K Number
K151139

Validate with FDA (Live)

Date Cleared
2016-10-18

(538 days)

Product Code
Regulation Number
870.1220
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

EasyMap MAP catheters are indicated for simultaneously pacing and recording Monophasic Action Potentials (MAPs) from the endocardial surface of the human heart.

Device Description

EasyMap MAP is a single-use disposable quadropolar catheter for recording monophasic action potentials and for intracardial pacing. Integrated in the catheter tip are a Silver-Chloride Electrode (AgCI), a Silver Electrode (Ag) and two orthogonally placed Silver Electrodes (Ag). These electrodes enable mapping of cardiac electrochemical potentials. The catheter tip can be deflected in a single direction up to 270 degrees.

AI/ML Overview

This document is a 510(k) premarket notification for a medical device called the EasyMap MAP Catheter. It outlines the device's characteristics, intended use, and a comparison to a predicate device, as well as a summary of the testing performed to demonstrate its safety and effectiveness.

Here's an analysis of the provided text to answer your questions:

1. A table of acceptance criteria and the reported device performance

The document doesn't explicitly state "acceptance criteria" with numerical thresholds for each test. Instead, it lists the tests performed and whether the device "Passed Test." The underlying acceptance criteria are implied to be that the device successfully meets the requirements of the applied standards or internal test methods.

TestApplied StandardReported Device PerformanceImplied Acceptance Criteria (based on "Passed Test")
Corrosion TestISO 10555Passed TestThe device's materials must resist degradation (corrosion) when exposed to conditions simulating the human body, as per ISO 10555.
Dimension TestsInternal Test MethodPassed TestDevice dimensions (e.g., diameter, length, electrode spacing) must conform to design specifications, as outlined in the internal test method.
Electrical Tests (Continuity, Short Circuit, Isolation/Leakage, High Voltage 1kV)EN 60601Passed TestThe device must meet electrical safety standards (e.g., no unintended current paths, adequate insulation, withstand specified voltage) as defined by EN 60601.
Mechanical Test - Mechanical Strength after moisture storageISO 10555Passed TestThe device must maintain mechanical integrity and specified strength after exposure to moisture mimicking physiological conditions, as per ISO 10555.
Mechanical Test - SteerabilityInternal Test MethodPassed TestThe catheter tip must be able to deflect to the specified angle (up to 270 degrees) and maintain its steerability as defined by the internal test method.
Mechanical Test - Fixation Push / Pull ControlInternal Test MethodPassed TestThe catheter's pushability and pullability, and the control of these actions, must meet the specified requirements of the internal test method.
Compatibility with existing products - BendingInternal Test MethodPassed TestThe catheter must exhibit appropriate bending characteristics and compatibility when used with existing products/systems, as defined by the internal test method.
Compatibility with existing products - DimensionsInternal Test MethodPassed TestThe catheter's dimensions must ensure compatibility when used with existing products/systems, as defined by the internal test method.
BiocompatibilityISO 10993Passed TestThe device must not cause unacceptable adverse biological reactions (e.g., cytotoxicity, irritation, sensitization) when in contact with human tissue, complying with ISO 10993.
Shelf Life TestInternal Test MethodPassed TestThe device must maintain its safety and performance characteristics for its specified shelf life, as demonstrated by the internal test method.
Packaging ValidationISO 11607-1Passed TestThe packaging must protect the device, maintain sterility, and withstand handling and storage conditions, as validated according to ISO 11607-1.
Sterilization ValidationEN 550; ISO11135Passed TestThe sterilization process (EO gas) must consistently achieve the required sterility assurance level (SAL) for the device, as validated according to EN 550 and ISO 11135.
X-Ray Test / VisibilityInternal Test MethodPassed TestThe device must be adequately visible under X-ray imaging to facilitate proper placement and monitoring during procedures, as determined by the internal test method.
Overall Performance Statement"Performance Based upon the documentation presented in this 510(k)"Safe and effectiveThe device is deemed safe and effective for its intended use, based on the aggregate results of all tests and the comparison to the predicate device.

2. Sample size used for the test set and the data provenance

The document does not specify the sample size for any of the tests. It also does not provide information on the data provenance (e.g., country of origin, retrospective or prospective nature). The tests listed are primarily bench (laboratory) tests performed on the device itself, not clinical studies involving patient data.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

This information is not applicable and not provided in the document. The tests performed are engineering and materials science tests, not diagnostic performance evaluations requiring expert-established ground truth.

4. Adjudication method for the test set

This information is not applicable and not provided in the document. No adjudication method is mentioned as the tests are objective measurements against standards or internal methods, not subjective evaluations requiring expert consensus.

5. 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

There is no mention of an MRMC study or any AI assistance in this document. The device is an electrode recording catheter, not an AI-powered diagnostic tool.

6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done

This information is not applicable. The device is a physical medical instrument, not an algorithm.

7. The type of ground truth used

For the engineering and material tests, the "ground truth" used is defined by accepted industry standards (ISO, EN) and the manufacturer's own validated internal test methods and specifications. For instance, for the corrosion test, the ground truth is compliance with ISO 10555. For dimension tests, the ground truth is the engineering drawing specifications.

8. The sample size for the training set

This information is not applicable as this is a physical medical device, not a machine learning algorithm that requires a training set.

9. How the ground truth for the training set was established

This information is not applicable as this is a physical medical device, not a machine learning algorithm.

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Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized caduceus symbol, which is a staff with two snakes entwined around it. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular pattern around the symbol. The logo is black and white.

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

October 18, 2016

MedFact Engineering GmbH % Melissa Walker President & Cto Graematter, Inc 1324 Clarkson Clayton Ctr. #332 Ballwin, Missouri 63011

Re: K151139

Trade/Device Name: EasyMap MAP Catheter Regulation Number: 21 CFR 870.1220 Regulation Name: Electrode Recording Catheter or Electrode Recording Probe Regulatory Class: Class II Product Code: DRF Dated: September 11, 2016 Received: September 13, 2016

Dear Melissa Walker:

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 devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in

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the quality systems (OS) 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.

Mude Jellman
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) K151139

Device Name EasyMap MAP Catheter

Indications for Use (Describe)

EasyMap MAP catheters are indicated for simultaneously pacing and recording Monophasic Action Potentials (MAPs) from the endocardial surface of the human heart.

Type of Use (Select one or both, as applicable)
☑ Prescription Use (Part 21 CFR 801 Subpart D) ☐ Over-The-Counter Use (21 CFR 801 Subpart C)

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Appendix 1: 510(k) Summary per 21CFR §807.92

Submitter'sinformationJörg ReinhardtMedFact Engineering GmbHHammerstrasse 3D-79540 Löerrach/ GermanyContact: Melissa WalkerGraematter, Inc.1324 Clarkson Clayton Ctr #332Ballwin, MO 63011Phone: 636-405-7498Date: 04/20/2015
Device/classificationnameClassification information for the EasyMap MAP Catheter follows:• 21 CFR 870.1220• Product Code DRF• Classification/Common name: Electrode recording catheter or electrode recording probe
The marketed device(s) to which substantial equivalence is claimed:• Franz Steerable Combination Catheter 510(k)• K903880 cleared October 12, 1990.
DevicedescriptionEasyMap MAP is a single-use disposable quadropolar catheter for recordingmonophasic action potentials and for intracardial pacing. Integrated in thecatheter tip are a Silver-Chloride Electrode (AgCI), a Silver Electrode (Ag)and two orthogonally placed Silver Electrodes (Ag). These electrodes enablemapping of cardiac electrochemical potentials.
The catheter tip can be deflected in a single direction up to 270 degrees.
Indications foruseEasyMap MAP catheters are indicated for simultaneously pacing andrecording monophasic Action-Potentials (MAPs) from the endocardial surfaceof the human heart.
Continued on next page

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Appendix 1: 510(k) Summary per 21CFR §807.92, Continued

Comparison matrix of basic key characteristics

The table below lists the main characteristics of the proposed EasyMap MAP Catheter compared to the Predicate Franz MAP Catheter. The Franz MAP Catheter was chosen as the predicate device because the intended use is identical to the EasyMap MAP Catheter in that both are designed to detect and record electrical potentials from the endocardial surfaces of the heart and to deliver externally generated pacing stimuli.

Device CharacteristicFranz SteerableCombination CatheterPredicate DeviceK903880Proposed New Device:EasyMap MAPCatheter
Physiologic purposeAid physician inmanagement ofarrhythmiassame
Intended for use byCardiac EP orcardiovascular surgeonssame
Primary functionMAP recording andtemporary cardiac pacingsame
Insertion methodPercutaneous through alarge vein by Seldingertechniquesame
Electrode materialMAP: AG/AgClPacing: Platinumsame
No. of electrodes4-8 electrodes2 MAP2-6 Pacing4 electrodes2 MAP2 Pacing
Electrode spacing -MAP electrodes4.5 mm edge to edgeMAP electrodes4.5 mm edge to edge
Image: Diagram of pacing and MAP recording electrodesPacing electrodes3.6 mm (center to center),1.6 mm (edge to edge)Pacing electrodes3.6 mm (center to center)1.6 mm (edge to edge)
SterileYessame
Method of sterilizationEO gassame
Single useYessame
Catheter body materialPebaxPebax
Catheter diameter5, 6, 7 F7F
catheter length80-150 cm110 cm
Tip deflection angle/range270° in two directionsUnidirectional up to 270°

Continued on next page

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Appendix 1: 510(k) Summary per 21CFR §807.92, Continued

Test summary The table below lists the applied standards and test results for the EasyMap MAP Catheter.

TestApplied StandardResult
Corrosion TestISO 10555Passed Test
Dimension TestsInternal Test MethodPassed Test
Electrical Tests- Continuity- Short Circuit- Isolation/Leakage Test- High Voltage Test (1 kV)EN 60601Passed Test
Mechanical Test- Mechanical Strength after moisture storageISO 10555Passed Test
- SteerabilityInternal Test Method
- Fixation Push / Pull ControlInternal Test Method
Compatibility with existing products- Bending- DimensionsInternal Test MethodPassed Test
BiocompatibilityISO 10993Passed Test
Shelf Life TestInternal Test MethodPassed Test
Packaging ValidationISO 11607-1Passed Test
Sterilization ValidationEN 550; ISO11135Passed Test
X-Ray Test / VisibilityInternal Test MethodPassed Test

Note: Tests are to be performed on sterilized products after storage and moisture (0.9% NaCl water bath 37 °C, 24 h) Thermal Shock Test and bending performance test.

Performance Based upon the documentation presented in this 510(k) it has been data demonstrated that the EasyMap MAP Catheter is safe and effective for its intended use.

§ 870.1220 Electrode recording catheter or electrode recording probe.

(a)
Identification. An electrode recording catheter or an electrode recording probe is a device used to detect an intracardiac electrocardiogram, or to detect cardiac output or left-to-right heart shunts. The device may be unipolar or multipolar for electrocardiogram detection, or may be a platinum-tipped catheter which senses the presence of a special indicator for cardiac output or left-to-right heart shunt determinations.(b)
Classification. Class II (performance standards).