K Number
K183266

Validate with FDA (Live)

Device Name
EP-TRACER System
Date Cleared
2019-03-01

(98 days)

Product Code
Regulation Number
870.1425
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The EP-TRACER System is an electrophysiology measurement system used to acquire, filter, digitize, amplify, display, and record signals obtained during electrophysiological studies and related procedures.

The system allows the user to monitor, display and record the signals. The system incorporates a stimulator intended to be used for diagnostic cardiac stimulation during electrophysiological testing of the heart.

Device Description

The EP-TRACER system is a computerized electrophysiology measurement system designed for both regular and experimental EP studies.

The EP-TRACER is comprised of these major components:
EP-TRACER hardware – Amplifier/stimulator
EP-TRACER Software – Software pre-installed

AI/ML Overview

This document describes the EP-TRACER System V2.2, an electrophysiology measurement system. The FDA 510(k) clearance (K183266) states its substantial equivalence to the predicate device, EP-TRACER System V2.0 (K161245). This submission primarily focuses on software modifications affecting the user interface, with no changes to the hardware.

Here's an analysis of the acceptance criteria and the study information provided:

1. Table of Acceptance Criteria and Reported Device Performance

The provided document does not explicitly state "acceptance criteria" in a quantitative, measurable format like sensitivity/specificity thresholds for a diagnostic device. Instead, the "acceptance criteria" for this submission are implicitly defined by demonstrating that the modifications to the device (V2.2 compared to V2.0) do not adversely affect safety and effectiveness and that the device conforms to relevant harmonized standards.

The "device performance" is therefore described by showing that the new device (V2.2) maintains the same fundamental technological characteristics and meets all applicable standards as the predicate device (V2.0).

Characteristic / Acceptance Criteria TypePredicate Device EP-TRACER V2.0 Performance (Implicit Acceptance Baseline)New Device EP-TRACER V2.2 Performance (Reported)Met?
Hardware ComponentsSame as listed in "Technological Characteristics" tableSameYes
Amplifier Dimensions38 channels: 28x27x7 cm; 70/102 channels: 28x27x12 cmSameYes
Environmental Specs (Temp, Humidity)Operating: +10°C to +30°C, 20-80% rH; Storage: -29°C to +66°C, <95% rHSameYes
Power Specs (Input, Requirements)100-240 V AC, 50-60 Hz; specific V/A for channelsSameYes
Design (Sampling Rate, CMRR, Impedance, Leakage, Filters, Gain, Dynamic Range, Baseline Correct.)1 kHz, >100 dB, 20 MΩ, <10 μA patient, <100 μA chassis, various filters, etc.SameYes
Stimulator Specs (Pulse Amplitude/Duration, ISI, etc.)Specific ranges and accuracies as listed in tableSameYes
Pacing Channels (Isolated, Isolation)2 isolated channels, IEC 60601-1 compliantSameYes
Computer Controlled Stimulus PulsesRanges and accuracies for current, pulse duration, load impedance, etc.SameYes
Programmed ProtocolsBASIC 1, 2, 3; ACUTE, Multi-Sx, Pace, etc.SameYes
Programmed Protocol Key10SameYes
Number of Extra-Stimuli5 (S2 - S6)SameYes
Sensing (ECG Sync)Internal from surface/intracardiac, trigger lockup, ECG delaySameYes
Backup StimulationUse external backup stimulatorSameYes
Compliance with StandardsEN ISO 13485:2012, EN ISO 14971:2012, EN 60601-x series, EN 10993-1, etc.Conformance demonstratedYes
Software User Interface (New)
Pressure mode displayFull-screen onlyFull-screen and "minimized" displayN/A
CalipersHorizontal onlyHorizontal and verticalN/A
Eport GenerationLimited format transferCustomizable, preconfigured template transferN/A
ClockReal-time clockReal-time clock + procedure clockN/A
New IconsNo (keystrokes for these functions)Yes (for split-screens, pressure mode, stimulator settings, add comment/mark, screenshot, toggle stimulator windows)N/A
Software CompatibilityWindows 7 (32 bit)Windows 7 (64 bit) and (32 bit)N/A
Overall Safety and EffectivenessNo adverse effects from modifications due to V&V activities.YesYes

N/A for "Met?" column for new software features as they are additions/improvements, not criteria to be met against a baseline.

2. Sample Size Used for the Test Set and the Data Provenance

The document does not describe a clinical study with patients or data from a test set in the traditional sense of evaluating diagnostic accuracy. This submission is for an electrophysiology measurement system, with the current iteration (V2.2) involving only software modifications to the user interface. The performance testing primarily focused on demonstrating conformity to harmonized standards and verifying that the software changes did not negatively impact the device's safety and effectiveness.

Therefore, there is no specific mention of a "test set" sample size or data provenance (country of origin, retrospective/prospective) related to patient data or clinical outcomes. The evaluation is based on engineering verification and validation activities against the pre-existing design specifications and regulatory standards.

3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of those Experts

Given that this is a modification to an electrophysiology measurement system focusing on user interface changes and compliance with standards, there is no indication of "experts" being used to establish ground truth for a test set in a diagnostic or clinical performance context. The "ground truth" here would relate to the correct functioning of the system's electrical measurements and stimulation based on engineering specifications and adherence to standards, likely assessed by qualified engineers and domain experts internal to the manufacturer.

4. Adjudication Method for the Test Set

As there is no described "test set" involving human interpretation or clinical data requiring ground truth establishment, there is no mention of an adjudication method.

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

No MRMC comparative effectiveness study was mentioned or performed. This device is an electrophysiology measurement system, not an AI-assisted diagnostic tool for image interpretation or similar. The "user interface convenience features" are productivity enhancements rather than AI-driven diagnostic assistance.

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

This is not applicable. The EP-TRACER System is an electrophysiology measurement system used by human operators (clinicians) for acquiring, displaying, and recording signals and performing diagnostic cardiac stimulation. It is not an algorithm designed to perform a standalone diagnostic task without human intervention. The software updates are improvements to the human-machine interface.

7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.)

For this submission, the "ground truth" essentially refers to:

  • The engineering specifications of the device (e.g., accuracy of pulse amplitude, sampling rate, filter characteristics).
  • Compliance with harmonized standards (e.g., electrical safety, EMC, usability).
  • The predicate device (EP-TRACER V2.0) as a baseline for safety and effectiveness of the core functionality.

The performance testing (verification and validation) demonstrated that the updated software met predetermined design and performance specifications and that modifications did not adversely affect the safety and effectiveness compared to the predicate.

8. The Sample Size for the Training Set

There is no mention of a "training set" in the context of machine learning or AI, as this submission doesn't describe an AI/ML algorithm being developed or deployed. The software modifications are user interface improvements.

9. How the Ground Truth for the Training Set Was Established

Not applicable, as there is no training set for an AI/ML algorithm mentioned.

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March 1, 2019

Schwarzer CardioTek GmbH % Melissa Walker President and Chief Technology Officer Graematter, Inc. 1324 Clarkson Clayton Ctr., #332 Ballwin, Missouri 63011

Re: K183266

Trade/Device Name: EP-TRACER System Regulation Number: 21 CFR 870.1425 Regulation Name: Programmable Diagnostic Computer Regulatory Class: Class II Product Code: DOK Dated: February 4, 2019 Received: February 4, 2019

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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 of medical device-related adverse events) (21 CFR 803) for

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devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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 comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

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) K183266

Device Name EP-TRACER System

Indications for Use (Describe)

The EP-TRACER System is an electrophysiology measurement system used to acquire, filter, digitize, amplify, display, and record signals obtained during electrophysiological studies and related procedures.

The system allows the user to monitor, display and record the signals. The system incorporates a stimulator intended to be used for diagnostic cardiac stimulation during electrophysiological testing of the 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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EP TRACER Summary

Submitter'sinformationContact: Tatjana NuberSchwarzer CardioTek GmbHIm Zukunftspark 374076 Heilbronn / GermanyContact: Melissa WalkerGraematter, Inc.1324 Clarkson Clayton Ctr #332Ballwin, MO 63011Phone: 636-405-7498Date: 28 Feb 2019
Device/classificationnameDevice Name:The EP-TRACER is a Class 2 device (product code DQK).
Classification/Common name:• Programmable diagnostic computer, 21 CFR §870.1425.
The marketed device(s) to which substantial equivalence is claimed:• EP-TRACER System, K161245.
DevicedescriptionThe EP-TRACER system is a computerized electrophysiology measurementsystem designed for both regular and experimental EP studies.The EP-TRACER is comprised of these major components:EP-TRACER hardware – Amplifier/stimulator EP-TRACER Software – Software pre-installed
Indications foruse"The EP-TRACER System is an electrophysiology measurement system used toacquire, filter, digitize, amplify, display, and record signals obtained duringelectrophysiological studies and related procedures."The system allows the user to monitor, display and record the signals. Thesystem incorporates a stimulator intended to be used for diagnostic cardiacstimulation during electrophysiological testing of the heart".
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510(k) Summary per 21CFR §807.92, Continued

Technological The table below lists the technological characteristics for both the new and characteristics predicate devices. Modifications to the EP TRACER for V2.2 are limited to user interface modifications.

Device CharacteristicPredicate Device EP-TRACER V2.0New Device EP-TRACER V2.2
Amplifier Dimensions (withintegrated stimulator) WxDxH38 channels: 28x27x7 in cm70/102 channels: 28x27x12 in cmSame
Environmental Specifications
Temperature Operating+10°C to +30°CSame
Temperature Transport/Storage-29°C to +66°CSame
Humidity Operating20 - 80 % rH (non-condensing)Same
Humidity Transport/Storage< 95 % rH (non-condensing)Same
Power Specifications
Power Requirements100 - 240 V AC,50 - 60 HzSame
Power Input38 channels:+5 V, 0.3 A & +12 V, 0.9 ASame
70 channels:+5 V, 0.3 A & +12 V, 1.5 A
102 channels:+5 V, 0.3 A & +12 V, 2 A
Design
Sampling and HoldEach channel sampled prior theacquisitionSame
Sampling Rate1 kHzSame
CMRR> 100 dBSame
Input ImpedanceTypical 20 ΜΩSame
Leakage Current
Patient Source< 10 μΑSame
Patient Sink< 10 μΑSame
Patient Sink (measured at patientleads under single faultconditions)< 50 μΑSame
Chassis Leakage< 100 μΑSame
ECG Input
Outputs12 lead ECG producedSame
High Pass Filter0.05 Hz, 0.2 HzSame
Low Pass Filter150 HzSame
RF FilteringAll inputsSame
GainBetween 0 and 255 mm/mV -continuousSame
Saturation Recovery< 1 sec (manual reset)Same
Notch FilterPower line (50/60 Hz)Same
Device CharacteristicPredicate Device EP-TRACER V2.0New Device EP-TRACER V2.2
Dynamic Range±5 mVSame
Baseline Correction±300 mVSame
Input/ Output
Inputs 32/38 channels20 intracardiac channels, 6 auxiliarychannels, 12 ECG channelsSame
Inputs 64/70 channels52 intracardiac channels, 6 auxiliarychannels, 12 ECG channelsSame
Inputs 102 channels84 intracardiac channels, 6 auxiliary(pressure) channels, 12 ECG channelsSame
OutputsNo outputsSame
SwitchingEach channel can be either bipolar orunipolar with manual switchingSame
High Pass Filter0.05 Hz, 0.2 Hz, 40 Hz, 80 HzSame
Low Pass Filter350 HzSame
RF FilteringAll inputsSame
GainBetween 0 and 255 mm/mV -continuousSame
Saturation Recovery< 1 s (manual reset)Same
Notch FilterPower line (50/60 Hz)Same
Dynamic Range±5 mVSame
Baseline Correction±300 mVSame
Stimulator (integrated into device)
Isolated Stimulus Channels2Same
Pulse Amplitude
Range0 - 25.5 mA into 1000 Ω loadSame
Increment0.1 msSame
Accuracy±0.15 msSame
Pulse Duration
Range0.1 - 9.9 msSame
Increment0.1 msSame
Accuracy±0.15 msSame
Inter-Stimulus Interval (ISI)
Range10 - 9999 msSame
Range (Burst)10 - 9999 msSame
Increment10 msSame
Sequential Delay (AV)
Range11 - 250 msSame
Increment1 msSame
Programmed ProtocolsPreprogrammed protocols:BASIC 1 (induction)BASIC 2 (termination)BASIC 3 (backup)ACUTEMulti-SxSame
Device CharacteristicPredicate Device EP-TRACER V2.0New Device EP-TRACER V2.2
Programmed ProtocolsPaceAutomatic modeWenkebach modeUser defined protocolsSame
Programmable Protocol Key10Same
Number of Extra-Stimuli5 (S2 - S6)Same
Sensing (ECG Synchronization)
Automatic or Manual TriggerSetting - SensitivityInternal from any surface or intra-cardiac channelSame
Automatic or Manual TriggerSetting - Trigger lockup(refractory time)5 - 5000 msSame
Automatic or Manual TriggerSetting - ECG Delay5 - 5000 msSame
Additional OutputsNoSame
Power SourceIntegrated with amplifier38 channels:+5 V, 0.3 A & +12 V, 0.9 A70 channels:+5 V, 0.3 A & +12 V, 1.5 A102 channels:+5 V, 0.3 A & +12 V, 2 ASame
Pacing Channels
Isolated Channels(i) atrial and(ii) ventricular and(iii) emergency fixed pace output toatrium and ventricleSame
Circuit IsolationCompliant with IEC 60601-1, Type CF,5 kV, common & differential modeSame
Computer Controlled Stimulus Pulses
Current0 - 25.5 mA into 1000 Ω loadSame
Current Steps0.1 mASame
Accuracy±0.1 mASame
Pulse durationPulse width 0.1 - 9.9 ms, steps of 0.1msSame
Accuracy±0.1 mASame
Load Impedance1000 ΩSame
Max. Output Voltage25 VSame
Inter-Stimulus Intervals
S1 Range10 - 9999 msSame
StabilityQuartz computer clock, ±30 parts permillion at +25°CSame
Extra-Stimuli5 (S2 - S6)Same
Coupling Interval30 - 9990 msSame
Accuracy±10 msSame
Protocol Automation
Auto decrement/incrementYesSame
Device CharacteristicPredicate Device EP-TRACER V2.0New Device EP-TRACER V2.2
Backup Manually ControlledStimulationUse external backup stimulatorSame
Emergency Backup PacingUse external backup stimulatorSame
Compliance with Standards
StandardsEN 60601-1EN 60601-1-2Same
Device DirectiveEuropean Union Medical DeviceDirective (CE Marked)Same
Environmental/ Electrical Specifications
Operating Temperature+10°C to +30°CSame
Storage Temperature-29°C to +66°CSame
Operating Humidity20 - 80 % rH (non-condensing)Same
Storage Humidity< 95 % rH (non-condensing)Same
Max. Current Draw15 A/115 V, 7 A/230 VSame
Chassis Leakage Current< 100 μΑSame
Advanced Features
Display Ablation ParametersConnection to RF ablationgenerator(s)Same
Certification
MDD Device ClassClass IIbSame
IEC 60601-1CertifiedSame
EMC ComplianceCertifiedSame
CE MarkingCertified CE 0197Same
US RegulationsK161245Current submission
System Dimensions
W x D x HCustomer OptionMobile Cart: 100x80x170 cmMobile Desk: 125x80x150 cmControl Desk: customer definedLaptop: customer definedSame

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

Software – user The EP TRACER V2.2 included software modifications affecting the user interface interface including improvements in the display and organization of the convenience system's outputs. There were no modifications to the hardware of the new features added device.

The table below shows the software differences between the EP-TRACER V2.2 vs. the predicate device EP-TRACER V2.0.

Device CharacteristicPredicate DeviceEP-TRACER V2.0New DeviceEP-TRACER V2.2
User Interface Convenience Features
Pressure mode displayPressure data is displayed in afull-screen window which isseparate from the main tracedisplay window.In addition to the full-screenpressure mode available in V2.0,pressure channels can bedisplayed in a “minimized”pressure mode display withinthe main trace display window.
CalipersHorizontal calipers can bedisplayedBoth horizontal and verticalcalipers can be displayed
One-click report generationEnables transfer of proceduraldata in a limited formatEnables transfer of proceduraldata to a customizable,preconfigured template.
ClockReal-time clockAdded a procedure clock,displaying procedure time.
New Icons
Split-screensExecuted with keystrokesIcon added for existing feature
Pressure modeOnly one pressure mode displayToggles between full-screen andminimized pressure modedisplay
Stimulator power settingsExecuted with keystrokesIcon added for existing feature
Add commentExecuted with keystrokesIcon added for existing feature
Add markExecuted with keystrokesIcon added for existing feature
Take screenshotExecuted with keystrokesIcon added for existing feature
Toggle stimulator protocol/parameters windowsExecuted with keystrokesIcon added for existing feature
Software compatibility
Operating systemWindows 7 (32 bit)Windows 7 (64 bit) andWindows 7 (32 bit)

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

PerformancetestingCompletion of all verification and validation activities demonstrated that thesubject devices meet their predetermined design and performancespecifications. Verification activities performed confirmed that themodifications to the predicate device did not adversely affect the safety andeffectiveness of the modified device.
Testing for the EP-Tracer V 2.2 shows conformance to the followingharmonized standards:• EN ISO 13485:2012• EN ISO 14971:2012• EN 60601-1:2006+A1: 2013• EN 60601-1-2:2007+ AC: 2010• EN 60601-1-6:2010• EN 60601-2-27:2006• EN 60601-2-34:2011• EN 10993-1:2009• EN 980:2008• EN 1041:2008• EN 62366: 2008• EN 62304: 2006
ConclusionBoth the subject and predicate devices have the same intended use,indications for use, and operate using the same fundamental scientifictechnology.

Based on the technical characteristics and the results of the performance testing, the EP TRACER V2.2 is substantially equivalent to V2.0.

§ 870.1425 Programmable diagnostic computer.

(a)
Identification. A programmable diagnostic computer is a device that can be programmed to compute various physiologic or blood flow parameters based on the output from one or more electrodes, transducers, or measuring devices; this device includes any associated commercially supplied programs.(b)
Classification. Class II (performance standards).