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510(k) Data Aggregation

    K Number
    K970902
    Device Name
    MEDILOG FD4
    Date Cleared
    1997-05-05

    (55 days)

    Product Code
    Regulation Number
    870.2800
    Reference & Predicate Devices
    N/A
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Medilog FD4 Hoher monitor is intended to be used in the diagnosis of various cardiac disorders by the recording of ECG in an ambulatory mode. These disorders principally include cardiac arrhythmia's and myocardial ischeamia.

    The ECG data is used by the physician as an aid in the diagnosis of the patients condition. In some circumstances the patient may be hospitalised as part of the medical evaluation and Holter monitoring may be performed in conjunction with other non-invasive or invasive procedures. In such cases there is no interaction between the FD4 and other equipment.

    Device Description

    Decer poton it looks like an MR63. The difference being the analogue cassette mechanism has been replaced with a digital acquisition module containing a slot for a PCMCIA Flash ATA card.

    The patient is connected to the FD4 via disposable electrodes attached to the chest. These detect the electrical signals generated by the heart, which are then transferred to the recorder via the electrode leads and patient cable. In the recorder, these signals are amplified, filtered, digitised and compressed without loss before being stored on a removable PCMCIA Flash ATA card. At the completion of recording the flash memory card is removed and the recorded ECG data is replayed and analysed on the Oxford Instruments ECG Analysis System.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and the study proving the device meets them, based on the provided text:

    Acceptance Criteria and Device Performance

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria CategorySpecific CriteriaReported Device Performance (FD4)
    Performance Bench TestsInput dynamic range meets American National Standard EC38 requirements.FD4 meets all requirements of American National Standard EC38.
    Gain accuracy meets American National Standard EC38 requirements.FD4 meets all requirements of American National Standard EC38.
    System noise meets American National Standard EC38 requirements.FD4 meets all requirements of American National Standard EC38.
    Multichannel crosstalk meets American National Standard EC38 requirements.FD4 meets all requirements of American National Standard EC38.
    Frequency response meets American National Standard EC38 requirements.FD4 meets all requirements of American National Standard EC38.
    Minimum feature size meets American National Standard EC38 requirements.FD4 meets all requirements of American National Standard EC38.
    Meets draft British Standard Electrical Equipment - part 2: Particular requirements for safety - section 2.47: specification for ambulatory electrocardiographic monitors.FD4 meets all requirements of the draft British Standard.
    Trial PerformanceRecording lasted for its intended duration.All recordings (29 total) met this criterion.
    Patient events detected.All recordings (29 total) met this criterion.
    Signal quality and gain comparable with the predicate device (Medilog MR63), where applicable.All recordings (29 total) met this criterion.
    No problems with either the recording or the replay.All recordings (29 total) met this criterion.
    Successful review by Oxford Instruments clinical specialist.All recordings (29 total) met this criterion.
    Technical SpecificationsImproved, updated standards including EC38 performance (compared to MR63).FD4 complies with IEC 601-1, UL 2601-1, AAMI EC38, 93/42/EEC (MDD). The MR63 complied with older standards (IEC 601-1, UL 544, 93/42/EEC).
    Improved operating range (temperature).FD4: 0 °C to 45 °C (compared to MR63: 5 °C to 40 °C).
    Improved frequency response (due to digital recording).FD4: 0.05Hz - 40 Hz (compared to MR63: 0.5Hz - 25Hz).
    Lower typical peak-to-peak noise over input bandwidth.FD4: <12 μV (compared to MR63: <50 μV).
    Higher resolution patient event timing.FD4: 1/128th sec (compared to MR63: 1 second).
    Improved dynamic range.FD4: 10 μV to 10 mV (compared to MR63: 50 μV to 10 mV).
    Provides patient isolation by virtue of plastic optical fiber.FD4: Automatically provided by plastic fibre optic cable (compared to MR63: XE-45 write-coupler).

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

    • Sample Size: A total of 29 recordings. 17 of these were performed in tandem with the predicate device (MR63).
    • Data Provenance: The data came from a variety of sources:
      • A programmable simulator (giving "researchiseble" EKGs - likely representative samples)
      • An EKG generator (providing real patient data from a database of recordings - likely retrospective, but no specific country of origin is mentioned)
      • Human volunteers (prospective data, but no specific country of origin is mentioned)

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

    • Number of Experts: The document states "Successful review by Oxford Instruments clinical specialist." This implies at least one clinical specialist was involved.
    • Qualifications of Experts: The qualification provided is "clinical specialist" at Oxford Instruments. Further specifics (e.g., years of experience, specific medical specialty like cardiology or electrophysiology) are not provided.

    4. Adjudication Method for the Test Set

    • The document mentions "Successful review by Oxford Instruments clinical specialist." This suggests a single expert review. There is no indication of an adjudication method involving multiple experts (e.g., 2+1, 3+1). It appears to be a single-reader review based on the stated acceptance criterion.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

    • No, an MRMC comparative effectiveness study was not done in the context of human readers improving with AI vs. without AI assistance.
    • The study compared the FD4 device's performance to its predicate device (MR63), but this was a technical/signal comparison, not a human reader performance study. The FD4 is a data acquisition device, not an AI interpretation system.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

    • This device (Medilog FD4) is a Holter monitor designed for recording ECGs, not for automated interpretation or diagnosis. It records and stores data for later analysis by a physician using a separate "Oxford Instruments ECG Analysis System" (Medilog Optima & Excel 2).
    • Therefore, the concept of "standalone algorithm performance" as typically applied to AI-based diagnostic devices does not directly apply to the FD4. The performance testing focuses on the quality of the recorded signal and its comparability to the predicate device.

    7. The Type of Ground Truth Used

    • The ground truth for the trial results was based on several metrics:
      • Technical/Operational Criteria: Intended recording duration, successful download, signal quality/gain comparability with predicate, absence of recording/replay problems.
      • Clinical Relevance: Detection of patient events, heart rate variability monitored and logged for comparison.
      • Expert Review: Successful review by an Oxford Instruments clinical specialist.
    • Given the nature of the device (a recorder), the "ground truth" is less about a definitive medical diagnosis and more about the fidelity and completeness of the ECG data captured and reviewed by an expert. It's a combination of objective technical performance and subjective expert assessment of data utility.

    8. The Sample Size for the Training Set

    • The document does not mention a training set for the FD4 device. This is because the FD4 is a hardware device for acquiring data, not a machine learning algorithm that requires training. The "Medilog Optima & Excel 2" analysis system might potentially incorporate algorithms, but the FD4 itself is a data acquisition unit.

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

    • As no training set is mentioned for the FD4 device, this question is not applicable.
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