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510(k) Data Aggregation

    K Number
    K212317
    Date Cleared
    2022-11-07

    (469 days)

    Product Code
    Regulation Number
    870.2800
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Eclipse MINI Model 98900

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Eclipse MINI Model 98900 is a portable non-invasive continuous ambulatory ECG patch recorder intended to record the patient's electrocardiogram. The recorder is intended to be used by either paediatric or adult patients suspected of cardiac arrhythmias in either a clinical setting or at home. The recorder does no cardiac analysis and is used with Spacelabs Ambulatory ECG Analysis Software.

    Device Description

    The Eclipse MINI Model 98900 (Eclipse MINI) is an ambulatory electrocardiograph (ECG) recorder capable of providing a 3-lead recording. It is connected to the patient using a custom, disposable, single-patient only, 3-lead sensor patch that is adhesively attached to the patient's chest. The Eclipse MINI is powered by batteries that are integrated in the Eclipse Sensor Patch. These batteries are primary cells which cannot be recharged and power the recorder for up to 15 days. For an extended recording multiple Eclipse Sensor Patches may be required. The single patient event button allows the patient to indicate symptomatic episodes in the recording for correlation with the patient diary. The Eclipse MINI is fully sealed and waterproof. The Eclipse MINI is attached to the "holster" of the Eclipse MINI Sensor Patch by inserting the USB connector on the sensor patch into the USB receptacle on the bottom of Eclipse MINI housing. Patient data from the Eclipse MINI is downloaded to a PC upon which the Spacelabs Sentinel Cardiology Information Management System (Sentinel), cleared in 510(k) submission K152881, has been installed. This allows the clinician to download, view, and analyze patient data from the Eclipse MINI, and create reports. Further analysis of these patient data can be performed by using Spacelabs Pathfinder SL Holter Analyzer (cleared in 510(k) submission K110001) and/or Spacelabs Lifescreen PRO Analyzer (cleared in 510(k) submission K201921). Finally, a non-medical device mobile phone app is available for patient use as an electronic note taking option in lieu of a manual, written patient diary.

    AI/ML Overview

    This is a 510(k) premarket notification for the Spacelabs Eclipse MINI Model 98900. A 510(k) submission generally aims to demonstrate substantial equivalence to a predicate device, rather than proving that a device meets specific acceptance criteria through a clinical study for a novel device. The document primarily focuses on demonstrating that the Eclipse MINI Model 98900 is substantially equivalent to the Reynolds Medical Ltd. Lifecard CF 7-Day Holter Recorder (K011837) based on technological characteristics and performance testing in accordance with regulatory standards.

    Therefore, the requested information regarding acceptance criteria and a study proving the device meets them, in the typical sense of a clinical trial for a new device, is not fully applicable or explicitly detailed in this 510(k) summary. The "acceptance criteria" here largely refer to meeting recognized standards for safety and performance to demonstrate substantial equivalence.

    Here's an attempt to extract and interpret the information based on the provided document within the context of a 510(k) submission:

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

    The document does not present a single table of "acceptance criteria" and "reported device performance" in the way one might expect for a specific clinical endpoint. Instead, the device's performance is demonstrated through compliance with various national and international standards and internal requirements, and by performing comparably to the predicate device.

    The "Technology Comparison" table (page 5) lists various characteristics and indicates that the Eclipse MINI's performance is consistent with these standards and the predicate. The "Summary of Performance Testing" sections (pages 6 and 7) state that the device "complies with internal requirements, applicable Standards, and the guidance document."

    Here is a summary of the broad performance areas and the reported compliance:

    Acceptance Criteria Category (implied by standards)Reported Device Performance (Summary of Testing)
    Shelf-LifeThe Eclipse MINI does not have a shelf life. The Eclipse MINI 3-lead Sensor Patch has a defined product life of 1 year from the date of manufacture. Test results indicated that the Eclipse MINI 3-lead Sensor Patch complies with its stated shelf-life.
    BiocompatibilityTested in accordance with ISO 10993-1: 2009. Test results indicated that the patient-contact materials in the Eclipse MINI comply with the applicable Standard and guidance document.
    Software Verification & ValidationDesigned and developed according to a robust software development process and rigorously verified and validated, adhering to FDA guidance (e.g., "Content of premarket submissions for software contained in medical devices," "Off-the-shelf software use in medical devices," "General principles of software validation," "Cybersecurity"). Test results indicate that the Eclipse MINI complies with its predetermined specifications, guidance documents and Standards.
    Electrical SafetyTested in accordance with IEC 60601-1: 2012 and IEC 60601-1-11: 2015. Test results indicated that the Eclipse MINI complies with the applicable Standards.
    Electromagnetic Compatibility (EMC)Tested in accordance with IEC 60601-1-2: 2014. Test results indicated that the Eclipse MINI complies with the applicable Standard.
    Performance Testing – BenchTested in accordance with internal requirements, ANSI/AAMI EC12:2000/(R)2015, IEC 60601-1-6: 2013, IEC 60601-2-47: 2012, IEC 62366-1: 2015, and relevant FDA guidance. This includes aspects like ECG recording accuracy, usability, and essential performance for ambulatory ECG systems. Test results indicated that the Eclipse MINI complies with internal requirements, applicable Standards, and the guidance document. Additionally, for Defibrillator Protection, it is stated that it is "Not defibrillator proof; however, Eclipse MINI is compliant with IEC 60601-1: 2005, Am1: 2012, Clause 8.5.5.2, Energy Reduction Test."

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    This information is not provided in a way that relates to a "test set" for a diagnostic study. The performance testing described (shelf-life, biocompatibility, software V&V, electrical safety, EMC, bench performance) are engineering and laboratory tests, not clinical studies with a patient test set in the traditional sense. Therefore, details like "sample size used for the test set" and "data provenance" (country/retrospective/prospective) are not applicable or detailed for this type of submission.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

    This device, the Eclipse MINI Model 98900, is an ECG recorder and "does no cardiac analysis" itself. It is used with "Spacelabs Ambulatory ECG Analysis Software" (which would have its own clearances, e.g., K152881, K110001, K201921). As such, it is not a diagnostic algorithm that provides an output requiring ground truth established by experts. Its function is to accurately record ECG data, and its performance is assessed against technical standards for signal acquisition and safety, not diagnostic accuracy. Therefore, this information is not applicable to the device described.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Not applicable, as there is no diagnostic "test set" and no "ground truth" adjudicated by experts for this recording device as described in the submission.

    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

    Not applicable. This device is an ECG recorder and not an AI/CADe/CADx system. No MRMC study or AI assistance improvement is mentioned or relevant to the device's function.

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

    Not applicable. This device is an ECG recorder, not an algorithm, and performs "no cardiac analysis."

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    Not applicable. As described in points 3, 4, 5, and 6, this device does not perform analysis that would require a ground truth for diagnostic accuracy. Its "ground truth" for performance is compliance with engineering and safety standards, and reliable recording of ECG data.

    8. The sample size for the training set

    Not applicable. This device is primarily hardware an embedded software for recording. It is not an AI/machine learning model that requires a training set. The software mentioned is developed through robust software development processes (as noted in the "Software" testing section) and validated against specifications, not "trained" on a data set in the ML sense.

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

    Not applicable, as there is no training set for an AI/ML model for this device.

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