(92 days)
The Current Wearable Health Monitoring System is intended for reusable bedside, mobile and central multi-parameter, physiologic monitoring of patients aged 14 years old and above in professional healthcare facilities, such as hospitals or skilled nursing facilities, or their own home. It is intended for monitoring of patients by trained healthcare professionals.
The Current Wearable Health Monitoring System is intended to provide visual and audible physiologic multi-parameter alarms. The Current Wearable Health Monitoring System is intended for temperature monitoring temperature at the upper arm is clinically indicated.
The Current Wearable Health Monitoring System is intended for continuous monitoring of the following parameters:
- · Pulse rate
- · Oxygen saturation
- · Temperature
- Movement
The Current Wearable Health Monitoring System is intended for intermittent or spot-check monitoring of:
- · Respiration rate
- · Non-invasive blood pressure
- · Lung function & spirometry
- · Weight
The Current Wearable Health Monitoring System is not intended for use in high-acuity environments, such as ICU or operating rooms.
The Current Wearable Health Monitoring System is not intended for use on acutely ill cardiac patients with the potential to develop life threatening arrhythmias e.g. very fast atrial fibrillation. For these patients, they should be monitored using a device with continuous ECG. The Current Wearable Health Monitoring System is not a substitute for an ECG monitor.
The Current Wearable Health Monitoring System is not intended for SpO2 monitoring in conditions of high motion or low perfusion.
The Current Wearable System is a remote patient monitoring system that consists of a monitoring device (the wearable) worn on the upper arm by 14 years old and above patients, a software platform (containing the alarming system) and a user interface to allow presentation of vital signs data both on mobile devices and web-based dashboard. The Current Wearable System is also integrated with third-party devices for displaying and monitoring physiological signs.
The Wearable is intended to continuously monitors physiological vital sign data from the person being monitored and securely transmit the encrypted data via the secure server. The wearable is intended for use in professional healthcare facilities, such as hospitals or skilled nursing facilities, or the home by trained healthcare professionals.
The healthcare professional can securely access the patient physiological signs remotely via a mobile application or a web-interface which is also intended to provide visual and audible physiologic multi-parameter alarms.
I am sorry, but the provided text does not contain the specific information required to complete your request. The document is a 510(k) summary for the Current Health System, focusing on an age range extension. While it mentions the device's intended use and compares it to a predicate device, it explicitly states that "no animal or clinical performance data is included" (Page 11) and that "The performance of the modification is identical to the predicate and previously cleared device in terms of technical specification and safety." (Page 11).
Therefore, there is no study described that proves the device meets specific acceptance criteria through performance data, sample sizes, expert involvement, or ground truth establishment. The submission relies on the existing clearance of the predicate device for its performance claims.
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Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, with the letters "FDA" in a blue square. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
August 24, 2023
Current Health Ltd Giovanni Maggi Regulatory Affairs Manager The Stamp Office, Level 3, 10 Waterloo Place Edinburgh, EH1 3EG United Kingdom
Re: K231506
Trade/Device Name: Current Health System Regulation Number: 21 CFR 870.2300 Regulation Name: Cardiac monitor (including cardiotachometer and rate alarm) Regulatory Class: Class II Product Code: MSX, FLL, DQA, BZQ, DRG, BZG Dated: July 28, 2023 Received: July 28, 2023
Dear Giovanni Maggi:
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.
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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-regulatoryinformation/postmarketing-safety-reporting-combination-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,
Shruti N. Mistry -S
for
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
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Indications for Use
510(k) Number (if known) K231506
Device Name Current Health System
Indications for Use (Describe)
The Current Wearable Health Monitoring System is intended for reusable bedside, mobile and central multi-parameter, physiologic monitoring of patients aged 14 years old and above in professional healthcare facilities, such as hospitals or skilled nursing facilities, or their own home. It is intended for monitoring of patients by trained healthcare professionals.
The Current Wearable Health Monitoring System is intended to provide visual and audible physiologic multi-parameter alarms. The Current Wearable Health Monitoring System is intended for temperature monitoring temperature at the upper arm is clinically indicated.
The Current Wearable Health Monitoring System is intended for continuous monitoring of the following parameters:
- · Pulse rate
- · Oxygen saturation
- · Temperature
- Movement
The Current Wearable Health Monitoring System is intended for intermittent or spot-check monitoring of:
- · Respiration rate
- · Non-invasive blood pressure
- · Lung function & spirometry
- · Weight
The Current Wearable Health Monitoring System is not intended for use in high-acuity environments, such as ICU or operating rooms.
The Current Wearable Health Monitoring System is not intended for use on acutely ill cardiac patients with the potential to develop life threatening arrhythmias e.g. very fast atrial fibrillation. For these patients, they should be monitored using a device with continuous ECG. The Current Wearable Health Monitoring System is not a substitute for an ECG monitor.
The Current Wearable Health Monitoring System is not intended for SpO2 monitoring in conditions of high motion or low perfusion.
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)
CONTINUE ON A SEPARATE PAGE IF NEEDED.
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Special 510(k) Ref: K231506
Special 510(k) Summary
Version: 1.0
Special 510(k) Summary
This summary of 510(k) substantial equivalence information is being submitted in accordance with the requirement of 21 CFR 807.92
| Submitter Information: | |
|---|---|
| Name: | Current Health Ltd. |
| Address: | The Stamp OfficeLevel 3, 10 Waterloo PlaceEdinburghEH1 3EGUnited Kingdom |
| Establishment Registration Number: | 3015134004 |
| Owner/Operator Number: | 10059040 |
| Phone: | +44 (0) 131 285 8101 |
| Contact: | Giovanni MaggiRegulatory Affairs Manager |
| E-mail: | giovanni.maggi@currenthealth.com |
| Date of Summary: | 27-Jul-2023 |
Device Information:
Below summarises the Device Classification information regarding the Current Health System.
| Device Proprietary Name | Current Health System |
|---|---|
| Common Name: | Remote Patient Monitor |
| Trade Name: | Current Wearable Health Monitoring System |
| Product Code(s): | MSX; FLL; DQA; BZQ; DRG; BZG (see below) |
Primary Product Code
| RegulationNumber (21 CFR) | Device | Product Class | Product Code | Classification Panel |
|---|---|---|---|---|
| 870.2300 | System, Network andCommunication,Physiological Monitors | Class II | MSX | Cardiovascular |
Secondary Product Codes
| RegulationNumber (21 CFR) | Device | Device Class | Product Code | Classification Panel |
|---|---|---|---|---|
| 880.2910 | Thermometer,Electronic, Clinical | Class II | FLL | General Hospital |
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Image /page/5/Picture/0 description: The image shows a blue abstract shape. The shape is a closed loop that resembles a combination of a figure eight and a circle. The loop is not perfectly symmetrical, and the lines are smooth and rounded.
Special 510(k) Ref: K231506
Section 05 – Special 510(k) Summary
Version: 1.0
| 870.2700 | Oximeter | Class II | DQA | Cardiovascular |
|---|---|---|---|---|
| 868.2375 | Monitor,BreathingFrequency | Class II | BZQ | Anaesthesiology |
| 870.2910 | Transmitters andReceivers, PhysiologicalSignal, Radiofrequency | Class II | DRG | Cardiovascular |
| 686.1840 | Spirometer, Diagnostic | Class II | BZG | Anaesthesiology |
Substantial Equivalence
| Manufacturer | Trade Name | Regulation & ProductCode | 510(k) Number |
|---|---|---|---|
| Current Health Ltd | Current Wearable HealthMonitoring System | MSX; FLL; DQA; BZQ;DRG; BZG | K222550 |
Referenced Device
| Manufacturer | Trade Name | Regulation & ProductCode | 510(k) Number |
|---|---|---|---|
| Draeger | Infinity Acute Care SystemMonitoring Solution (IACS) | MHX; BZQ; CCK; DQA,DRT; DSK; DXN; FLL; FLS;MLD; MSX | K113798 |
Submission Description
This Special 510(k) covers an extension of the age range to 14 years old and above patients on the software platform and G2 wearable of the Current Health System. This was also presented in the Q-Submission, Q212340.
There are no significant changes presented to the other software components previously cleared in K191272 – specifically, there is no change to the display of data from the wearable or how alarms are presented/notified to the healthcare professional. There are no changes to the wearable hardware component, as cleared in 510(k) K210133. There are no changes to the alarms system, as cleared in 510(k) K222550. Well-established methods have been used to evaluate the change and the data to be reviewed is provided in a summary in this submission.
Well-established methods have been used to evaluate the change and the date to be reviewed in a summary in this submission.
Device Description
General Description
The Current Wearable System is a remote patient monitoring system that consists of a monitoring device (the wearable) worn on the upper arm by 14 years old and above patients, a software platform (containing the alarming system) and a user interface to allow presentation of vital signs data both on mobile devices and web-based dashboard. The Current Wearable System is also integrated with third-party devices for displaying and monitoring physiological signs.
The Wearable is intended to continuously monitors physiological vital sign data from the person being monitored and securely transmit the encrypted data via the secure server. The wearable is
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urrent health
Special 510(k) Ref: K231506
Section 05 – Special 510(k) Summary
Version: 1.0
intended for use in professional healthcare facilities, such as hospitals or skilled nursing facilities, or the home by trained healthcare professionals.
The healthcare professional can securely access the patient physiological signs remotely via a mobile application or a web-interface which is also intended to provide visual and audible physiologic multi-parameter alarms.
Intended / Indications for Use
The Current Wearable Health Monitoring System is intended for reusable bedside, mobile and central multiparameter, physiologic monitoring of patients aged 14 years old and above in professional healthcare facilities, such as hospitals or skilled nursing facilities, such as hospitals or their own home. It is intended for monitoring of patients by trained healthcare professionals.
The Current Wearable Health Monitoring System is intended to provide visual and audible physiologic multiparameter alarms. The Current Wearable Health Monitoring System is intended for temperature monitoring where monitoring temperature at the upper arm is clinically indicated.
The Current Wearable Health Monitoring System is intended for continuous monitoring of the following parameters:
- . Pulse rate
- Oxygen saturation
- Temperature
- Movement
The Current Wearable Health Monitoring System is intermittent or spot-check monitoring of the following parameters of:
- . Respiration rate
- Non-invasive blood pressure
- Lung function & spirometry .
- Weight
The Current Wearable Health Monitoring System is not in high-acuity environments, such as ICU or operating rooms.
The Current Wearable Health Monitoring System is not intended for use on acutely ill cardiac patients with the potential to develop life-threatening arrhythmias e.g., very fast atrial fibrillation. For these patients, they should be monitored using a device with continuous ECG. The Current Wearable Health Monitoring System is not a substitute for an ECG monitor.
The Current Wearable Health Monitoring System is not intended for SpO2 monitoring in conditions of high motion or low perfusion.
Comparison with the Predicate and Previously Cleared Device
The candidate device is substantially equivalent to the predicate, K222550, the Current Health Wearable Monitoring System and a comparison of the key characteristics is summarised in Table 1.
| Characteristic | Current Health WearableMonitoring System withModification | Current HealthWearableMonitoring SystemK222550(Primary Predicate) | Draeger IACSK113798(ReferencedDevice) | Equivalencewith PrimaryPredicate |
|---|---|---|---|---|
| Device Name | Current Health MonitoringSystem | Current HealthMonitoring System | Infinity Acute CareSystem MonitoringSolution (IACS) | Equivalent |
| Characteristic | Current Health WearableMonitoring System withModification | Current HealthWearableMonitoring SystemK222550(Primary Predicate) | Draeger IACSK113798(ReferencedDevice) | Equivalencewith PrimaryPredicate |
| Manufacturer | Current Health Ltd | Current Health Ltd | Draeger | Equivalent |
| DeviceClassification | II | II | II | Equivalent |
| PrimaryProduct Code | MSX | MSX | MHX | Equivalent |
| SecondaryProduct Code | FLL; DQA; BZQ; DRG | FLL; DQA; BZQ; DRG | BZQ; CCK; DQA,DRT; DSK; DXN;FLL; FLS; MLD; MSX | Equivalent |
| TargetPopulation | 14 years and above | Adult | Adult, Paediatricand Neonatal | Substantiallyequivalent |
| Indications forUse | The Current WearableHealth Monitoring System isintended for reusablebedside, mobile and centralmulti-parameter,physiologic monitoring ofpatients aged 14 years oldand above in professionalhealthcare facilities, such ashospitals or skilled nursingfacilities, such as hospitalsor skilled nursing facilities,or their own home. It isintended for monitoring ofpatients by trainedhealthcare professionals.The Current WearableHealth Monitoring System isintended to provide visualand audible physiologicmulti-parameter alarms.The Current WearableHealth Monitoring System isintended for temperaturemonitoring wheremonitoring temperature atthe upper arm is clinicallyindicated.The Current WearableHealth Monitoring System isintended for continuousmonitoring of the followingparameters:● Pulse rate | The Current WearableHealth MonitoringSystem is intended forreusable bedside,mobile and centralmulti-parameter,physiologic patientmonitoring of adultpatients inprofessionalhealthcare facilities,such as hospitals orskilled nursingfacilities, or their ownhome. It is intendedfor monitoring ofpatients by trainedhealthcareprofessionals.The Current WearableHealth MonitoringSystem is intended toprovide visual andaudible physiologicmulti-parameteralarms. The CurrentWearable HealthMonitoring System isintended fortemperaturemonitoring wheremonitoringtemperature at theupper arm is clinicallyindicated. | The IACSMonitoring Solutionis a combination oftwo devices; InfinityM540 patientmonitor withInfinity M500docking stationintegrated with theInfinity C500Medical Cockpit oroptional C700(larger screen size)Medical Cockpit andrespective software.The IACS isintended for multi-parameter,physiologic patientmonitoring of adult,pediatric andneonatal patients inenvironmentswhere patient careis provided bytrained healthcareprofess sionals. TheIACS obtains thephysiologic, multi-parameter datafrom theconnection to theM540 monitor andoptional medicaldevices and | SubstantiallyEquivalent |
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current health
Special 510(k) Ref: K231506
Section 05 – Special 510(k) Summary
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| ) { current health |
|---|
Special 510(k) Ref: K231506
Section 05 – Special 510(k) Summary
| Characteristic | Current Health WearableMonitoring System withModification | Current HealthWearableMonitoring SystemK222550(Primary Predicate) | Draeger IACSK113798(ReferencedDevice) | Equivalencewith PrimaryPredicate |
|---|---|---|---|---|
| Oxygen saturation Temperature Movement The Current WearableHealth Monitoring System isintended for intermittent orspot-check monitoring ofthe following parameters of: Respiration rate Non-invasive bloodpressure Lung function &spirometry Weight The Current WearableHealth Monitoring System isnot intended for use in high-acuity environments, suchas ICU or operating rooms.The Current WearableHealth Monitoring System isnot intended for use onacutely ill cardiac patientswith the potential todevelop life-threateningarrhythmias e.g., very fastatrial fibrillation. For thesepatients, they should bemonitored using a devicewith continuous ECG. TheCurrent Wearable HealthMonitoring System is not asubstitute for an ECGmonitor.The Current WearableHealth Monitoring System isnot intended for SpO2monitoring in conditions ofhigh motion or lowperfusion. | The Current WearableHealth MonitoringSystem is intended forcontinuousmonitoring of thefollowing parametersin adults:Pulse rate Oxygensaturation Temperature Movement The Current WearableHealth MonitoringSystem is intended forintermittent or spot-check monitoring ofthe followingparameters in adults,of: Respirationrate Non-invasivebloodpressure Lungfunction &spirometry Weight inadults The Current WearableHealth MonitoringSystem is notintended for use inhigh-acuityenvironments, such asICU or operatingrooms.The Current WearableHealth MonitoringSystem is notintended for use onacutely ill cardiacpatients with thepotential to developlife-threateningarrhythmias e.g., very | displays. Thetransfer of this datais accomplished bythe Infinitynetwork.The Infinity M540 isintended for themonitoring of multi-parameter,physiologicalpatient informationobtained fromconnectedhardware inenvironmentswhere patient careis provided bytrained healthcareprofessional. TheM540 is intended tomonitor one patientat a time. |
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Special 510(k) Ref: K231506
Section 05 – Special 510(k) Summary
| Characteristic | Current Health WearableMonitoring System withModification | Current HealthWearableMonitoring SystemK222550(Primary Predicate) | Draeger IACSK113798(ReferencedDevice) | Equivalencewith PrimaryPredicate |
|---|---|---|---|---|
| fast atrial fibrillation.For these patients,they should bemonitored using adevice withcontinuous ECG. TheCurrent WearableHealth MonitoringSystem is not asubstitute for an ECGmonitor.The Current WearableHealth MonitoringSystem is notintended for SpO2monitoring inconditions of highmotion or lowperfusion. | ||||
| Intendeduser/Location | Professional healthcarefacilities & homeenvironments | Professionalhealthcare facilities& homeenvironments | Professionalhealthcarefacilities | Equivalent |
| Site ofapplication | Wearable monitor upperarm with a strap | Wearable monitorupper arm with astrap | Wearable monitor | Equivalent |
| Wearablephysiologicalmonitoring | Pulse rate; Oxygensaturation; Temperature;Respiration Rate;Movement | Pulse rate; Oxygensaturation;Temperature;Respiration Rate;Movement | Heart rate;Arrhythmia(adult andpediatric only);12-lead analysis;ST segmentanalysisincluding TruST®(adult andpediatric only);12-lead STsegment analysis(adult andpediatric only);Apnea;Respiration rate;Invasivepressure; Non-invasive | Equivalent |
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| ) current health |
|---|
Special 510(k) Ref: K231506
Section 05 – Special 510(k) Summary
| Characteristic | Current Health WearableMonitoring System withModification | Current HealthWearableMonitoring SystemK222550(Primary Predicate) | Draeger IACSK113798(ReferencedDevice) | Equivalencewith PrimaryPredicate |
|---|---|---|---|---|
| Temperature;Cardiac output;Arterial oxygensaturation (SpO2); Pulse rate;Perfusion Index(PI); Totalhemoglobin(SpHb) - adultand pediatriconly; Totaloxygen content(SpCO) - adultand pediatriconly;Methemoglobinsaturation(SpMet); Plethvariability index(PVI);MainstreametCO2 | ||||
| Instructions ofuse | Instructions for useincluded that includesgraphical instructions, textand relevant warnings andcautions | Instructions for useincluded thatincludes graphicalinstructions, text andrelevant warningsand cautions | Instructions for useincluded thatincludes graphicalinstructions, textand relevantwarnings andcautions | Equivalent |
| Sterile | No | No | No | Equivalent |
| Re-usable | Yes | Yes | Yes | Equivalent |
| Generation ofAlarms | The alarm system inputsdata from the patient factsdatabase (data from thewearable, existingintegrated devices andfrom a broader range ofpatient observations) togenerate appropriatealarms, notifications andquantified notes to theclinical care team | The alarm systeminputs data fromthe patient factsdatabase (datafrom the wearable,existingintegrated devicesand from abroader range ofpatientobservations) togenerateappropriate alarms,notifications | Arrhythmiadetector and alarm(including ST-segmentmeasurement andalarm) | Equivalent |
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| Image: Current Health logo | current health |
|---|---|
| ---------------------------- | ---------------- |
Special 510(k) Ref: K231506
Section 05 - Special 510(k) Summary
Version: 1.0
| Characteristic | Current Health WearableMonitoring System withModification | Current HealthWearableMonitoring SystemK222550(Primary Predicate) | Draeger IACSK113798(ReferencedDevice) | Equivalencewith PrimaryPredicate |
|---|---|---|---|---|
| and quantified notesto the clinicalcare team | ||||
| Display ofAlarms on UserInterface | Alarms are presentedthrough visual and audiblenotifications on the webdashboard and mobileapps | Alarms arepresented throughvisual and audiblenotifications on theweb dashboard andmobile apps | Alarms arepresented throughuser interfacedisplayable atbedside | Equivalent |
Table 1: Comparison of characteristics between the Modified System and the Predicate Systems.
Technological Characteristics
The proposed modification to extending the age range to 14 years old and above patients on the Current Health Wearable Monitoring System has identical indications for use, operating principles, performance, and technical specification as the predicate device, the Current Health Wearable Monitoring system.
Summary of Non-Clinical Tests (Performance data)
The performance of the modification is identical to the predicate and previously cleared device in terms of technical specification and safety.
Summary of Animal & Clinical Studies
Substantial equivalence is based on an assessment of non-clinical performance data and no animal or clinical performance data is included.
Conclusion
Based on the information presented in this Special 510(k) submission, the Current Health Wearable Monitoring System with the modified intended patient population, is substantially equivalent to the predicate device (Current Health Wearable Monitoring System) in terms of safety, performance, functionality, and indications for use and is as safe and effective as the predicate device for its intended use.
§ 870.2300 Cardiac monitor (including cardiotachometer and rate alarm).
(a)
Identification. A cardiac monitor (including cardiotachometer and rate alarm) is a device used to measure the heart rate from an analog signal produced by an electrocardiograph, vectorcardiograph, or blood pressure monitor. This device may sound an alarm when the heart rate falls outside preset upper and lower limits.(b)
Classification. Class II (performance standards).