K Number
K152427
Device Name
PC ECG
Date Cleared
2016-02-05

(163 days)

Product Code
Regulation Number
870.2340
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
SE-1515 PC ECG is intended to acquire, process and store ECG signals from adult and pediatric patients undergoing stress exercise test or resting test. The SE-1515 PC ECG is intended to be used only in hospitals and healthcare facilities by doctors and trained healthcare professionals. The cardiogram recorded by the SE-1515 PC ECG can help users to analyze and diagnose heart diseases. However, the ECG with measurements is offered to clinicians on an advisory basis only. It is mainly used in the ECG Outpatient Department and Physical Examination Department.
Device Description
SE-1515 is a PC-based ECG designed to acquire, process and store ECG signals and analyze and diagnose heart disease. SE-1515 consists of analysis software and sampling boxes, and has four configurations: Wired 18-lead ECG system, Wired 16-lead ECG system, Wired 12-lead ECG system and Wireless 12-lead ECG system. Wired 18-lead ECG system consists of analysis software and wired DE18 sampling box. Wired 16-lead ECG system consists of analysis software and wired DE15 sampling box. Wired 12-lead ECG system consists of analysis software and wired DP12 sampling box. Wireless 12-lead ECG system contains analysis software, wireless DX12 sampling boxes (DX12 transmitter and DX12 receiver). The communication between DX12 transmitter and DX12 receiver is based on Bluetooth technology. For stress exercise testing, the user should connect a BP monitor and a treadmill or an ergo meter to the PC.
More Information

No
The summary describes standard ECG signal processing and analysis, with no mention of AI or ML terms or methodologies. The validation mentions database testing for interpretation features, which is common for traditional algorithms.

No.
The device is intended for acquiring, processing, and storing ECG signals for analysis and diagnosis of heart diseases, not for providing medical treatment or therapy.

Yes

Explanation: The "Intended Use" section states that "The cardiogram recorded by the SE-1515 PC ECG can help users to analyze and diagnose heart diseases." This clearly indicates a diagnostic function for the device.

No

The device description explicitly states that the SE-1515 consists of "analysis software and sampling boxes" and lists multiple configurations that include wired and wireless sampling boxes, which are hardware components.

Based on the provided information, the SE-1515 PC ECG is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • IVD devices are used to examine specimens derived from the human body. The SE-1515 PC ECG directly acquires electrical signals from the patient's body (ECG signals) through electrodes placed on the skin. It does not analyze biological samples like blood, urine, or tissue.
  • The intended use describes acquiring, processing, and storing ECG signals from patients. This is a direct measurement of physiological activity, not an analysis of a biological specimen.
  • The device description focuses on hardware (sampling boxes) and software for signal acquisition and analysis. This aligns with a device that interacts directly with the patient.

Therefore, the SE-1515 PC ECG falls under the category of a medical device that performs physiological measurements, but it is not an IVD.

N/A

Intended Use / Indications for Use

SE-1515 PC ECG is intended to acquire, process and store ECG signals from adult and pediatric patients undergoing stress exercise test or resting test. The SE-1515 PC ECG is intended to be used only in hospitals and healthcare facilities by doctors and trained healthcare professionals. The cardiogram recorded by the SE-1515 PC ECG can help users to analyze and diagnose heart diseases. However, the ECG with measurements is offered to clinicians on an advisory basis only. It is mainly used in the ECG Outpatient Department and Physical Examination Department.

Product codes (comma separated list FDA assigned to the subject device)

DPS

Device Description

SE-1515 is a PC-based ECG designed to acquire, process and store ECG signals and analyze and diagnose heart disease. SE-1515 consists of analysis software and sampling boxes, and has four configurations: Wired 18-lead ECG system, Wired 16-lead ECG system, Wired 12-lead ECG system and Wireless 12-lead ECG system.

Wired 18-lead ECG system consists of analysis software and wired DE18 sampling box.

Wired 16-lead ECG system consists of analysis software and wired DE15 sampling box. Wired 12-lead ECG system consists of analysis software and wired DP12 sampling box. Wireless 12-lead ECG system contains analysis software, wireless DX12 sampling boxes (DX12 transmitter and DX12 receiver). The communication between DX12 transmitter and DX12 receiver is based on Bluetooth technology.
For stress exercise testing, the user should connect a BP monitor and a treadmill or an ergo meter to the PC.

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

Adult and pediatric patients

Intended User / Care Setting

hospitals and healthcare facilities by doctors and trained healthcare professionals.

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 data:

  • Biocompatibility testing: Conducted in accordance with ISO 10993-1, included Cytotoxicity, Skin Sensitization, and Skin Irritation tests. The worst case of the whole system is considered surface contacting for duration of less than 24 hours.
  • Electrical safety and electromagnetic compatibility (EMC): Complies with IEC 60601-1:2005/A1: 2012 and IEC 60601-1-2: 2007.
  • Bench Testing: Conducted per IEC 60601-2-25: 2011, all results showed pass. ECG interpretation features were also validated by database testing.
  • Software Verification and Validation Testing: Conducted with documentation provided per FDA guidance. Software considered "moderate" level of concern.

Clinical data: Not applicable.

Summary: The non-clinical data support the safety of the device and the hardware and software verification and validation demonstrate that SE-1515 PC ECG device should perform as intended in the specified use conditions, and all the data demonstrate that the subject devices perform comparably to the predicate device that is currently marketed for the same intended use.

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

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

EDAN Instrument, Inc. SE-1010, K131819

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Philips Medical Systems, Philips DXL 12/16-lead ECG Algorithm, K132068, Philips Medical Systems, Philips TC70, K113144

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

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

Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized image of an eagle with three human profiles incorporated into its design. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular pattern around the eagle.

Public Health Service

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

February 5, 2016

Edan Instruments. Inc. % Doug Worth Sr. Dir. US RA/QA Edan Medical 1200 Crossman Ave. Suite 200 Sunnyvale, California 94086

Re: K152427

Trade/Device Name: PC ECG, model SE-1515 Regulation Number: 21 CFR 870.2340 Regulation Name: Electrocardiograph Regulatory Class: Class II Product Code: DPS Dated: December 24, 2015 Received: December 28, 2015

Dear Doug Worth:

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

1

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.

Mitchell Stein

for Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K152427

Device Name PC ECG, model SE-1515

Indications for Use (Describe)

SE-1515 PC ECG is intended to acquire, process and store ECG signals from adult and pediatric patients undergoing stress exercise test or resting test. The SE-1515 PC ECG is intended to be used only in hospitals and healthcare facilities by doctors and trained healthcare professionals. The cardiogram recorded by the SE-1515 PC ECG can help users to analyze and diagnose heart diseases. However, the ECG with measurements is offered to clinicians on an advisory basis only. It is mainly used in the ECG Outpatient Department and Physical Examination Department.

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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3

510(K) Summary

Prepared in accordance with the content and format regulatory requirements of 21 CFR Part 807.92

| 1. Submitter: | Edan Instruments, Inc
3/F - B, Nanshan Medical
Equipments Park, Nanhai Rd 1019#,
Shekou, Nanshan Shenzhen,
518067 P.R. China
Tel: +86(0755) 26858736
Fax: +1 (408) 418-4059 |
|---------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact person:
Preparing date: | Queena Chen
December 24, 2015 |
| 2. Device name and
classification: | Device Name: PC ECG
Model: SE-1515
Classification Name/ Product code:
870.2340 Electrocardiograph/DPS
Regulatory Class: Class II |
| 3. Predicate Device(s): | 1) EDAN Instrument, Inc. SE-1010, K131819 (Primary)
2) Philips Medical Systems, Philips DXL 12/16-lead ECG
Algorithm, K132068 (Reference)
3) Philips Medical Systems, Philips TC70, K113144(Reference) |
| 4. Reason for
Submission | New product. |
| 5. Pre-Submission,
IDE | Not applicable, there is no prior submission. |
| 6. Device Description: | SE-1515 is a PC-based ECG designed to acquire, process and
store ECG signals and analyze and diagnose heart disease.
SE-1515 consists of analysis software and sampling boxes, and
has four configurations: Wired 18-lead ECG system, Wired
16-lead ECG system, Wired 12-lead ECG system and Wireless
12-lead ECG system.

Wired 18-lead ECG system consists of analysis software and
wired DE18 sampling box.

Wired 16-lead ECG system consists of analysis software and
wired DE15 sampling box. Wired 12-lead ECG system consists
of analysis software and wired DP12 sampling box. Wireless |
| | 12-lead ECG system contains analysis software, wireless DX12
sampling boxes (DX12 transmitter and DX12 receiver). The
communication between DX12 transmitter and DX12 receiver
is based on Bluetooth technology.
For stress exercise testing, the user should connect a BP
monitor and a treadmill or an ergo meter to the PC. |
| 7. Intended Use: | SE-1515 PC ECG is intended to acquire, process and store ECG
signals from adult and pediatric patients undergoing stress
exercise test or resting test. The SE-1515 PC ECG is intended
to be used only in hospitals and healthcare facilities by doctors
and trained healthcare professionals. The cardiogram recorded
by the SE-1515 PC ECG can help users to analyze and diagnose
heart diseases. However, the ECG with measurements and
interpretive statements is offered to clinicians on an advisory
basis only. |

4

8. Predicate Device Comparison

The subject devices share the same characteristics in all items with the predicate device, concluding from using the same technology and principle. All the technological differences existed between the subject and predicate devices are only some performance parameters items, which are shown in the following tables in details.

ItemSE-1515SE-1010Remark
510(k) NumberCurrent SubmissionK131819----
Indications for Use
Intended useSE-1515 PC ECG is intended to acquire process and store ECG signals from adult and pediatric patients undergoing stress exercise test or resting test. The SE-1515 PC ECG is intended to be used only in hospitals and healthcare facilities by doctors and trained healthcare professionals. The cardiogram recorded by the SE-1515 PC ECG can help users to analyze and diagnose heart diseases. However, the ECG with measurements and interpretive statements is offered to clinicians on an advisory basis only. It is mainly used in the ECGSE-1010 is a PC-based diagnostic tool intended to acquire, process and store ECG signals from adult and pediatric patients undergoing stress exercise test or resting test. PC ECG is intended to be used only in hospitals and healthcare facilities by doctors and trained healthcare professionals. The cardiogram recorded by SE-1010 can help users to analyze and diagnose heart disease. However the ECG with measurements and interpretive statements is offered to clinicians on anDifferent
Outpatient Department and
Physical Examination
Department.advisory basis only.
High/Low Pass
FiltersDFT Filter:
0.01 Hz/0.05 Hz/0.32 Hz/0.67 Hz
AC Filter: 50 Hz/60 Hz/Off
EMG Filter:
25 Hz/35 Hz/45 Hz/Off
Low Pass Filter:
300 Hz/270 Hz/150 Hz/100 Hz/75
HzDFT Filter: weak/strong
AC Filter: 50 Hz/60 Hz/Off
Low Pass/EMG Filter:
25 Hz/35 Hz/45 Hz/75 Hz/100
Hz/150 HzDifferent
Sampling Box
----DE15DP12----
Classification
Anti-electric-sho
ck typeClass IIClass IISame
Anti-electric-sho
ck degreeType CF with defibrillation-proofType CF with
defibrillation-proofSame
Lead number16-lead12-leadDifferent
Degree of
protection
against harmful
ingress of waterSealed equipment without
waterproofSealed equipment without
waterproofSame
Degree of safety
of application in
the presence of
flammable gasEquipment not suitable for use in
the presence of flammable gasEquipment not suitable for use
in the presence of flammable
gasSame
Working modeContinuous operationContinuous operationSame
Processing
Sampling Rate16 kHz /channel1 kHz /channelDifferent
Resolution0.1575 µV/LSB @ 1 kHz2.52 µV/LSB @ 1 kHzDifferent
Time Constant>3.2 s≥3.2 sSame
Frequency
Response0.01 Hz~300 Hz0.05 Hz ~ 150 HzDifferent
Input Impedance≥100 MΩ>50 ΜΩDifferent
Dynamic RangeAC Differential ± 5 mV, DC
offset ±600 mVAC Differential ± 5 mV, DC
offset ±600 mVSame
System Noise≤12.5μ Vp-p≤12.5μ Vp-pSame
Common Mode
Rejection≥140 dB(AC ON)
≥123 dB(AC OFF)>110 dBDifferent
Pace Detect±750 uV~±700 mV @ 50 us ~2.0
ms±2 to ±700 mV @ 0.1 ms to
2.0 msDifferent
ESD Sensitivity+6 kV contact+6 kV contactSame
±8 kV air±8 kV air
Heart Rate Meter30 BPM ~300 BPM, ±1 BPM
DE1830 BPM ~300 BPM, ±1 BPM
DP12Same
Classification
Anti-electric-sho
ck typeClass IIClass IISame
Anti-electric-sho
ck degreeType CF with defibrillation-proofType CF with
defibrillation-proofSame
Lead number18-lead12-leadDifferent
Degree of
protection
against harmful
ingress of waterSealed equipment without
waterproofSealed equipment without
waterproofSame
Degree of safety
of application in
the presence of
flammable gasEquipment not suitable for use in
the presence of flammable gasEquipment not suitable for use
in the presence of flammable
gasSame
Working modeContinuous operationContinuous operationSame
Processing
Sampling Rate16 kHz /channel1 kHz /channelDifferent
Resolution0.1575 µV/LSB @ 1 kHz2.52 µV/LSB @ 1 kHzDifferent
Time Constant≥3.2 s≥3.2 sSame
Frequency
Response0.01 Hz~300 Hz0.05 Hz ~ 150 HzDifferent
Input Impedance≥100 ΜΩ>50 ΜΩDifferent
Dynamic RangeAC Differential ± 5 mV, DC
offset ±600 mVAC Differential ± 5 mV, DC
offset ±600 mVSame
System Noise≤12.5μ Vp-p≤12.5μ Vp-pSame
Common Mode
Rejection≥140 dB (AC ON)
≥123 dB (AC OFF)>110 dBDifferent
Pace Detect±750 uV~±700 mV @ 50 us ~2.0
ms±2 to ±700 mV @ 0.1 ms to
2.0 msDifferent
ESD Sensitivity±6 kV contact
±8 kV air±6 kV contact
±8 kV airSame
Heart Rate Meter30 BPM ~300 BPM, ±1 BPM30 BPM~300 BPM, ±1 BPMSame
DP12 Sampling Box
Classification
Anti-electric-sho
ck typeClass IIClass IISame
Anti-electric-sho
ck degreeType CF with defibrillation-proofType CF with
defibrillation-proofSame
Lead number12-lead12-leadSame
protection
against harmful
ingress of waterprotection against ingress of waterprotection against ingress of water
Degree of safety
of application in
the presence of
flammable gasNot suitable for use in the
presence of a flammable
anesthetic mixture with air or with
oxygen or nitrous oxideNot suitable for use in the
presence of a flammable
anesthetic mixture with air or
with oxygen or nitrous oxideSame
Working modeContinuous operationContinuous operationSame
Processing
Sampling Rate1,000 /sec/channel1,000 /sec/channelSame
Resolution2.52 $ μ $ V/LSB @ 1 kHz2.52 $ μ $ V/LSB @ 1 kHzSame
Time Constant$ ≥ $ 3.2 s$ ≥ $ 3.2 sSame
Frequency
Response0.05 Hz ~ 150 Hz (-3 dB)0.05 Hz ~ 150 Hz (-3 dB)Same
Input Impedance>50 MΩ @ 10 Hz, defibrillator
protected>50 MΩ @ 10 Hz, defibrillator
protectedSame
Dynamic RangeAC Differential ± 5 mV, DC
offset ±600 mVAC Differential ± 5 mV, DC
offset ±600 mVSame
System
Noise$ ≤ $ 12.5 $ μ $ Vp-p$ ≤ $ 12.5 $ μ $ Vp-pSame
Common Mode
Rejection>110 dB>110 dBSame
Pace Detect±2 to ±700 mV@0.1 to 2.0 ms±2 to ±700 mV@0.1 to 2.0 msSame
ESD Sensitivity±6 kV contact
±8 kV air±6 kV contact
±8 kV airSame
Heart Rate Meter30 BPM ~300 BPM, ±1 BPM30 BPM ~300 BPM, ±1 BPMSame
DX12 Sampling Box
Classification
Anti-electric-sho
ck
typeClass IIClass IISame
Anti-electric-sho
ck degreeType CF with defibrillation-proofType CF with
defibrillation-proofSame
Lead number12-lead12-leadSame
Degree of
protection
against harmful
ingress of waterEnclosed equipment without
protection against ingress of waterEnclosed equipment without
protection against ingress of waterSame
Degree of safety
of application in
the presence of
flammable gasNot suitable for use in the
presence of a flammable
anesthetic mixture with air or with
oxygen or nitrous oxideNot suitable for use in the
presence of a flammable
anesthetic mixture with air or
with oxygen or nitrous oxideSame
Working modeContinuous operationContinuous operationSame
Processing
Sampling Rate10,000/sec/channel10,000/sec/channelSame
Resolution2.52 $ μ $ V/LSB @ 500 Hz2.52 $ μ $ V/LSB @ 500 HzSame
Time Constant$ ≥ $ 3.2 s$ ≥ $ 3.2 sSame
Frequency Response0.05 Hz ~ 150 Hz (-3 dB)0.05 Hz ~ 150 Hz (-3 dB)Same
Input Impedance$ ≥ $ 20 M $ Ω $ @ 10 Hz, defibrillator protected$ ≥ $ 20 M $ Ω $ @ 10 Hz, defibrillator protectedSame
Dynamic RangeAC Differential $ ± $ 5mV, DC offset $ ± $ 500 mVAC Differential $ ± $ 5mV, DC offset $ ± $ 500 mVSame
System Noise$ ≤ $ 15 $ μ $ Vp-p$ ≤ $ 15 $ μ $ Vp-pSame
Common Mode Rejection$ ≥ $ 100 dB$ ≥ $ 100 dBSame
Pace Detect$ ± $ 2 to $ ± $ 500 mV@0.1 to 2.0 ms$ ± $ 2 to $ ± $ 500 mV@0.1 to 2.0 msSame
ESD Sensitivity$ ± $ 6 kV contact
$ ± $ 8 kV air$ ± $ 6 kV contact
$ ± $ 8 kV airSame
Heart Rate Meter30 BPM ~300 BPM, $ ± $ 1 BPM30 BPM ~300 BPM, $ ± $ 1 BPMSame
Transmitting Frequency2402-2480Hz2402-2480HzSame
Frequency Band2402-2480Hz2402-2480HzSame
Modulation TypeFHSSFHSSSame
Transmitting Power4.65dBM4.65dBMSame
Analysis Software
Operating systemWindows XP SP2/SP3 (32/64 bit), Windows 7 SP1 (32/64 bit) or Windows 8 (32/64 bit)Windows XP PROFESSIONAL SP2/SP3, Windows Vista (32/64 bit) or Windows 7 (32/64 bit)Different
Safety requirementsTested for compliance with IEC 62304Tested for compliance with IEC 62304Same
Vector loopSupport the FRANK sampling and Calculating VCG.
Can show the FRANK leads X,Y,Z wave and median complexes of the orthogonal FRANK leads X,Y,Z as well as the vector loops in three plansSupport the FRANK sampling and Calculating VCG.
Can show the FRANK leads X,Y,Z wave and median complexes of the orthogonal FRANK leads X,Y,Z as well as the vector loops in three plans.Same
Resting ECG
Measuring the ECGAmplitudes(mV),intervals(ms) nd slopes(mV/s) can be ensured on all ECG waveformsAmplitudes(mV),intervals(ms) nd slopes(mV/s) can be ensured on all ECG waveformsSame
ReanalysisManually change theManually change theSame
measurement marks of medians
and the interpretation resultmeasurement marks of
medians and the interpretation
result
Interpretation
libraryHas Interpretation library and can
editHas Interpretation library and
can editSame
Exercise Test
Test Phaseeach protocol has three phase:
pretest, exercise, recoveryeach protocol has three phase:
pretest, exercise, recoverySame
Pretest PhaseConsists of stages configured in
each protocol. Commonly used
stages are: supine, standing,
hyperventilation, warm-upConsists of stages configured
in each protocol. Commonly
used stages are: supine,
standing, hyperventilation,
warm-upSame
Exercise
PhaseThe selected protocol will control
the treadmill or bicycle
ergo-meterThe selected protocol will
control the treadmill or bicycle
ergo-meterSame
Recovery phaseThe clock begins timing the
recovery phase. In recovery, the
treadmill speed and grade or the
bicycle load will change
according to the protocol
configurationThe clock begins timing the
recovery phase. In recovery, the
treadmill speed and grade
or the bicycle load will change
according to the protocol
configurationSame
Full disclosure
ECGCan save the full disclosure ECG
and print either the entire full 1
disclosure ECG or only a selected
segmentCan save the full disclosure
ECG and print either the entire
full 1 disclosure ECG or only a
selected segmentSame
Final reportsConfigured report, tabular
summary, graded exercise
summary report, selected medians
report, sample cardiac cycles,
trend report ST/HR Slope, ECG
stripsConfigured report, tabular
summary, graded exercise
summary report, selected
medians report, sample cardiac
cycles, trend report ST/HR
Slope, ECG stripsSame
Writer
Writer
Technologylaser printer or jet printerlaser printer or jet printerSame
Writer
Amplitude
Accuracy±5%±5%Same
Paper SizeA4, LetterA4, LetterSame
Environmental Specifications
Temperature
Operating+5 ~+40+5 ~+40Same
Transport/Storag
eDP12/DE15 ECG sampling box:
-40°C (-8°F) ~ +55°C (+131°F)DP12 sampling box:
-40°C (-8°F) ~ +55°C (+131°F)Same
DX12 ECG sampling box:
-20°C (-4°F)~+55°C (+131°F)DX12 ECG sampling box:
-20°C (-4°F)~+55°C (+131°F)
Humidity
Operating25% to 80% RH25% to 80% RHSame
Transport/Storagenon-condensing 25% to 93% RH
non-condensingnon-condensing 25% to 93% RH non-condensingSame
Pressure
Operating860 hPa ~1060 hPa860 hPa ~1060 hPaSame
Transport/Storage700 hPa ~1060 hPa700 hPa ~1060 hPaSame

Table 1: Comparison between SE-1515 and SE-1010

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Table 2: Comparison between SE-1515 and DXL 12/16-lead ECG Algorithm

ItemSE-1515Philips DXL 12/16-lead ECG AlgorithmRemark
510(k) NumberCurrent SubmissionK132068---
Intended useSE-1515 PC ECG is intended
to acquire process and store
ECG signals from adult and
pediatric patients undergoing
stress exercise test or resting
test. The SE-1515 PC ECG is
intended to be used only in
hospitals and healthcare
facilities by doctors and trained
healthcare professionals. The
cardiogram recorded by the
SE-1515 PC ECG can help
users to analyze and diagnose
heart diseases. However, the
ECG with measurements and
interpretive statements is
offered to clinicians on an
advisory basis only. It is
mainly used in the ECG
Outpatient Department and
Physical Examination
Department.To analyze multi-channel ECG
signals from adult and pediatric
patients with algorithms that
provide measurements, data
presentations, graphical
presentations and interpretations
for review by the user.
The interpreted ECG with
measurements and interpretive
statements is offered to the
clinician on an advisory basis
only. It is to be used in
conjunction with the clinician's
knowledge of the patient, the
results of the physical
examination, the ECG tracings,
and other clinical findings. A
qualified physician is asked to
over read and validate (or change)
the computer generated ECG
interpretation.
Where the clinician decides to
evaluate the electrocardiogram of
adult and pediatric patients as part
of decisions regarding possible
diagnosis, potential treatment,
effectiveness of treatment or to
rule-out causes for symptoms.Different
Lead Number12/15/1612/16Different

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ItemSE-1515Philips TC70Remark
510(k) NumberCurrent SubmissionK113144---
Intended useSE-1515 PC ECG is intended
to acquire process and store
ECG signals from adult and
pediatric patients undergoing
stress exercise test or resting
test. The SE-1515 PC ECG is
intended to be used only in
hospitals and healthcare
facilities by doctors and trained
healthcare professionals. The
cardiogram recorded by the
SE-1515 PC ECG can help
users to analyze and diagnose
heart diseases. However, the
ECG with measurements and
interpretive statements is
offered to clinicians on an
advisory basis only. It is
mainly used in the ECG
Outpatient Department and
Physical Examination
Department.To acquire multi-channel ECU
signals from adult and pediatric
patients from body surface ECG
electrodes and to record, display,
analyze and store these ECU
signals for review by the user. To
be used in healthcare facilities by
trained healthcare professionals.
Analysis of the ECU signals is
accomplished with algorithms that
provide measurements, data
presentations, graphical
presentations and interpretations
for review by the user.
The interpreted EGG with
measurements and interpretive
statements is offered to the
clinician on an advisory basis
only. It is to be used in
conjunction with the clinician's
knowledge of the patient, the
results of the physical
examination, the EGG tracings,
and other clinical findings. A
qualified physician is asked to
over read and validate (or change)
the computer generated ECG
interpretation.Different
Lead Number12/15/16/1812/16/18Different

Table 3: Comparison between SE-1515 and Philips TC70

As seen in the comparison tables, the subject and predicate devices have similar design features and performance specifications. The main technological differences between the subject and predicate devices are minor differences, and do not raise different questions of safety or effectiveness. As demonstrated in the non-clinical testing, the different technological characteristics do not affect the safety and effectiveness of the Edan SE-1515 PC ECG.

9. Performance Data:

Non-clinical data:

The following performance data were provided in support of the substantial equivalence determination.

Biocompatibility testing

12

The biocompatibility evaluation for SE-1515 PC ECG device is conducted in accordance with the International Standard ISO 10993-1 "Biological Evaluation of Medical Devices - Part 1: Evaluation and Testing within a Risk Management Process," as recognized by FDA. The worst case of the whole system is considered surface contacting for duration of less than 24 hours. And the battery of testing included the following tests:

  • Cytotoxicity .
  • . Skin Sensitization
  • Skin Irritation

Electrical safety and electromagnetic compatibility (EMC)

Electrical safety and EMC testing were conducted on the SE-1515 PC ECG device, consisting of all the modules and accessories in the system. The system complies with the IEC 60601-1:2005/A1: 2012 standard for safety and the IEC 60601-1-2: 2007 standard for EMC.

Bench Testing

Bench testing was conducted per IEC 60601-2-25: 2011, and all the results show pass. ECG interpretation features were also validated by database testing.

Software Verification and Validation Testing

Software verification and validation testing were conducted and documentation was provided as recommended by FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices." The software for this device was considered as a "moderate" level of concern, since a failure or latent flaw in the software will not directly result in serious injury or death to the patient or operator, and the software device is an accessory to a medical device that has a Moderate Level of Concern.

Clinical data: Not applicable.

Summary

Based on the non-clinical and clinical performance as documented in the system development, the subject devices were found to have a safety and effectiveness profile that is similar to the predicate device.

10. Conclusion

The non-clinical data support the safety of the device and the hardware and software verification and validation demonstrate that SE-1515 PC ECG device should perform as intended in the specified use conditions, and all the data demonstrate that the subject devices perform comparably to the predicate device that is currently marketed for the same intended use. In other words, the subject SE-1515 PC ECG device is substantially equivalent to the predicate devices.