(231 days)
The Tempus Pro is a portable vital signs monitor intended to be used by clinicians and medically qualified personnel for the attended or unattended monitoring of single or multiple vital signs in clinical and pre-hospital care applications. The device is indicated for: 3 & 5 Lead ECG monitoring; 12 Lead ECG recording; real-time arrhythmia detection / alarming; QT measurement / alarming and ST measurements / alarming: impedance pneumography: noninvasive blood pressure (NIBP); end-tidal CO2 (ETCO2) and respiration rate; pulse oximetry (SpO2); contact temperature; and invasive pressure.
The monitor is intended to be used as a stand-alone monitor or as a telemedicine system (transmitting patient data to other medical professionals located elsewhere).
The device is indicated for adults, paediatrics and neonates.
The Tempus Pro is a multi-parameter vital signs monitor designed for use in pre-hospital care and remote clinical locations by trained healthcare professionals. It provides 3&5 lead ECG monitoring, 12 lead ECG recording, real-time arrhythmia detection / alarming, QT measurement / alarming and ST measurements / alarming pulse oximetry, non-invasive blood pressure, sidestream capnometry, 2 channels of contact temperature, impedance respiration, up to 4 channels of invasive pressure and user configurable alarms.
In addition, it provides the ability to transmit all vital signs data via wired or wireless connections to a software system (called i2i) expected to be based in a facility far from the user e.g. a response centre facility. In addition to sending all vital signs, the system can also send pictures or video via an integrated camera, geographic position by an integrated GPS receiver and voice via a wired or wireless headset.
The provided text describes a 510(k) submission for the Tempus Pro Patient Monitor with Enhanced Features, specifically the addition of arrhythmia detection/alarming, QT measurement/alarming, and ST measurements/alarming.
Here's an analysis of the acceptance criteria and study information, based on the provided document:
1. Table of Acceptance Criteria and Reported Device Performance
The document mentions that the Arrhythmia detection, ST elevation, and QT interval measurements were evaluated in accordance with FDA guidance on arrhythmia detection and alarm, using the FDA recognized consensus standard EC57 (FDA Rec No: 3-118). However, it does not provide a specific table of acceptance criteria or quantitative performance metrics for these features. It only states: "A summary report demonstrating compliance with the guidance and associated standard is presented as part of this 510(k) submission." and "In each case the results of this testing confirmed that acceptance criteria defined by the relevant standard, or other appropriate reference document had been met."
Without access to the "summary report" or the full 510(k) submission, we cannot extract specific numerical acceptance criteria or reported device performance for the new features. The table below reflects the information that is available.
| Feature / Metric | Acceptance Criteria | Reported Device Performance |
|---|---|---|
| Arrhythmia Detection / Alarming | Compliance with FDA guidance on arrhythmia detection and alarm, and consensus standard EC57 (FDA Rec No: 3-118). | "Results of this testing confirmed that acceptance criteria defined by the relevant standard... had been met." (No specific numerical performance provided in this document). |
| ST Measurement / Alarming | Compliance with FDA guidance on arrhythmia detection and alarm, and consensus standard EC57 (FDA Rec No: 3-118). | "Results of this testing confirmed that acceptance criteria defined by the relevant standard... had been met." (No specific numerical performance provided in this document). |
| QT Measurement / Alarming | Compliance with FDA guidance on arrhythmia detection and alarm, and consensus standard EC57 (FDA Rec No: 3-118). | "Results of this testing confirmed that acceptance criteria defined by the relevant standard... had been met." (No specific numerical performance provided in this document). |
| General Device Parameters | Operate to specification across stated performance and temperature range. Ensure all data is transmitted reliably and accurately. | Confirmed by bench testing. |
2. Sample Size Used for the Test Set and Data Provenance
The document explicitly states that the evaluation was performed in accordance with "FDA guidance on arrhythmia detection and alarm" and "the FDA recognized consensus standard EC57 (FDA Rec No: 3-118), which defines methods of presenting results when testing against specified ECG databases."
However, the provided text does not specify the sample size (e.g., number of patients, number of ECGs) used for the test set. It also does not specify the data provenance (e.g., country of origin, retrospective or prospective) of the ECG databases used. EC57 typically refers to standard databases like MIT-BIH Arrhythmia Database, but this is not explicitly stated in the provided text.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
The document does not provide information on the number of experts used to establish ground truth or their specific qualifications for the test set. For standard ECG databases (like those referenced by EC57), ground truth is typically established by multiple expert cardiologists.
4. Adjudication Method for the Test Set
The document does not specify the adjudication method used for the test set. If standard ECG databases were used, the ground truth annotations would have been established prior to the device under test being evaluated.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
The document does not indicate that a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was done to assess how much human readers improve with AI vs without AI assistance. The focus of this 510(k) appears to be on the device's standalone performance in arrhythmia detection and measurement against established standards.
6. Standalone Performance (Algorithm Only without Human-in-the-Loop Performance)
Yes, a standalone study was done. The document states that "Arrhythmia detection and alarms, ST elevation and QT interval measurements... were evaluated in accordance with FDA guidance on arrhythmia detection and alarm... This guidance calls for use of the FDA recognized consensus standard EC57 (FDA Rec No: 3-118), which defines methods of presenting results when testing against specified ECG databases." This indicates the algorithm's performance was evaluated independently against pre-annotated databases, which is a standalone assessment.
7. Type of Ground Truth Used
The ground truth used would be expert consensus annotations as provided in the "specified ECG databases" referenced by the EC57 standard. These databases contain ECG recordings with validated annotations of arrhythmias and other cardiac events, established by a panel of cardiologists.
8. Sample Size for the Training Set
The document does not provide any information regarding the sample size used for the training set of the algorithms. It is possible the algorithms were pre-trained and integrated, or that general ECG databases were used for training, but this is not detailed.
9. How the Ground Truth for the Training Set Was Established
The document does not provide any information on how the ground truth for the training set was established. If standard ECG databases were used for training, the ground truth would have been established by expert consensus annotations within those databases.
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November 15, 2023
Remote Diagnostic Technologies Ltd Leigh Cornock Director Of Systems Engineering And Test The Old Coach House, The Avenue, Farleigh Wallop Basingstoke, RG252HT United Kingdom
Re: K133973
Trade/Device Name: Tempus Pro With Enhanced Features Regulation Number: 21 CFR 870.1025 Regulation Name: Arrhythmia Detector And Alarm (Including St-Segment Measurement And Alarm) Regulatory Class: Class II Product Code: QYW, MHX
Dear Leigh Cornock:
The Food and Drug Administration (FDA) is sending this letter to notify you of an administrative change related to your previous substantial equivalence (SE) determination letter dated August 14, 2014. Specifically, FDA is updating this SE Letter because FDA has created a new product code to better categorize your device technology.
Please note that the 510(k) submission was not re-reviewed. For questions regarding this letter please contact Jennifer Kozen, OHT2: Office of Cardiovascular Devices, 301-796-5813, Jennifer.Kozen@fda.hhs.gov.
Sincerely.
Jennifer W.Shih-S
Jennifer Kozen Assistant Director Division of Cardiac Electrophysiology, Diagnostics and Monitoring Devices Office of Cardiovascular Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
August 14, 2014
REMOTE DIAGNOSTIC TECHNOLOGIES LTD Leigh Cornock Director of System Engineering and Tests The Old Coach House, The Avenue, Farleigh Wallop Basingstoke, RG252HT GB
Re: K133973 Trade/Device Name: TEMPUS PRO WITH ENHANCED FEATURES Regulation Number: 21 CFR 870.1025 Regulation Name: Arrhythmia Detector And Alarm (Including St-Segment Measurement And Alarm) Regulatory Class: Class II Product Code: MHX Dated: December 23, 2013 Received: July 14, 2014
Dear Leigh Cornock,
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 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
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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 Industry and Consumer Education 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. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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 Industry and Consumer Education 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.
AthelBStei
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 Statement
510(k) Number (if known): K133973
Device Name: Tempus Pro
Indications for Use:
The Tempus Pro is a portable vital signs monitor intended to be used by clinicians and medically qualified personnel for the attended or unattended monitoring of single or multiple vital signs in clinical and pre-hospital care applications. The device is indicated for: 3 & 5 Lead ECG monitoring; 12 Lead ECG recording; real-time arrhythmia detection / alarming; QT measurement / alarming and ST measurements / alarming: impedance pneumography: noninvasive blood pressure (NIBP); end-tidal CO2 (ETCO2) and respiration rate; pulse oximetry (SpO2); contact temperature; and invasive pressure.
The monitor is intended to be used as a stand-alone monitor or as a telemedicine system (transmitting patient data to other medical professionals located elsewhere).
The device is indicated for adults, paediatrics and neonates.
Prescription Use _ V_ AND/OR (Part 21 CFR 801 Subpart D)
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)
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Remote Diagnostic Technologies Ltd - Tempus Pro™ Patient Monitor With Enhanced Features 510(k)
510(k) Summary of Safety and Effectiveness
5.1 Submitter's Information
The submitter of this abbreviated pre-market notification is:
| Name: | Remote Diagnostic Technologies Limited |
|---|---|
| Address: | The Old Coach House, Farleigh Wallop, Basingstoke,RG25 2HT, United Kingdom |
| Company Phone No: | +44 (0) 1256 362 400 |
| Company Fax No: | +44 (0) 1256 362 415 |
| Contact Person: | Dr Leigh Cornock (Director of Systems Eng. & Test) |
| Date summary prepared: | 9th July, 2014 |
5.2 Device Identification
| Device Trade Name: | Tempus Pro |
|---|---|
| Common Name: | Patient Monitor (with arrhythmia detection or alarms) |
| Class: | II |
| Classification Panel: | 74 |
| Product Code: | MHX |
| Regulation Number: | 870.1025 |
5.3 Device Description
The Tempus Pro is a multi-parameter vital signs monitor designed for use in pre-hospital care and remote clinical locations by trained healthcare professionals. It provides 3&5 lead ECG monitoring, 12 lead ECG recording, real-time arrhythmia detection / alarming, QT measurement / alarming and ST measurements / alarming pulse oximetry, non-invasive blood pressure, sidestream capnometry, 2 channels of contact temperature, impedance respiration, up to 4 channels of invasive pressure and user configurable alarms.
In addition, it provides the ability to transmit all vital signs data via wired or wireless connections to a software system (called i2i) expected to be based in a facility far from the user e.g. a response centre facility. In addition to sending all vital signs, the system can also send pictures or video via an integrated camera, geographic position by an integrated GPS receiver and voice via a wired or wireless headset.
5.4 Indications for Use
The following indications for use for the Tempus Pro remain unchanged from the previously cleared Tempus Pro apart from the addition of the arrhythmia detection, ST and QT measurement / alarming features,
"The Tempus Pro is a portable vital signs monitor intended to be used by clinicians and medically qualified personnel for the attended or unattended monitoring of single or multiple vital signs in clinical and pre-hospital care applications. The device is indicated for: 3 & 5 Lead ECG monitoring; 12 Lead ECG recording; realtime arrhythmia detection / alarming; QT measurement / alarming and ST measurements / alarming; impedance pneumography; non-invasive blood pressure (NIBP); end-tidal CO2 (ETCO2) and respiration rate; pulse oximetry (SpO2); contact temperature; and invasive pressure.
The monitor is intended to be used as a stand-alone monitor or as a telemedicine system (transmitting patient data to other medical professionals located elsewhere).
The device is indicated for adults, paediatrics and neonates."
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Remote Diagnostic Technologies Ltd - Tempus Pro™ Patient Monitor With Enhanced Features 510(k)
5.5 Comparison with Cleared Device
The intended use and indications for use, plus the fundamental technology used in the Tempus Pro device, remain essentially unchanged by the addition of optional enhanced software feature to the ECG monitoring capability, which is specifically:
- . Arrhythmia detection and alarms
- ST Elevation and depression measurement and alarms 트
- I QT Interval measurement and alarm
5.6 Substantial Equivalence
In adding these optional features, substantial equivalence to the previously cleared Tempus Pro (K130773) has been claimed as well as substantial equivalence to the following predicate devices:
- . Arrhythmia detection - Mindray iPM Patient Monitor (K123074)
- I QT and ST measurement - Philips Medical IntelliVue Patient Monitor MP2 (K120366)
With respect to arrhythmia analysis and alarms, ST elevation and QT interval measurements, the implementation of algorithms utilized in previously 510(k) cleared devices, plus the additional alarm feature, were evaluated in accordance with FDA guidance on arrhythmia detection and alarm.
This guidance calls for use of the FDA recognized consensus standard EC57 (FDA Rec No: 3-118), which defines methods of presenting results when testing against specified ECG databases. A summary report demonstrating compliance with the guidance and associated standard is presented as part of this 510(k) submission.
5.7 Summary of Non-Clinical Testing
The above modifications are software only and have been made under well-established design control procedures, which ensure that appropriate risk management processes have been carried out to determine their impact and ensure that appropriate verification/ validation testing is performed.
The non-clinical testing carried out in relation to addition of the enhanced features described above is summarized in the following table:
| Area | Testing Performed |
|---|---|
| Safety | This is a minor software only change so no impact on the safety of thedevice. The device has previously been tested to IEC 60601-1. |
| Defibrillation andelectrosurgical protection | This is a minor software only change so no impact on theperformance of the device. The device has previously been tested foroperation with a defibrillator and operation with an electro-surgical unitaccording to IEC 60601-1 (and relevant particular standards). |
| Environmental | This is a minor software only change so no impact on theperformance of the device. The device has previously been tested toa range of environmental (temperature, altitude, humidity, vibration,shock) tests according to RTCA DO-160, MIL810, EN 1789, EN13718-1, EN 60068. |
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Remote Diagnostic Technologies Ltd - Tempus Pro™ Patient Monitor With Enhanced Features 510(k)
| Area | Testing Performed |
|---|---|
| Ingress Protection | This is a minor software only change so no impact on theperformance of the device. The device has previously been tested toIEC 60529 for solid and water ingress. |
| ECG monitoring | This is a minor software only change so no impact on theperformance of the device. No change is made to the ECG board,applied parts, or software relating to communication with the ECGboard Testing to AAMI EC11 & EC13 and IEC 60601-2-25 & IEC60601-1-27 has previously been performed. |
| EMC | This is a minor software only change so no impact on theperformance of the device. The device has previously been tested toIEC 60601-1-2 for emissions and immunity including 20 V/m radiatedimmunity. |
| Alarms | This is a minor software only change so no impact on theperformance of the device. The alarm physical functions of theproduct have previously been tested to IEC 60601-1-8. |
| Comparative testingtopredicates | Comparative testing has been performed to demonstrate that theperformance of the device is equivalent to the predicates. |
| Software | The requirements of the FDA document Guidance for the Content ofPremarket Submissions for Software in Pre-Market Submissions hasbeen applied. In addition, the requirements of IEC 62304 have beenaddressed. |
| Bench testing | All parameters of the device have been tested to confirm they operateto specification across their stated performance range and acrosstheir stated temperature range. |
| Bench testing | The product has been bench tested to confirm that all data istransmitted reliably and accurately. |
In each case the results of this testing confirmed that acceptance criteria defined by the relevant standard, or other appropriate reference document had been met.
With respect to usability, no additional user validation was considered necessary, as the Tempus Pro is almost identical to the predicate Tempus Pro in terms of physical and interface features, including size and weight, user interface data layouts, button styles, menus, and layout of connectors, resulting the physical interaction with the device being unchanged.
5.8 Conclusion
In accordance with the Federal Food, Drug and Cosmetic Act, 21 CFR Part 807 and based on the information provided in this Premarket Notification, Remote Diagnostic Technologies Limited conclude that the Tempus Pro Patient Monitor with the enhancement of arrhythmia detection and alarms is safe and effective, and substantially equivalent to the previously cleared version of this device and other cleared devices used as predicates.
§ 870.1025 Arrhythmia detector and alarm (including ST-segment measurement and alarm).
(a)
Identification. The arrhythmia detector and alarm device monitors an electrocardiogram and is designed to produce a visible or audible signal or alarm when atrial or ventricular arrhythmia, such as premature contraction or ventricular fibrillation, occurs.(b)
Classification. Class II (special controls). The guidance document entitled “Class II Special Controls Guidance Document: Arrhythmia Detector and Alarm” will serve as the special control. See § 870.1 for the availability of this guidance document.