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510(k) Data Aggregation
(124 days)
M5 Recorder
The M5 Recorder is indicated for use on patients who may be asymptomatic or who may suffer from transient symptoms such as palpitations, shortness of breath, dizziness, light headedness, pre-syncope, syncope, fatigue, chest pain and/or anxiety.
The M5 Recorder is intended for use by adults and all pediatric subgroups (weighing more than 10 Kg).
The M5 Recorder is a small, lightweight ambulatory electrocardiograph (ECG) recorder that records ECG continuously. The M5 records 1 or 3 channels of ECG up to 21 days. The battery duration of the M5 is dependent on the configured settings of sample rate and channel selection. The device is composed of the ECG recorder that can be utilized with a patch electrode or with a patient cable lead set using off the shelf electrodes intended for long-term monitoring. The device snaps onto the patch electrode or patient cable lead set and automatically begins recording. The recording will continue until either the M5 completes the programmed monitoring session, is removed from the Patch Electrode or patient cable, or the battery is depleted.
At the end of the recording, the device can be plugged into a PC via the M5 USB cable. The ECG recording can be transferred to a PC where processing software can transfer the data to a format that can be processed through recording processing software provided by recording processing software manufacturers and analyzed by qualified healthcare providers. The M5 recorder acquires ECG data and does not perform any data processing or arrhythmia analysis of the ECG data. Only the M5 Recorder is part of this 510K application.
During the recording period the patient wears the M5 Recorder with the patch electrode on the upper chest near the sternum. If using the M5 Recorder with the patient cable, the patient will wear off the shelf electrodes (2 - 5) positioned on the torso. The M5 Recorder can be worn continuously up to 14 days with the same patch electrode and up to 4 days with the patient cable and same set of off the shelf electrodes.
The M5 Recorder consists of a microprocessor, measuring circuit, memory, data storage, light emitting diode (LED), and contacts to the electrode. In addition to that, the M5 Recorder contains firmware to control the collection of the ECG data and allows transfer to the processing software. The M5 Recorder has an internal Bluetooth radio that may be utilized with a host ambulatory ECG analysis system (such as the Global Instrumentation M12A application) to allow the qualified health care provider a view of the patient's ECG immediately following hook-up. The LED on the M5 Recorder will flash. This provides visual confirmation to the professional that the recorder is actively collecting data.
The M5 recorder also has a button on the recorder. The primary function of the button is to provide an event feature where the patient presses the button on the recorder when they feel a symptom. The LED will flash to provide feedback to the patient that the event marking has occurred. The button also allows for a battery status check.
The associated spare parts that are part of the M5 Recorder system are the M5 Patch Electrode, M5 Patient Cable, M5 USB Cable, and GI Wall Charger.
The M5 Recorder is an ambulatory ECG recorder. It records 1 or 3 channels of ECG for up to 21 days for the purpose of detecting transient symptoms such as palpitations, shortness of breath, dizziness, lightheadedness, pre-syncope, syncope, fatigue, chest pain, and/or anxiety in adult and pediatric patients (weighing >10 kg).
Here’s a summary of the M5 Recorder's acceptance criteria and the studies performed, based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The provided document does not explicitly state quantitative clinical acceptance criteria for the M5 Recorder's performance in terms of diagnostic accuracy (e.g., sensitivity, specificity for arrhythmia detection), as the device itself does not perform arrhythmia analysis. Instead, the performance data focuses on technical compliance with established standards and usability. The acceptance criteria essentially revolves around demonstrating substantial equivalence to predicate devices and meeting relevant safety and performance standards.
Acceptance Criteria Category | Specific Criteria/Standard Adhered To | M5 Recorder Performance (Reported) |
---|---|---|
Safety & Essential Performance | ANSI AAMI ES60601-1:2005/(R)2012 and A1:2012 (Medical Electrical Equipment - Part 1: General requirements for basic safety and essential performance) | Compliance shown through design verification. |
Electromagnetic Compatibility (EMC) | IEC 60601-1-2 Edition 4.0 2014-02 (Medical Electrical Equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances - Requirements and tests) | Compliance shown through design verification. |
Usability | IEC 60601-1-6 Edition 3.1 2010-01 (Medical electrical equipment - part 1-6: General requirements for basic safety and essential performance – Collateral standard: Usability) and IEC/EN 62366-1 Edition 1.0 2015-02 (Medical devices Application of usability engineering to medical devices) | Successful in validating clinical and patient usability based on established usability goals and pass/fail criteria from 5 independent usability tests (U1-U5). |
Home Healthcare Environment | IEC 60601-1-11 Edition 2.0 2015-01 (Medical electrical equipment – part 1-6: General requirements for basic safety and essential performance - Collateral standard: Requirements for medical electrical equipment and medical electrical systems used in the home healthcare environment) | Compliance shown through design verification. |
Ambulatory ECG Systems Performance | IEC/EN 60601-2-47 Edition 2.0 2012-02 (Medical electrical equipment - Part 2-47: Particular requirements for the basic safety and essential performance of ambulatory electrocardiographic systems) | Compliance shown through design verification. |
Software Life Cycle Processes | IEC 62304:2006/A1:2016 (Medical device software Software life cycle processes) | Software verification and validation testing conducted; documentation provided. |
Risk Management | ISO 14971:2007-03-01 (Medical devices Application of risk management to medical devices) | Risk management process performed according to the standard. |
ECG Trunk Cables & Patient Leadwires | ANSI AAMI EC53:2013 | Compliance shown through design verification. |
Disposable ECG Electrodes | ANSI/AAMI EC12:2000/(R) 2015 | Compliance shown through design verification. |
Electrocardiograph Electrodes Special Controls | U.S. FDA Class II Special Controls Guidance Document: Electrocardiograph Electrodes (July, 2011) | Manufacturing follows recommendations of this guidance. |
Biocompatibility | ISO 10993: Biological Evaluation of Medical Devices, Part 5, 10, 12, and FDA GLP Regulations, 21 CFR Part 58 | Biocompatibility evaluation conducted in compliance. Case material (Valox 357U polycarbonate) has ISO 10993 certification. |
Mechanical Testing | IEC 60601-1 (various specific tests listed) | All listed tests successfully performed. |
Recording Duration | Sustained recording for up to 14 days (comparable to predicates, though M5 can run up to 21 days with electrode/battery changes). | Battery runs up to 19.9 days, rated down 20% to guarantee minimum of 14 days of recording throughout life. |
Frequency Response | Meets IEC 60601-2-47 requirement for >= 0.05-40Hz. | 0.05 Hz – 60Hz @ 200sps; 0.05 Hz – 100Hz @ 250sps; 0.05 Hz – 175 Hz @ 500sps (all meet or exceed requirement) |
Input Impedance | >10 Ohms (comparable to predicates) | >10 Ohms |
Resolution | Performance equivalent to IEC 60601-2-47 (comparable to predicates) | 16 bits (higher than predicates: 12 bits and 10 bits) |
2. Sample size used for the test set and the data provenance
The document states that no clinical studies were performed. The "test set" for the M5 Recorder primarily relates to usability testing and bench testing for compliance with standards.
- Usability Testing Test Set:
- Sample Size: 64 volunteer subjects.
- Data Provenance: Not explicitly stated regarding country of origin, but implied to be associated with Global Instrumentation LLC (Manlius, NY, USA), so likely U.S. based. The studies were prospective as they were conducted specifically for the M5 Recorder (May 7, 2019, through March 10, 2020).
- Bench Testing: No specific "sample size" of patients/data is applicable here, as these are technical performance tests on the device hardware and software.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Usability Testing: The document mentions "Clinical users participated in the U5 Usability Test. The clinical user group comprised a cross section of experience in using ambulatory ECG recorders and clinical positions representative of the intended M5 Recorder user base." It does not specify a precise number of experts or their exact qualifications (e.g., "radiologist with 10 years of experience"). However, the implication is that qualified healthcare professionals who would typically use such devices were involved. The ground truth here is successful interaction with the device and its components, as assessed by these clinical users and observation by Global Instrumentation LLC personnel.
- Bench Testing: For compliance with technical standards, the "ground truth" is adherence to the specifications of those standards. This is established through engineering and quality assurance processes, not by external experts adjudicating clinical outcomes.
4. Adjudication method for the test set
- Usability Testing: The text indicates that the usability testing was "implemented and overseen by Global Instrumentation LLC personnel." It states, "The testing was successful in validating the clinical and patient usability of the M5 System based on the usability goals and pass/fail criteria established in each study." This implies an internal adjudication process based on predefined criteria, rather than an expert consensus method like 2+1 or 3+1 that is common in clinical diagnostic accuracy studies.
- Bench Testing: Adjudication is internal, based on meeting the requirements of each standard.
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, an MRMC comparative effectiveness study was not done. The M5 Recorder is a data acquisition device (records ECG data) and does not perform any data processing or arrhythmia analysis. Therefore, there is no AI component in the device itself that would assist human readers, and such a study would not be applicable.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
No, a standalone algorithm performance study was not done. The M5 Recorder is explicitly stated to "acquire ECG data and does not perform any data processing or arrhythmia analysis of the ECG data." It is a hardware recorder, not an analytical algorithm.
7. The type of ground truth used
- For biocompatibility and mechanical testing, the ground truth is adherence to the specified international and national standards (e.g., ISO 10993, IEC 60601-1).
- For software validation, the ground truth is successful execution against specified requirements, as guided by FDA's guidance for software in medical devices and IEC 62304.
- For usability testing, the ground truth was the ability to meet "usability goals and pass/fail criteria established in each study," validated by participant interaction and observation by personnel.
8. The sample size for the training set
Not applicable. The M5 Recorder is a data acquisition device and does not contain artificial intelligence or machine learning algorithms that would require a "training set."
9. How the ground truth for the training set was established
Not applicable. As stated above, there is no training set for this device.
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