(176 days)
The intended use of the Spacelabs Healthcare CardioExpress (CardioExpress) is to acquire ECG signals from adult and pediatric patients using ECG electrodes. CardioExpress is only intended to be used in hospitals or healthcare facilities by doctors and trained healthcare professionals. The cardiogram recorded by CardioExpress can help users to analyze and diagnose heart disease. However, the interpreted ECG with measurements and interpretive statements are only intended to be used on adult patients, and is offered to clinicians on an advisory basis only.
The Spacelabs Healthcare (Spacelabs) CardioExpress, Models 98400-SL3-IEC, 98400-SL3-AHA, 98400-SL6-IEC, 98400-SL6-AHA, 98400-SL12-IEC, and 98400-SL12-AHA, are a series of electrocardiographs (ECGs) designed to acquire, analyze, display, and record ECG signals from ECG electrodes connected to a patient.
After been amplified, filtered and analyzed, the ECG signal waveforms and analysis results are presented on a liquid crystal diode (LCD) display, and recorded on the paper through either a thermal or USB printer. ECG data, result and patient information may be stored in the memory file. The file can be transmitted to a personal computer (PC) through either an UART or Ethernet connection.
The CardioExpress can optionally contain auto analysis software which assists in performing auto measurement and auto interpretation of data. The CardioExpress consists of two (2) basic components: (1) the signal acquisition module, and (2) the central processing unit. All models contain a rechargeable battery.
The CardioExpress series of ECG monitors are provided in three (3) primary models: CardioExpress SL-3; CardioExpress SL-6; and CardioExpress SL-12.
Here's an analysis of the acceptance criteria and study information for the Spacelabs Healthcare CardioExpress Electrocardiograph, based on the provided text:
Acceptance Criteria and Device Performance
The provided document describes the Spacelabs Healthcare CardioExpress electrocardiographs (ECG) and their substantial equivalence to predicate devices. The "acceptance criteria" discussed are primarily compliance with various international standards for medical electrical equipment, including safety, usability, alarm systems, and specific requirements for ECGs. The "reported device performance" is the confirmation that the device complies with these standards and its predetermined specifications.
Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria Category | Specific Standard/Requirement | Reported Device Performance |
|---|---|---|
| Software Testing | - Robust software development process- Verification and validation per internal requirements- FDA guidance (e.g., "The content of premarket submissions for software contained in medical devices," "Off-the-shelf software use in medical devices," "General principles of software validation," "Cybersecurity for networked medical devices") | Test results indicate that the CardioExpress complies with its predetermined specifications and the applicable standards and guidance documents. |
| Electrical Safety Testing | IEC 60601-1: 1988, Am1: 1991, and Am2: 1995 (Medical electrical equipment. Part 1: Particular requirements for safety) | Test results indicated that CardioExpress complies with the Standard. |
| Electromagnetic Compatibility (EMC) Testing | IEC 60601-1-2: 2001 (Medical electrical equipment - Part 1-2: General requirements for safety - Collateral standard: Electromagnetic compatibility - Requirements and tests) | Test results indicated that CardioExpress complies with the Standards. |
| Performance Testing (General) | - Internal requirements- IEC 60601-1-6: 2004 (Usability)- IEC 60601-1-8: 2003, Am1: 2006 (Alarm systems)- IEC 60601-2-25: 1993, Am: 1999 (Particular requirements for the safety of electrocardiographs)- IEC 60601-2-51: 2003 (Particular requirements for safety, including essential performance, of recording and analyzing single channel and multichannel electrocardiographs) | Test results indicate that CardioExpress complies with its predetermined specifications and the applicable standards. Verification and validation activities were conducted to establish the performance and safety characteristics of CardioExpress. |
Study Information
It's important to note that the provided text is a 510(k) summary, which focuses on demonstrating substantial equivalence to a legally marketed predicate device rather than presenting a novel clinical trial for efficacy. Therefore, many of the detailed study parameters typically found in clinical trials for new AI/ML devices might not be explicitly stated or applicable in the same way.
-
Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):
- The document does not explicitly state a sample size for a test set in the context of a clinical performance study. The "test results" mentioned pertain to compliance with electrical, EMC, software, and general performance standards. These tests often use controlled environments and simulated data or hardware, not patient-derived datasets in a clinical sense.
- Similarly, there is no information provided regarding data provenance (country of origin, retrospective/prospective) for any test set involving patient data. This is consistent with the nature of a 510(k) submission primarily focusing on technical and safety standards compliance.
-
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 document mentions the device includes "auto analysis software which assists in performing auto measurement and auto interpretation of data." However, it clarifies that "the interpreted ECG with measurements and interpretive statements are only intended to be used on adult patients, and is offered to clinicians on an advisory basis only." This suggests the device's interpretation is an aid and not a definitive diagnosis that would require extensive expert ground truth establishment in a clinical performance study for this 510(k). The regulatory submission focuses on the safety and foundational performance of the device as an electrocardiograph.
-
Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- This information is not available in the provided text. Adjudication methods are typically associated with clinical performance studies where expert consensus is used to establish ground truth for a diagnostic interpretation. Since such a study for the auto-interpretation feature is not described, neither is an adjudication method.
-
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:
- No MRMC comparative effectiveness study is mentioned or appears to have been done for this 510(k) submission. The document states the auto-analysis software "assists" and is "offered to clinicians on an advisory basis only," indicating it's not claiming improved human reader performance through AI assistance in a comparative effectiveness study.
-
If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- The document implies the auto-analysis software can function in a "standalone" computational sense (performing auto measurement and interpretation). However, it explicitly states the interpreted ECG... is only intended to be used on adult patients, and is offered to clinicians on an advisory basis only. This means that while the algorithm can generate interpretations, its intended use always involves a human clinician for final diagnosis. Therefore, a standalone clinical performance study (where the algorithm's interpretation alone dictates patient management) would not be applicable given the advisory nature of the interpretation. The testing described primarily covers the technical correctness and safety of the device's functions.
-
The type of ground truth used (expert consensus, pathology, outcomes data, etc):
- Due to the nature of the 510(k) submission focusing on technical and safety compliance of a basic ECG device, specific ground truth types (like pathology or outcomes data) for clinical interpretation accuracy are not detailed. The "ground truth" for the performance tests mentioned would be the expected output or behavior according to the specified IEC standards and internal design specifications.
-
The sample size for the training set:
- The document does not provide a sample size for a training set. The device (an ECG machine) is designed to acquire and analyze ECG signals, and its software includes "auto analysis." This auto-analysis likely relies on well-established algorithms for ECG waveform and rhythm analysis, which may have been developed and refined over decades using large, diverse datasets. However, no specific details about "training sets" for a deep learning or complex AI model are presented in this submission.
-
How the ground truth for the training set was established:
- As no training set is described, information on how its ground truth was established is not provided. If "auto analysis software" refers to rule-based or conventional signal processing algorithms, the "ground truth" for their development would be based on established cardiology principles and guidelines, rather than a prospectively labeled dataset in the modern AI sense.
{0}------------------------------------------------
| Submission Date: | 25 January 2013 |
|---|---|
| Submitter: | Spacelabs Healthcare1 Harforde CourtJohn Tate RoadHertfordSG13 7NWUnited Kingdom |
| Submitter Contact: | Mr. Al Van HoudtSpacelabs HealthcarePhone: +1 (425) 657-7200, ext 5970Fax: +1 (425) 657-7210Email: al.vanhoudt@spacelabs.com |
| ApplicationCorrespondent: | Thomas KroenkePrincipal ConsultantSpeed To Market, Inc.PO Box 3018Nederland, CO 80466 USAtkroenke@speedtomarket.net303 956 4232 |
| Manufacturing Site: | Edan Instruments, Inc.2/F And 5/F, Block A/B, Unit 8, Xing Hua Building,Nanhai Rd, NanshanShenzhen CHINA 518067 |
| Trade Name: | Spacelabs Healthcare CardioExpress, Models 98400-SL3-IEC,98400-SL3-AHA, 98400-SL6-IEC, 98400-SL6-AHA, 98400-SL12-IEC, and 98400-SL12-AHA |
| Common Name: | Electrocardiograph |
| Classification Name: | Electrocardiograph |
| ClassificationRegulation: | 21 CFR §870.2340 |
| Product Code: | DPS |
{1}------------------------------------------------
·
:
.
| SubstantiallyEquivalent Devices: | New Spacelabs Models | Predicate510(k) Number | PredicateManufacturer / Model |
|---|---|---|---|
| Spacelabs HealthcareCardioExpress, Models98400-SL3-IEC,98400-SL3-AHA, | K090367 | Edan Instruments, Inc. /SE-601 SeriesElectrocardiograph | |
| 98400-SL6-IEC,98400-SL6-AHA,98400-SL12-IEC, and98400-SL12-AHA | K091513 | Edan Instruments, Inc. /SE-3, SE-300A, SE-300B,SE-6, SE-600, SE-12, SE-12 Express, SE-1200AND SE-1200 Express | |
| Device Description: | The Spacelabs Healthcare (Spacelabs) CardioExpress, Models 98400-SL3-IEC, 98400-SL3-AHA, 98400-SL6-IEC, 98400-SL6-AHA,98400-SL12-IEC, and 98400-SL12-AHA, are a series ofelectrocardiographs (ECGs) designed to acquire, analyze, display, andrecord ECG signals from ECG electrodes connected to a patient.After been amplified, filtered and analyzed, the ECG signalwaveforms and analysis results are presented on a liquid crystal diode(LCD) display, and recorded on the paper through either a thermal orUSB printer. ECG data, result and patient information may be storedin the memory file. The file can be transmitted to a personal computer(PC) through either an UART or Ethernet connection.The CardioExpress can optionally contain auto analysis softwarewhich assists in performing auto measurement and auto interpretationof data. The CardioExpress consists of two (2) basic components: (1)the signal acquisition module, and (2) the central processing unit. Allmodels contain a rechargeable battery.The CardioExpress series of ECG monitors are provided in three (3)primary models: CardioExpress SL-3; CardioExpress SL-6; andCardioExpress SL-12. | ||
| Intended Use: | The intended use of the Spacelabs Healthcare CardioExpress(CardioExpress) is to acquire ECG signals from adult and pediatricpatients using ECG electrodes. CardioExpress is only intended to beused in hospitals or healthcare facilities by doctors and trainedhealthcare professionals. The cardiogram recorded by CardioExpresscan help users to analyze and diagnose heart disease. However, theinterpreted ECG with measurements and interpretive statements areonly intended to be used on adult patients, and is offered to clinicians on an advisory basis only. |
{2}------------------------------------------------
| TechnologyComparison: | Characteristic | Predicate Devices | Proposed Devices |
|---|---|---|---|
| CardioExpress SL-3 | Channels | 3 | Same |
| Lead Color Coded Option | AHA and IEC | Same | |
| Leads | 12 standard | Same | |
| Acquisition Mode | 12 simultaneous leads | Same | |
| Heart Rate RecognitionTechnique | Peak-to-peak detection | Same | |
| Heart Rate Range | 30 - 300 beats per minute(BPM) | Same | |
| Recorder | Thermal dot-matrixrecorder | Same | |
| CardioExpress SL-6 | Channels | 6 | Same |
| Lead Color Coded Option | AHA and IEC | Same | |
| Leads | 12 standard | Same | |
| Acquisition Mode | 12 simultaneous leads | Same | |
| Heart Rate RecognitionTechnique | Peak-to-peak detection | Same | |
| Heart Rate Range | 30 - 300 beats per minute(BPM) | Same | |
| Recorder | Thermal dot-matrixrecorder | Same | |
| CardioExpress SL-12 | Channels | 12 | Same |
| Lead Color Coded Option | AHA and IEC | Same | |
| Leads | 12 standard | Same | |
| Acquisition Mode | 12 simultaneous leads | Same | |
| Heart Rate RecognitionTechnique | Peak-to-peak detection | Same | |
| Heart Rate Range | 30 - 300 beats per minute(BPM) | Same | |
| Recorder | Thermal dot-matrixrecorder | Same |
p
{3}------------------------------------------------
Summary of Performance Testing:
| Software Testing | Software was designed and developed according to a robust softwaredevelopment process, and was rigorously verified and validated.Software information is provided in accordance with internalrequirements and the following standards and guidance documents:FDA guidance: The content of premarket submissions for software contained in medical devices, 11.May 05; FDA guidance: Off-the-shelf software use in medical devices. 09 Sep 99; FDA guidance: General principles of software validation; Final guidance for industry and FDA staff, 11 Jan 02; and FDA guidance: Cybersecurity for networked medical devices containing off-the-shelf (OTS) software, 14 January 2005. Test results indicate that the CardioExpress complies with its predetermined specifications and the applicable standards and guidance documents. |
|---|---|
| Electrical SafetyTesting | CardioExpress was tested for performance in accordance with the following Standard:IEC 60601-1: 1988, Am1: 1991, and Am2: 1995. Medical electrical equipment. Part 1: Particular requirements for safety. Test results indicated that CardioExpress complies with the Standard. |
| ElectromagneticCompatibilityTesting | CardioExpress was tested for performance in accordance with the following Standard:IEC 60601-1-2: 2001, Medical electrical equipment - Part 1-2: General requirements for safety - Collateral standard: Electromagnetic compatibility - Requirements and tests. |
Test results indicated that CardioExpress complies with the Standards.
.
{4}------------------------------------------------
Performance Testing CardioExpress was tested for performance in accordance with internal requirements and the following standards:
- IEC 60601-1-6: 2004, Medical electrical equipment -- Part 1-6: . General requirements for safety - Colluteral standard: Usabilitv:
- IEC 60601-1-8: 2003, Am1: 2006, Medical electrical equipment -. Part 1-8: General requirements for safety - Collateral standard: General requirements, tests and guidance for alarm systems in medical electrical equipment and medical electrical svstems;
- IEC 60601-2-25: 1993. Am: 1999. Medical electrical equipment -. Part 2-25: Particular requirements for the safety of electrocardiographs; and
- IEC 60601-2-51: 2003, Medical electrical equipment Part 2-51: . Particular requirements for safety, including essential performance, of recording and analysing single channel and multichannel electrocardiographs.
Test results indicate that CardioExpress complies with its predetermined specifications and the applicable standards.
Conclusion
Verification and validation activities were conducted to establish the performance and safety characteristics of CardioExpress. The results of these activities demonstrate that CardioExpress is safe and effective when used in accordance with its intended use and labeling.
Therefore, CardioExpress is considered substantially equivalent to the predicate device.
{5}------------------------------------------------
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
July 23, 2013
Spacelabs Healthcare Ltd. c/o Mr. Thomas Kroenke PO Box 3018 Nederland, CO 80466
Re: K130207
Trade/Device Name: CardioExpress Electrocardiographs (SL3. SL6. and SL12) Regulation Number: 21 CFR 870.2340 Regulation Name: Electrocardiograph Regulatory Class: Class II Product Code: DPS Dated: June 24, 2013 Received: June 24, 2013
Dear Mr. Thomas Kroenke:
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. Iisting 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
{6}------------------------------------------------
Page 2 - Mr. Thomas Kroenke
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 contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. 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/ResourcesforYou/Industry/default.htm.
Sincerely yours,
Owen P. Faris -S
for Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
{7}------------------------------------------------
Indications for Use
| 510(k) Number (if known): | K130207 |
|---|---|
| Device Name: | Spacelabs Healthcare CardioExpress, Models 98400-SL3-IEC,98400-SL3-AHA, 98400-SL6-IEC, 98400-SL6-AHA,98400-SL12-IEC, and 98400-SL12-AHA |
| Indications for Use: | The intended use of the Spacelabs Healthcare CardioExpress(CardioExpress) is to acquire ECG signals from adult andpediatric patients using ECG electrodes. CardioExpress is onlyintended to be used in hospitals or healthcare facilities by doctorsand trained healthcare professionals. The cardiogram recordedby CardioExpress can help users to analyze and diagnose heartdisease. However, the interpreted ECG with measurements andinterpretive statements are only intended to be used on adultpatients, and is offered to clinicians on an advisory basis only. |
X Prescription Use (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 IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Digitally signed by
Owen P. Faris -S
Date: 2013.07.23
09:17:50-04'00'
Page 1 of 1
§ 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).