K Number
K103427
Device Name
MOBILEECG SYSTEM
Manufacturer
Date Cleared
2011-03-24

(122 days)

Product Code
Regulation Number
870.2340
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The MobileECG System is intended to provide an interpretation of the resting 12 lead ECG in all situations, whether in a hospital or primary care setting. It is capable of diagnosing all commonly recognized ECG abnormalities such as myocardial infarction (MI), including acute MI, ventricular hypertrophy, abnormal ST-T changes and common abnormalities of rhythm. The MobileECG System is intended for use in adults and children of any age from birth upwards. The MobileECG System's interpretation software is not intended as sole means of diagnosis and is offered to physicians and clinicians on an advisory basis only in conjunction with the physician's knowledge of ECG.
Device Description
The MobileECG System is an electrocardiograph consisting of Model 950-12LR HHC module and CardioVu interpretation software. The Model 950-12LR HHC module is a small, light weight, single battery, wireless module designed to transmit 12Lead electrical heart activity of a patient to a computer. This module will transmit a patient's ECG wirelessly to a laptop, netbook, tablet, or desktop computer containing the CardioVu interpretation software from up to 100 feet away. Elimination of the cable reduces a source of artifact resulting in high-quality ECG tracings. Wireless dedicated and secure communication links the Model 950-12LR HHC module to CardioVu interpretation software. The CardioVu software receives, displays, and stores the patients ECG data wirelessly on a laptop, netbook, tablet, or desktop computer in "real time". The software also has the data using ECG algorithms for review by a physician or other qualified medical professional as an advisory basis only in conjunction with the physician's knowledge of ECG. The wireless feature allows the patient not to be tethered to the computer or a bulky box thus reducing motion artifacts caused by movement of the connecting cables and providing comfort to the patient.
More Information

No
The description mentions "ECG algorithms" but does not use any terminology associated with AI or ML, nor does it describe characteristics typical of AI/ML-based systems (like training data or performance metrics beyond equivalence testing).

No
The device is used for diagnosis and interpretation of ECGs, not for treating any condition.

Yes

Explanation: The "Intended Use / Indications for Use" section states that the MobileECG System is "capable of diagnosing all commonly recognized ECG abnormalities such as myocardial infarction (MI), including acute MI, ventricular hypertrophy, abnormal ST-T changes and common abnormalities of rhythm."

No

The device description explicitly states that the MobileECG System consists of both a hardware module (Model 950-12LR HHC module) and software (CardioVu interpretation software). The hardware module is responsible for acquiring the ECG data.

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.
  • MobileECG System Function: The MobileECG System directly measures the electrical activity of the heart in vivo (within the living body) using electrodes placed on the patient's skin. It does not analyze samples taken from the body.
  • Intended Use: The intended use clearly states it provides an interpretation of the resting 12 lead ECG, which is a measurement of the heart's electrical signals.

Therefore, the MobileECG System falls under the category of a medical device that performs a physiological measurement, not an in vitro diagnostic test.

N/A

Intended Use / Indications for Use

The MobileEG System is intended to provide an interpretation of the resting 12 lead ECG in all situations, whether in a hospital or primary care setting. It is capable of diagnosing all commonly recognized ECG abnormalities such as myocardial infarction (MI), including acute MI, ventricular hypertrophy, abnormal ST-T changes and common abnormalities of rhythm.

The MobileECG System is intended for use in adults and children of any age from birth upwards.

The MobileECG System's interpretation software is not intended as sole means of diagnosis and is offered to physicians and clinicians on an advisory basis only in conjunction with the physician's knowledge of ECG.

Product codes

DPS

Device Description

The MobileECG System is an electrocardiograph consisting of Model 950-12LR HHC module and CardioVu interpretation software.

The Model 950-12LR HHC module is a small, light weight, single battery, wireless module designed to transmit 12Lead electrical heart activity of a patient to a computer. This module will transmit a patient's ECG wirelessly to a laptop, netbook, tablet, or desktop computer containing the CardioVu interpretation software from up to 100 feet away.

Elimination of the cable reduces a source of artifact resulting in high-quality ECG tracings. Wireless dedicated and secure communication links the Model 950-12LR HHC module to CardioVu interpretation software.

The CardioVu software receives, displays, and stores the patients ECG data wirelessly on a laptop, netbook, tablet, or desktop computer in "real time". The software also has the data using ECG algorithms for review by a physician or other qualified medical professional as an advisory basis only in conjunction with the physician's knowledge of ECG. The wireless feature allows the patient not to be tethered to the computer or a bulky box thus reducing motion artifacts caused by movement of the connecting cables and providing comfort to the patient.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

The MobileECG System is intended for use in adults and children of any age from birth upwards.

Intended User / Care Setting

Not Found

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)

Non-clinical tests were performed to compare the MobileECG System to the predicated devices.

The following applicable standards were used to compare the MobileECG System to the predicated devices: ANS/AAMI EC11, IEC 60601-1-2, IEC 60601-1-1, IEC 60601-1-4, 21 CFR 898, ANSI/AAMI EC53, AND FCC Part 15.247.

After comparing predicated devices to Memtec's MobileECG System, results show that with the intended use, the Model 950-12LR HHC module with CardioVu interpretation software is equivalent in safety and effectiveness. Therefore Memtec supports a claim of substantial equivalence for the MobileECG System.

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

Not Found

Predicate Device(s)

K974351, K053083, K052883, K030535, K083749

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

2011

510(k) K103427

SUMMARY OF SAFETY AND EFFECTIVENE

510(k) SUMMARY of Safety and Effectiveness

1. General Information

| Submitter's Name:
Address: | Memtec Corporation
68 Stiles Road Unit D
Salem, NH 03079 |
|-------------------------------|----------------------------------------------------------------|
| Telephone: | 603 893-8080 Ext. 204 |
| Contact Person: | Dennis Garboski |
| Trade Name: | MobileECG System |
| Common Name: | Electrocardiograph (per 21 CFR 870.2340) |
| Class: | II |

2. Predicated Devices

The legally marketed predicated devices to which equivalence is being claimed is:

Micromedical, Inc.Biolog 3000K974351
Datrix, Inc.Cardio WiFi andK053083
Datrix, Inc.CardioServerK052883
QRS DiagnosticEKGCARD SYSTEMK030535
QRS DiagnosticCardioview 32K083749

3. Description of Device

·

The MobileECG System is an electrocardiograph consisting of Model 950-12LR HHC module and CardioVu interpretation software.

The Model 950-12LR HHC module is a small, light weight, single battery, wireless module designed to transmit 12Lead electrical heart activity of a patient to a computer. This module will transmit a patient's ECG wirelessly to a laptop, netbook, tablet, or desktop computer containing the CardioVu interpretation software from up to 100 feet away.

Elimination of the cable reduces a source of artifact resulting in high-quality ECG tracings. Wireless dedicated and secure communication links the Model 950-12LR HHC module to CardioVu interpretation software.

The CardioVu software receives, displays, and stores the patients ECG data wirelessly on a laptop, netbook, tablet, or desktop computer in "real time". The software also has the data using ECG algorithms for review by a physician or other qualified medical professional as an advisory basis only in conjunction with the physician's knowledge of ECG. The wireless feature allows the patient not to be tethered to the computer or a bulky box thus reducing motion artifacts caused by movement of the connecting cables and providing comfort to the patient.

1

Image /page/1/Picture/0 description: The image shows the text "K103427 P2/2" in a handwritten style. The text appears to be a code or identifier, possibly related to a document or item. The handwriting is clear and legible, with distinct characters.

4. Indications For Use

The MobileEG System is intended to provide an interpretation of the resting 12 lead ECG in all situations, whether in a hospital or primary care setting. It is capable of diagnosing all commonly recognized ECG abnormalities such as myocardial infarction (MI), including acute MI, ventricular hypertrophy, abnormal ST-T changes and common abnormalities of rhythm.

The MobileECG System is intended for use in adults and children of any age from birth upwards.

The MobileECG System's interpretation software is not intended as sole means of diagnosis and is offered to physicians and clinicians on an advisory basis only in conjunction with the physician's knowledge of ECG.

5. Non-clinical Tests Used in Determination of Substantial Equivalence

Non-clinical tests were performed to compare the MobileECG System to the predicated devices.

The following applicable standards were used to compare the MobileECG System to the predicated devices: ANS/AAMI EC11, IEC 60601-1-2, IEC 60601-1-1, IEC 60601-1-4, 21 CFR 898, ANSI/AAMI EC53, AND FCC Part 15.247.

6. Conclusions From Non-clinical Testing

After comparing predicated devices to Memtec's MobileECG System, results show that with the intended use, the Model 950-12LR HHC module with CardioVu interpretation software is equivalent in safety and effectiveness. Therefore Memtec supports a claim of substantial equivalence for the MobileECG System.

2

Image /page/2/Picture/1 description: The image shows the logo for the Department of Health & Human Services USA. The logo is a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" written around the perimeter. Inside the circle is an image of an eagle with its wings spread, with three lines representing the feathers. The eagle is facing to the right.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002

Memtec Corporation c/o Mr. Dennis Garboski President 68 Stiles Road Unit D Salem, NH 03079

MAR 2 4 2511

K103427 Re:

Trade/Device Name: MobileECG Regulation Number: 21 CFR 870.2340 Regulation Name: Electrocardiograph Regulatory Class: Class II (two) Product Code: DPS Dated: March 14, 2011 Received: March 16, 2011

Dear Mr. Garboski:

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 (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.

3

Page 2 –Mr. Dennis Garboski

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 go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/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,

17 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 STATEMENT

Indications for Use

510(k) Number(if known) KIO 3427

Device Name: MobileECG System

Indications for Use

The MobileECG System is intended to provide an analysis of rhythm and of detailed morphology of complex cardiac complexes for the resting 12 lead ECG in all situations, whether in a hospital or primary care setting. It is adjunct to the diagnosis of all commonly recognized ECG abnormalities such as myocardial infarction (MI), including acute MI, ventricular hypertrophy, abnormal ST-T changes and common abnormalities of rhythm.

The MobileECG System is intended for use in adults and children of any age from birth upwards.

Prescription Use

Over-The-Counter Use_

(Part 21 CFR 801 Subpart D)

(21 CFR 801 Subpart C)

(Please Do Not Write Below This Line)

Concurrence of CDRH, Office of Device Evaluation (ODE)

A.D.O. for B.Zuckerman

(Division Sign-Off) ular Device 510(k) Number