicated for use in recording physiological waveforms and activity as part of a physiological recording system. The subject is not restricted to a medical environment. The subject may participate in normal activities while the Actiwave recorder is in place. Actiwave is a multi-use recorder. Actiwave may be used wherever quantifiable measurement of human physiological signal waveforms and/or activity are needed. Actiwave may be used in a clinical setting or in basic scientific research under the supervision of a trained clinician.

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Image /page/3/Picture/0 description: The image contains the alphanumeric strings "K100266" and "P4/4". The strings are written in a handwritten style with black ink on a white background. The strings appear to be some kind of identifier or code.

510(k) Premarket Notification Actiwave™

Technological characteristics of the device compared to predicate 5.4 device

Actiwave and the SEER Light Compact Digital Holter Recorder (FDA 510(k) Number: K021470) are each physiological recording systems based upon the concept of an ambulatory, unattended physiological recorder that logs physiological data to the recorder. Each of these devices is a solid-state recorder with electronic amplifiers, data collection means, and with the ability to store data until it is transferred to a personal computer. Actiwave and the SEER Light Compact Digital Holter Recorder are of similar mechanical materials, construction, size, and human interface characteristics. Activave and the SEER Light Compact Digital Holter Recorder are of similar electronic design and their operational characteristics are functionally equivalent.

5.5 Assessment of non-clinical performance data and safety testing

The performance of the Actiwave Recorder has been tested in accordance with a Special Control specific to this device type. The categories of tests applied to this device are entirely contained within the Special Control. These categories are: Input dynamic range, Input Impedance, Gain Stability, System noise, Multichannel crosstalk, Frequency response, Timing accuracy, and Temporal alignment. For all the categories, we have determined that Actiwave performance meets the test criteria in the Special Control. In addition to performance testing, the device has been tested for electrical safety and electromagnetic interference according to internationally recognized standards. The testing according to these standards has raised no issues as to the safety and effectiveness of the present device or the present device compared to the predicate device.

5.6 Conclusion

The results of the tests conducted in accordance with the Special Control demonstrate that the Actiwave is as safe, as effective, and performs as well as the predicate device.

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DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/4/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular border with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" arranged around the top half of the circle. Inside the circle is an abstract symbol resembling a stylized bird or human figure, with flowing lines forming the shape of a wing or hair.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Room W-O66-0609 Silver Spring, MD 20993-0002

CamNtech, UK, Ltd. c/o Mr. Howard Smith Engineering Director Upper Pendrill Court, Ermine Street North Papworth Everard, Cambridge, UK CB233UY

APR 2 9 2010

Re: K100266

Device Name: Actiwave™ Regulation Number: 21 CFR 870.2800 Regulation Name: Ambulatory Electrocardiograph (Without Analysis) Regulatory Class: Class II (Two) Product Code: MWJ Dated: January 25, 2010 Received: January 29, 2010

Dear Mr. Smith:

. 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.

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

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Page 2 - Mr. Howard Smith

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 go to http://www.fda.gov/AboutFDA/CentersOffices/CDRF/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. 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

Brom D. Zuckerman, M.D.

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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1.0 INDICATIONS FOR USE STATEMENT

Indications for Use

510(k) Number (if known): K100266

Device Name: Actiwave™

Indications For Use:

The Actiwave Recorder is an ambulatory, body-worn, dermally-affixed, physiological signal and activity recorder. Actiwave is indicated for use in recording physiological waveforms and activity as part of a physiological recording system. The subject is not restricted to a medical environment. The subject may participate in normal activities while the Actiwave recorder is in place. Actiwave is a multi-use recorder. Actiwave may be used wherever quantifiable measurement of human physiological signal waveforms and/or activity are needed. Actiwave may be used in a clinical setting or in basic scientific research under the supervision of a trained clinician.

Prescription Use AND/OR -Over-The-Counter Use (Part 21 CFR 801 Subpart D) . (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)

(Division Sign-Off)
Division of Cardiovascular Devices
510(k) Number K100266

Page 4-1

§ 870.2800 Medical magnetic tape recorder.

(a)
Identification. A medical magnetic tape recorder is a device used to record and play back signals from, for example, physiological amplifiers, signal conditioners, or computers.(b)
Classification. Class II (performance standards).