K Number
K200722
Device Name
PCA-C1 series Patient Cable
Manufacturer
Date Cleared
2021-06-03

(441 days)

Product Code
Regulation Number
870.2900
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
PCA-C100 Patient Cable is intended to be used with QT ECG device. The Patient Cable is used to connect electrodes placed at appropriate sites on the patient to an ECG device for general diagnostic evaluation by healthcare professionals.
Device Description
The PCA-C100 Patient Cable is a reusable ECG patient cable that is used to transmit cardiac electrical signals (ECG) from electrodes, which are affixed to the patient's body for both diagnostic purposes. The PCA-C100 Patient Cable is a crucial part of the system used diagnose the cardiac electrical signal (ECG). It allows a safe connection between the electrodes on the patient and QT ECG (K180157). The PCA-C100 Patient Cable is composed of three components: Snap - Connected with Leadwire and commercial ECG electrode. Leadwire - fitted with Trunk, and connected with ten Snaps. Trunk - Fitted with two ends: one of them connects the QT ECG (K180157); and the other end connects the Leadwires.
More Information

No
The device description and performance studies focus solely on the physical cable's function of transmitting electrical signals and its safety/performance characteristics. There is no mention of any data processing, analysis, or algorithmic components that would suggest AI/ML.

No.
The device is used to transmit cardiac electrical signals for diagnostic purposes, not to provide therapy.

No

The device is a cable that transmits signals for diagnostic evaluation; it is not the diagnostic device itself.

No

The device description explicitly details physical components (Snap, Leadwire, Trunk) and their function in transmitting electrical signals, indicating it is a hardware device.

Based on the provided information, the PCA-C100 Patient Cable is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In Vitro Diagnostics are devices used to examine specimens taken from the human body (like blood, urine, tissue) to provide information for diagnosis, monitoring, or screening.
  • PCA-C100 Function: The PCA-C100 Patient Cable is a component that connects electrodes placed on the patient's body to an ECG device. It transmits electrical signals from the body, not from a specimen taken from the body.
  • Intended Use: The intended use clearly states it's used to connect electrodes placed at appropriate sites on the patient to an ECG device.
  • Device Description: The description reinforces that it transmits cardiac electrical signals from electrodes, which are affixed to the patient's body.

Therefore, the PCA-C100 Patient Cable is a medical device used for in vivo (within the living body) measurement, not in vitro (in glass/outside the body) diagnostic testing.

N/A

Intended Use / Indications for Use

PCA-C100 Patient Cable is intended to be used with QT ECG device. The Patient Cable is used to connect electrodes placed at appropriate sites on the patient to an ECG device for general diagnostic evaluation by healthcare professionals.

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

DSA

Device Description

The PCA-C100 Patient Cable is a reusable ECG patient cable that is used to transmit cardiac electrical signals (ECG) from electrodes, which are affixed to the patient's body for both diagnostic purposes.

The PCA-C100 Patient Cable is a crucial part of the system used diagnose the cardiac electrical signal (ECG). It allows a safe connection between the electrodes on the patient and QT ECG (K180157).

The PCA-C100 Patient Cable is composed of three components:
. Snap - Connected with Leadwire and commercial ECG electrode.
. Leadwire - fitted with Trunk, and connected with ten Snaps.
. Trunk - Fitted with two ends:
- one of them connects the QT ECG (K180157); and
- the other end connects the Leadwires.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

The ECG cable attached to sensors places at standard specified locations on the chest wall.

Indicated Patient Age Range

Not Found

Intended User / Care Setting

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)

A series of safety and performance tests were conducted on the subject device, PCA-C100 Patient Cable.

Biocompatibility

  • In Vitro Cytotoxicity Test
  • White Rabbit Skin Irritation Test
  • Skin Sensitization Study (Maximization Test)

Electromagnetic compatibility and electrical safety tests

  • Electrical Safty Test
    • ANSI AAMI EC53:2013 ECG Trunk Cables And Patient Leadwires
  • ANSI AAMI 60601-1: ES60601-1:2005/(R)2012 And A1:2012 C1:2009/(R)2012 And A2:2010/(R)2012 (Consolidated Text) Medical Electrical Equipment - Part 1 : General Requirements For Basic Safety And Essential Performance (IEC 60601-1:2005, MOD)
  • Safety and Essential Performance of Electrocardiographs
  • Leadwires to trunk cable interconnection
    • ANSI AAMI EC53:2013, ECG Trunk Cables And Patient Leadwires

Performance & Shelf life

  • Shelf life testing is not applicable since the PCA-C100 Patient Cable is reusable.
  • Performance testing - Bench was conducted on the PCA-C100 Patient Cable according with established protocols and test results confirm that the final product met the requirements for the safety and performance standards and it's intended use.
  • Performance testing - Clinical is not required and was not performed to demonstrate safty and effectiveness of PCA-C100 Patient Cable.
  • Performance testing - Animal is not required and was not performed to demonstrate safty and effectiveness of PCA-C100 Patient Cable.

All the test results demonstrate PCA-C100 Patient Cable meets the requirements of its predefined acceptance criteria and intended use, and is substantially equivalent to the predicate device.

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.

K120010

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.

K180157

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

§ 870.2900 Patient transducer and electrode cable (including connector).

(a)
Identification. A patient transducer and electrode cable (including connector) is an electrical conductor used to transmit signals from, or power or excitation signals to, patient-connected electrodes or transducers.(b)
Classification. Class II (performance standards).

0

Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: a symbol on the left and the FDA name on the right. The symbol on the left is a stylized image of a human figure, while the FDA name on the right is written in blue letters. The words "U.S. FOOD & DRUG ADMINISTRATION" are written in a clear, sans-serif font.

June 3, 2021

QT Medical, Inc. Ruey-Kang Chang CEO 1360 Valley Vista Dr., Suite 203 Diamond Bar, California 91765

Re: K200722

Trade/Device Name: PCA-C1 series Patient Cable Regulation Number: 21 CFR 870.2900 Regulation Name: Patient Transducer And Electrode Cable (Including Connector) Regulatory Class: Class II Product Code: DSA Dated: May 19, 2021 Received: June 1, 2021

Dear Ruey-Kang Chang:

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

1

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 devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Jennifer Shih 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

Enclosure

2

Indications for Use

510(k) Number (if known) K200722

Device Name

PCA-C100 Patient Cable

Indications for Use (Describe)

PCA-C100 Patient Cable is intended to be used with QT ECG device. The Patient Cable is used to connect electrodes placed at appropriate sites on the patient to an ECG device for general diagnostic evaluation by healthcare professionals.

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

QT Medical, Inc. PCA-C100 Patient Cable Traditional 510(k) 510(k) Summary

510(k) Summary

4

510(k) SUMMARY

5.1Type of Submission:Traditional 510(k)
5.2Date of Summary:02/20/2020
5.3Submitter:QT Medical, Inc.
Address:1360 Valley Vista Dr., Suite 203, Diamond Bar, CA 91765, USA
Phone:+1 909 323 0007
Fax:+1 310 755 3108
Contact:Ruey-Kang Chang
(rk.chang@qtmedical.com)

5.4 Identification of the Device:

Proprietary/Trade name:PCA-C100 Patient Cable
Classification Product Code:DSA
Regulation Number:870.2900
Regulation Description:Patient transducer and electrode cable
(including connector).
Review Panel:Cardiovascular
Device Class:II

ર્સ્ડ Identification of the Predicate Device:

Predicate Device Name:Cable / lead-wire
Manufacturer:Shenzhen Med-link Electronics Tech Co., Ltd.
Classification Product Code:DSA
Regulation number:870.2900
Device Class:II
510(k) Number:K120010

5.6 Indications for Use of the Device

Indication for Use:

PCA-C100 Patient Cable is intended to be used with QT ECG device. The Patient Cable is used to connect electrodes placed at appropriate sites on the patient to an ECG device for general diagnostic evaluation by healthcare professionals.

5

5.7 Device Description

The PCA-C100 Patient Cable is a reusable ECG patient cable that is used to transmit cardiac electrical signals (ECG) from electrodes, which are affixed to the patient's body for both diagnostic purposes.

The PCA-C100 Patient Cable is a crucial part of the system used diagnose the cardiac electrical signal (ECG). It allows a safe connection between the electrodes on the patient and QT ECG (K180157).

The PCA-C100 Patient Cable is composed of three components:

  • . Snap - Connected with Leadwire and commercial ECG electrode.
  • . Leadwire - fitted with Trunk, and connected with ten Snaps.
  • . Trunk - Fitted with two ends:
    • ם one of them connects the QT ECG (K180157); and
    • ם the other end connects the Leadwires.

5.8 Non-clinical Testing

A series of safety and performance tests were conducted on the subject device, PCA-C100 Patient Cable.

● Biocompatibility

  • In Vitro Cytotoxicity Test
  • White Rabbit Skin Irritation Test
  • Skin Sensitization Study (Maximization Test) i

. Electromagnetic compatibility and electrical safety tests

  • Electrical Safty Test
    • ANSI AAMI EC53:2013

ECG Trunk Cables And Patient Leadwires

  • ANSI AAMI 60601-1: ES60601-1:2005/(R)2012 And A1:2012
    C1:2009/(R)2012 And A2:2010/(R)2012 (Consolidated Text) Medical Electrical Equipment - Part 1 : General Requirements For Basic Safety And Essential Performance (IEC 60601-1:2005, MOD)

  • Safety and Essential Performance of Electrocardiographs

  • . Leadwires to trunk cable interconnection

    • ANSI AAMI EC53:2013, ECG Trunk Cables And Patient Leadwires

6

OT Medical, Inc. PCA-C100 Patient Cable

e,

● Performance & Shelf life

  • Shelf life testing is not applicable since the PCA-C100 Patient Cable is reusable.

  • Performance testing - Bench was conducted on the PCA-C100 Patient Cable according with established protocols and test results confirm that the final product met the requirements for the safety and performance standards and it's intended use.

  • Performance testing - Clinical is not required and was not performed to demonstrate safty and effectiveness of PCA-C100 Patient Cable.

  • Performance testing - Animal is not required and was not performed to demonstrate safty and effectiveness of PCA-C100 Patient Cable.

All the test results demonstrate PCA-C100 Patient Cable meets the requirements of its predefined acceptance criteria and intended use, and is substantially equivalent to the predicate device.

5.9 Substantial Equivalence Determination

The PCA-C100 Patient Cable submitted in this 510(k) file is substantially equivalent in intended use, technology/mechanism of action, safety and performance to the cleared device, Cable / lead-wire (K120010). Differences between the devices cited in this section do not raise any new issue of substantial equivalence.

ItemSubject devicePredicate device
ManufacturerQT Medical, Inc.Shenzhen Med-link
Electronics Tech Co., Ltd.
Trade NameQT ECGCable / lead-wireSubstantial equivalence
determination
Common NameCable / lead-wireCable / lead-wire
Device ModelPCA-C100VA018BCA
510(k) No.(to be assigned)K120010
Product CodeDSADSAIdentical
Regulation Number870.2900870.2900Identical
ItemSubject DevicePredicate deviceSubstantial
equivalence
determination
Indications for
UsePCA-C100 Patient Cable
is intended to be used
with QT ECG device. The
Patient Cable is used to
connect electrodes
placed at appropriate
sites on the patient to
an ECG device for
general diagnostic
evaluation by healthcare
professionals.The Shenzhen Med-link
Cable / lead-wire are
intended to be used with
ECG, EKG, Sp02 and
Invasive Blood Pressure
monitoring devices. The
Cable / lead-wire are used
to connect electrodes,
catheters, and/or sensors
placed at appropriate sites
on the patient to a
monitoring device for
general monitoring and/or
diagnostic evaluation by
healthcare professional.Equivalent
PCA-C100 Patient Cable
is used with a specified
ECG device (QT ECG) and
can not be used with a
defibrillator. The
predicate has various
types connect to various
devices, like ECG, EKG,
and Spo2 and invasive
blood pressure
monitoring devices.
The differences in
indications for use do
not change the device's
intended use to connect
electrodes placed at
appropriate sites on the
patient to a general
diagnostic evaluation
device by healthcare
professionals.
Patent UsageReusableReusableIdentical
Anatomical SiteThe ECG cable attached
to sensors places at
standard specified
locations on the chest
wall.The ECG and EKG cable
attached to sensors places
at standard specified
locations on the chest wall.Identical
Design /
AppearanceECG and EKG Cable
with connector (lead
wire, electrode snapper)ECG and EKG Cables with
various connectors
(monitor, truck / lead wire,
electrode grabber &
snapper)Equivalent
PCA-C100 Patient Cable
differs in that it has only
one type to connect a
specified device (QT
ECG), and only one type
(snapper) to connect
with electrodes.
ItemSubject DevicePredicate deviceSubstantial
equivalence
determination
Cable Length550mm (limb lead)
350mm (chest lead)Various specified
3060mm
(model:VA008BBA)Equivalent
Since the main device
(QT ECG) is closer to
the patient, the cable
length is shorter than
the predicate device.
Both devices provide
adequate length to
connect with the main
device and electrode.
Wire MaterialShielded & Unshielded
Copper with TPU JacketShielded & Unshielded
Copper with PVC or TPU
JacketIdentical
SterilityNon sterileNon sterileIdentical
Biocompatibility
EvaluationAll the patient contracting
materials are evaluated by
the biocompatibility
standard ISO 10993-5,
ISO 10993-10All the patient contracting
materials are evaluated by
the biocompatibility
standard ISO 10993-5, ISO
10993-10Identical
Connector
Retention ForceANSI/AAMI EC 53:2013ANSI/AAMI EC 53:1995 /
(R) 2001Identical
Performance
and SafetyANSI/AAMI EC 53:2013
and IEC 60601-1:2005 +
A1:2012ANSI/AAMI EC 53:1995 /
(R) 2001 and IEC 60601-
1:1998; AM1; A2:1995Identical

7

QT Medical, Inc. PCA-C100 Patient Cable

Traditional 510(k) 510(k) Summary

8

Traditional 510(k) 510(k) Summary

9

5.10 Similarity and Difference

The PCA-C100 Patient Cable has been compared with "Cable/Lead-Wire ". The subject device has the same intended use, technology/mechanism of action, safety and performance as the predicate device. Although there are some specifications that are different between two devices, the performance test and usability test have been completed to demonstrate that the differences between these parameters would not impact the safety and effectiveness of the subject device. The subject device has undergone safety and performance tests, and the results complied with the test requests. Therefore, the difference between the subject device and the predicate device did not raise any problem of substantial equivalence. The subject device is substantially equivalent to the predicate device in intended use, safety and performance claims.

5.11 Conclusion

In conclusion, QT Medical, Inc. believes that PCA-C100 Patient Cable is as safe and as effective as the predicate, and thus, is substantially equivalent to the predicate device.