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510(k) Data Aggregation
(116 days)
The Microlife Wrist Watch Blood Pressure Monitor, Model BP3NU1-4X is a device intended to measure the systolic and diastolic blood pressure and pulse rate of an adult individual by using a non-invasive oscillometric technique in which an inflatable cuff is wrapped around the wrist.
The device detects the appearance of irregular heartbeat during measurement and gives a warning signal with the reading once the irregular heartbeat is detected.
The device can be used in connection with your personal computer (PC) running the Microlife Blood Pressure Analyzer (BPA) software. The memory data can be transferred to the PC by connecting the monitor via cable with the PC.
Microlife Wrist Watch Blood Pressure Monitor, Model BP3NU1-4X is designed to measure systolic and diastolic blood pressure and pulse rate of an individual by using a non-invasive technique in which an inflatable cuff is wrapped around the wrist. Our method to define systolic and diastolic pressure is similar to the auscultatory method but uses a capacitor pressure sensor rather than a stethoscope and mercury manometer. The sensor converts tiny alterations in cuff pressure to electrical signals, by analyzing those signals to define the systolic and diastolic blood pressure and calculating pulse rate, which is a well - known technique in the market called the "oscillometric method".
The device has Irregular Heartbeat Detection (IHD) function. It detects the appearance of irreqular heartbeat during measurement and the irreqular heart beat symbol " is displayed on the LCD screen if any irregular heart beat signal has been detected. In addition, the device can be used in connection with your personal computer (PC) running the Microlife Blood Pressure Analyzer (BPA) software. The memory data can be transferred to the PC by connecting the monitor with the PC via USB cable.
Here's an analysis of the provided text regarding the acceptance criteria and study for the Microlife Wrist Watch Blood Pressure Monitor, Model BP3NU1-4X.
Based on the provided document, the device did not undergo specific clinical testing for its overall accuracy and performance for this particular submission (K141083). Instead, the submission relies on the "substantial equivalence" principle to predicate devices. Therefore, direct acceptance criteria and study data for this specific model as if it were a novel device are not present in the given text.
The document claims that the device's measurement algorithm and program codes from a predicate device (BP3BS1-3C) remain unchanged, and therefore its performance in terms of blood pressure measurement would be identical. This means the clinical performance data would refer to those predicate devices, not the BP3NU1-4X directly.
However, I can extract information relevant to the type of testing and standards that would typically apply to such a device, and how the manufacturer justifies not conducting new clinical trials for this specific model.
Acceptance Criteria and Study for Microlife Wrist Watch Blood Pressure Monitor, Model BP3NU1-4X
Important Note: The provided document states that no new clinical testing was necessary for the Microlife Wrist Watch Blood Pressure Monitor, Model BP3NU1-4X because its fundamental scientific technology, measurement algorithm, and program codes are identical to a predicate device (Model BP3BS1-3C). Therefore, the "reported device performance" in the table below reflects the performance expected based on the predicate device, or general expectations for such devices, rather than new, specific performance data for Model BP3NU1-4X itself.
1. Table of Acceptance Criteria and the Reported Device Performance
Acceptance Criteria Category | Expected Performance (from relevant standards or predicate device) | Reported Device Performance (as justified in the submission) |
---|---|---|
Blood Pressure Measurement Accuracy | In accordance with ANSI/AAMI SP10: 2008 & AAMI / ANSI / IEC 80601-2-30:2009 for oscillometric blood pressure monitors (e.g., mean difference and standard deviation between device and reference measurements within specified limits). | Stated to be "identical with performance of the predicate device BP3BS1-3C" due to identical measurement algorithm and program codes. The predicate device would have demonstrated compliance with ANSI/AAMI SP10 standards. |
Pulse Rate Measurement Accuracy | As per relevant standards for oscillometric blood pressure monitors. | Expected to be identical to the predicate device BP3BS1-3C. |
Irregular Heartbeat Detection (IHD) | Ability to detect and provide a warning signal for irregular heartbeats. | Device "detects the appearance of irregular heartbeat during measurement and gives a warning signal with the reading once the irregular heartbeat is detected." |
Electrical Safety & EMC | Compliance with FDA November 1993 Draft "Reviewer Guidance for Premarket Notification Submissions", and relevant EMC standards. | "Met all relevant requirements of the aforementioned tests" (EMC Test was conducted). |
Mechanical & Environmental Performance | Withstanding specified storage, operating, vibration, drop, and life tests. | "Met all relevant requirements of the aforementioned tests" (Storage, Operating, Vibration, Drop, Life tests were conducted). |
Software Validation | Compliance with FDA November 2005 "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices" (moderate level of concern). | "Software validation was conducted in accordance with a moderate level of concern designation." |
2. Sample size used for the test set and the data provenance
- Clinical Performance Test Set: No new clinical test set was used for the BP3NU1-4X device itself, specifically for blood pressure measurement accuracy. The justification for substantial equivalence is based on the performance of a predicate device (BP3BS1-3C). The document does not specify the sample size or data provenance for the original clinical studies performed on the predicate device.
- Non-Clinical Testing: The non-clinical tests (reliability, EMC) were conducted on the BP3NU1-4X device. The sample sizes for these engineering tests are not specified but are typically sufficient to demonstrate compliance with the respective standards.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Not applicable for the BP3NU1-4X directly, as new clinical testing was not performed. For the predicate device, clinical validation (e.g., against ANSI/AAMI SP10) would typically involve qualified clinicians taking reference measurements (e.g., auscultatory readings by trained observers) to establish ground truth. The document does not provide details on these experts for the predicate testing.
4. Adjudication method for the test set
- Not applicable as new clinical testing was not performed for the BP3NU1-4X. In a typical clinical validation for a blood pressure monitor, multiple trained observers often take reference readings, and their agreement (or specific adjudication rules) would be used to establish the validated ground truth.
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 automated blood pressure monitor, not an AI-assisted diagnostic imaging device requiring human reader intervention.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Yes, implicitly. The blood pressure measurement algorithm operates autonomously without human intervention during measurement. The justification for substantial equivalence relies on the standalone performance of this algorithm, which remains "unchanged" from the predicate device. The accuracy testing required by standards like ANSI/AAMI SP10 is a standalone performance evaluation of the device's measurement capabilities against a reference standard.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- For the blood pressure accuracy (referencing the predicate device's clinical validation), the ground truth would typically be established by simultaneous auscultatory measurements performed by trained human observers using a mercury sphygmomanometer or another validated reference device, following standardized protocols (e.g., specified by ANSI/AAMI SP10).
- For non-clinical tests, ground truth is the specified engineering requirement or standard for the test (e.g., specific voltage levels for EMC, impact force for drop tests).
8. The sample size for the training set
- Not applicable. This device is likely using a fixed algorithm based on established oscillometric principles, not a machine learning model that requires a distinct "training set" in the conventional sense. The "training" or development of the algorithm would have occurred during the initial design of the oscillometric method, likely incorporating physiological models and experimental data, but this is not disclosed as a separate dataset in this submission.
9. How the ground truth for the training set was established
- Not applicable for the same reasons as (8). Any data used for the development of the oscillometric algorithm would have been associated with reference measurements (e.g., auscultatory) to optimize the algorithm's accuracy, but this is part of the fundamental technology development, not a separate "training set" for an AI model in this context.
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(74 days)
The Microlife Wrist Watch Blood Pressure Monitor, Model BP3BS1-3C is a device intended to measure the systolic and diastolic blood pressure and pulse rate of an adult individual by using a non-invasive oscillometric technique in which an inflatable cuff is wrapped around the wrist.
The device detects the appearance of irregular heartbeat during measurement and gives a warning signal with the reading once the irregular heartbeat is detected.
The device can be used in connection with your personal computer (PC) running the Microlife Blood Pressure Analyzer (BPA) software. The memory data can be transferred to the PC by connecting the monitor with the PC via USB cable.
Microlife Wrist Watch Blood Pressure Monitor, Model BP3BS1-3C is designed to measure systolic and diastolic blood pressure, pulse rate of an individual by using a non-invasive technique in which an inflatable cuff is wrapped around the wrist. Our method to define systolic and diastolic pressure is similar to the auscultatory method but uses an electronic pressure sensor rather than a stethoscope and mercury manometer. The sensor converts tiny alterations in cuff pressure to electrical signals, by analyzing those signals to define the systolic and diastolic blood pressure and calculating pulse rate, which is a well - known technique in the market called the "oscillometric method".
The device has an Irregular Heartbeat Detection (IHD) function. It detects the appearance of irregular heartbeat during measurement and the irregular heart beat symbol "is displayed on the LCD screen if any irreqular heart beat signal has been detected. In addition, the device can be used in connection with your personal computer (PC) running the Microlife Blood Pressure Analyzer (BPA) software. The memory data can be transferred to the PC by connecting the monitor with the PC via USB cable.
The device being reviewed is the Microlife Wrist Watch Blood Pressure Monitor, Model BP3BS1-3C.
Here's an analysis of the acceptance criteria and study information provided:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria | Reported Device Performance |
---|---|
Accuracy (Blood Pressure Measurement) | "The BP3BS1-3C met all relevant requirements of this standard [ANSI/AAMI SP10: 2008], as applicable to our modified device." |
"The measurement algorithm and its program codes of BP3BS1-3C remain unchanged." | |
"The fundamental scientific technology of the modified BP3BS1-3C device is the same as the predicate BP3MK1-3 (BP W100) device. Therefore the performance of the BP3BS1-3C in terms of blood pressure measurement would be identical with performance of the predicate BP3MK1-3 (BP W100) device." | |
Reliability Tests | "Microlife Wrist Watch Blood Pressure Monitor, Model BP3BS1-3C tested met all relevant requirements of the aforementioned tests." (Includes Storage, Operating, Vibration, Drop, Life tests) |
EMC Test | "Microlife Wrist Watch Blood Pressure Monitor, Model BP3BS1-3C tested met all relevant requirements of the aforementioned tests." |
Software Validation | "Software validation was conducted in accordance with a moderate level of concern designation in accordance with the FDA November 2005 document 'Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices'." |
"Adhered to the FDA September 1999 document 'Guidance for Off-The-Shelf Software Use in Medical Devices'." |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: Not explicitly stated for the clinical performance testing of the modified device.
- Data Provenance: The document states that the modified device (BP3BS1-3C) did not undergo new clinical testing because it is "identical" in technical aspects and measurement algorithm to the predicate device (BP3MK1-3). Therefore, the clinical performance data would be derived from the studies supporting the predicate device, but the specifics of those studies (e.g., country of origin, retrospective/prospective nature) are not provided in this document.
3. Number of Experts Used to Establish Ground Truth and Qualifications
- Not Applicable. No new clinical study was performed for the modified device to establish ground truth for blood pressure measurements. Clinical testing for blood pressure monitors typically involves comparison to a reference standard (e.g., sphygmomanometer measurements by trained observers), not expert consensus in the same way an imaging AI might.
4. Adjudication Method for the Test Set
- Not Applicable. As no new clinical test set was used for the modified device, there was no adjudication method described.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done
- No. This device is a standalone blood pressure monitor, not an AI-assisted diagnostic tool that would typically involve human readers. There is no mention of an MRMC study.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Yes, effectively. The performance of the device's blood pressure measurement algorithm is assessed against a standard (ANSI/AAMI SP10: 2008), which represents standalone performance. The document explicitly states that "the measurement algorithm and its program codes of BP3BS1-3C remain unchanged," implying its standalone performance maintains equivalence to the predicate device.
7. The Type of Ground Truth Used
- Reference Standard Measurements (for predicate device): For blood pressure monitors conforming to standards like ANSI/AAMI SP10, the ground truth for blood pressure measurements is established by trained observers using a reference standard method (e.g., auscultatory method with a mercury sphygmomanometer). While not detailed for this specific submission, it's inferred from the standard adherence.
8. The Sample Size for the Training Set
- Not Applicable / Not provided. Blood pressure monitors using the oscillometric method are based on established physiological principles and algorithms, rather than training a machine learning model on a "training set" in the conventional sense of AI. The algorithm for the device "remains unchanged" from its predicate, which indicates it's a fixed, established algorithm.
9. How the Ground Truth for the Training Set was Established
- Not Applicable / Not provided. As mentioned above, this isn't a machine learning device that requires a training set and corresponding ground truth in the same way an AI diagnostic algorithm would. The algorithm's development (for the predicate device) would have been based on physiological models and empirical data, but not a "training set" in the modern AI context.
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(17 days)
The Microlife Wrist Watch Blood Pressure Monitor, Model BP 3MK1-3 (BP W100) is a device intended to measure the systolic and diastolic blood pressure and pulse rate of an adult individual by using a non-invasive technique in which an inflatable cuff is wrapped around the wrist.
The device detects the appearance of irregular heartbeat during measurement, and gives a warning signal with the reading once the irregular heartbeat is detected.
Microlife Wrist Watch Blood Pressure Monitor, Model BP3MK1-3(BP W100) is designed to measure the systolic and diastolic blood pressure and pulse rate of an individual by using a non-invasive technique in which an inflatable cuff is wrapped around the wrist. Our method to define systolic and diastolic pressure is similar to the auscultatory method but uses an electronic capacitive pressure sensor rather than a stethoscope and mercury manometer. The sensor converts tiny alterations in cuff pressure to electrical signals, by analyzing those signals to define the systolic and diastolic blood pressure and calculating pulse rate, which is a well - known technique in the market called the "oscillometric method".
The device detects the appearance of irregular heartbeat during measurement and the irregular heart beat symbol " irregular heart beat signal has been detected.
Here's a summary of the acceptance criteria and study information for the Microlife Wrist Watch Blood Pressure Monitor, Model BP3MK1-3 (BP W100), based on the provided text:
Acceptance Criteria and Device Performance:
The document explicitly states that the device's performance is compared to its predicate device (BP3BU1) and other models (BP3BT0-AP) based on non-clinical and clinical testing. Crucially, the application for this model (BP3MK1-3) argues that no new clinical testing is required because the measurement algorithm and program codes are unchanged from the predicate device and the fundamental scientific technology is the same. Therefore, the device meets the acceptance criteria by being demonstrated as equivalent to an already cleared device that met the ANSI/AAMI SP10-2002 standard.
Acceptance Criteria (Met by Predicate Device) | Reported Device Performance |
---|---|
ANSI/AAMI SP10-2002 "National Standard for Manual, Electronic or Automated Sphygmomanometers" (All relevant sections addressed and tested for predicate) | Clinical performance remains unchanged from predicate device BP3BU1. (No new clinical data presented for this specific device model due to equivalence claim). |
Electrical, Mechanical, and Environmental Performance Requirements (FDA November 1993 Draft "Reviewer Guidance for Premarket Notification Submissions") | Device (BP3MK1-3) met all relevant requirements of: Reliability Tests (Storage, Operating, Vibration, Drop, Life) and EMC Test. |
Equivalence to Predicate Device (BP3BU1) in terms of safety and effectiveness | Demonstrated no difference between BP3MK1-3 and BP3BU1 based on non-clinical test results. |
Study Details:
Since the submission claims substantial equivalence to a predicate device (BP3BU1) and states that "anther clinical test for the modified device, BP3MK1-3(BP W100) is not required" due to unchanged algorithms and technology, the following details pertain to the implication of that claim rather than direct studies for this specific device model. The document does not provide details of the original clinical study for the predicate device BP3BU1 beyond mentioning compliance with ANSI/AAMI SP10-2002.
-
Sample size used for the test set and the data provenance:
- Test Set Sample Size: Not explicitly stated for either non-clinical (reliability, EMC) or clinical (from predicate) tests.
- Data Provenance: Not specified for the predicate device's clinical testing. The non-clinical tests (reliability, EMC) for the BP3MK1-3 were conducted by the manufacturer.
-
Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- This information is not provided for the predicate device's clinical testing, nor is it relevant for the non-clinical tests conducted for the BP3MK1-3.
-
Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- Not provided for the predicate device's clinical testing.
-
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 is a blood pressure monitor, not an AI-assisted diagnostic imaging device for human readers.
-
If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- The core functionality of the device is to measure blood pressure using an oscillometric method, which is an algorithm-only measurement. The document states the "measurement algorithm and the program codes of the BP3MK1-3(BP W100) remain unchanged." This implies standalone performance was measured for the predicate and is assumed for this device. Specific performance metrics (accuracy, precision) are not detailed but are implied to meet the ANSI/AAMI SP10-2002 standard.
-
The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- For blood pressure monitors seeking compliance with standards like ANSI/AAMI SP10, the "ground truth" typically involves simultaneous measurements by trained observers using a mercury sphygmomanometer (auscultatory method), often double-blinded, which serves as the "reference method." This would have been the case for the predicate device's clinical testing.
-
The sample size for the training set:
- Not applicable as this is not an AI/machine learning device that uses a "training set" in the conventional sense. The "training" of the device refers to its design and calibration based on known physiological principles and validated algorithms.
-
How the ground truth for the training set was established:
- Not applicable (see point 7).
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(24 days)
The Microlife Wrist Watch Blood Pressure Monitor, Model BP3BU1-4U is a device intended to measure the systolic and diastolic blood pressure and pulse rate of an adult individual by using a technique in which an inflatable cuff is wrapped around the wrist.
The device can be used in connection with your personal computer (PC) running the Microlife Blood Pressure Analyzer (BPA) software. The memory data can be transferred to the PC by connecting the monitor via cable with the PC.
The Microlife Wrist Watch Blood Pressure Monitor, Model BP3BU1-4U is designed to measure the systolic and diastolic blood pressure and pulse rate of an individual by using a technique in which an inflatable cuff is wrapped around the wrist. Our method to define systolic and diastolic pressures is similar to the auscultatory method but uses an electronic semiconductor pressure sensor rather than stethoscope and mercury manometer. The sensor converts tiny alteration in cuff pressure to electrical signals; by analyzing those signals to define the systolic, diastolic and calculating pulse rate is a well known technique in the market called the "oscillometric method". The device can be used in connection with your personal computer (PC) running the Microlife Blood Pressure Analyzer (BPA) software. The memory data can be transferred to the PC by connecting the monitor via cable with the PC.
The provided text describes a 510(k) premarket notification for a blood pressure monitor and does not contain detailed information about acceptance criteria or specific study results that would typically be associated with AI/ML-based medical devices or comparative effectiveness studies. The document primarily focuses on demonstrating substantial equivalence to a predicate device based on non-clinical and some clinical aspects, but not in the way an AI-based device's performance would be evaluated.
However, based on the information provided, here's an attempt to extract and infer relevant details:
1. Table of Acceptance Criteria and Reported Device Performance:
The document refers to the ANSI/AAMI SP10-2002 National Standard for Manual, Electronic or Automated Sphygmomanometers. This standard would define the acceptance criteria for blood pressure measurement accuracy. While the specific numerical criteria are not detailed in the provided text, typically these standards involve criteria for mean difference and standard deviation between the test device and a reference measurement.
Acceptance Criteria (Inferred from ANSI/AAMI SP10-2002) | Reported Device Performance |
---|---|
Mean difference between device and reference for systolic blood pressure (SBP) ≤ 5 mmHg | "BP3BU1-4U met all relevant requirements of this standard, as applicable to our modified device." (No specific numerical performance reported) |
Standard deviation of difference between device and reference for SBP ≤ 8 mmHg | "BP3BU1-4U met all relevant requirements of this standard, as applicable to our modified device." (No specific numerical performance reported) |
Mean difference between device and reference for diastolic blood pressure (DBP) ≤ 5 mmHg | "BP3BU1-4U met all relevant requirements of this standard, as applicable to our modified device." (No specific numerical performance reported) |
Standard deviation of difference between device and reference for DBP ≤ 8 mmHg | "BP3BU1-4U met all relevant requirements of this standard, as applicable to our modified device." (No specific numerical performance reported) |
Important Note: The document states, "Repeat testing was not performed for the modified device, as clinical testing results were not affected by the changes to the modified device." This means the performance data provided is for the predicate device (BP3BU1-5), not the new device (BP3BU1-4U), and the assumption is that the modification (addition of PC-link function) did not impact the clinical performance related to blood pressure measurement accuracy.
2. Sample Size Used for the Test Set and Data Provenance:
- Test Set Sample Size: Not explicitly stated for the clinical evaluation. The document only mentions that the predicate device (Microlife Wrist Watch Blood Pressure Monitor, Model BP3BU1-5) underwent testing according to ANSI/AAMI SP10-2002. Standards like ANSI/AAMI SP10 typically require a minimum number of subjects (e.g., 85 subjects for validation).
- Data Provenance: Not specified (e.g., country of origin). The study for the predicate device would have been prospective to adhere to the ANSI/AAMI standard.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Their Qualifications:
- Number of Experts: Not explicitly stated. The ANSI/AAMI SP10 standard for blood pressure monitor validation typically requires at least two independent trained observers to perform auscultatory reference measurements.
- Qualifications of Experts: Not specified in the document, but for compliance with ANSI/AAMI SP10, these would be clinical professionals (e.g., physicians, nurses, or trained technicians) who are proficient in auscultatory blood pressure measurement.
4. Adjudication Method for the Test Set:
- Adjudication Method: Not explicitly detailed. For ANSI/AAMI SP10, if multiple observers are used, their readings are compared, and specific protocols are followed to handle discrepancies (e.g., averaging their readings if within a certain threshold, or rereading if outside the threshold). This isn't a typical "adjudication" in the sense of consensus for image interpretation, but rather a methodology for obtaining a reliable reference measurement.
5. Multi Reader Multi Case (MRMC) Comparative Effectiveness Study:
- No MRMC study was done. This device is a standalone blood pressure monitor, not an AI-assisted diagnostic tool that would typically involve human readers interpreting cases. Therefore, the concept of a human reader improving with AI vs. without AI assistance is not applicable here.
6. Standalone Performance Study:
- Yes, a standalone performance study was done for the predicate device. The clinical testing according to ANSI/AAMI SP10-2002 is a standalone performance study of the device's accuracy in measuring blood pressure compared to a reference standard. The document states, "The BP3BU1-4U met all relevant requirements of this standard, as applicable to our modified device," indicating that the predicate device's standalone performance satisfied the standard.
7. Type of Ground Truth Used:
- Expert Consensus of Auscultatory Measurements. For blood pressure monitors, the ground truth (reference method) is typically obtained through skilled clinical professionals performing auscultatory measurements using a mercury sphygmomanometer (or an appropriately validated non-mercury reference device) simultaneously or sequentially with the test device, following standardized protocols outlined in ANSI/AAMI SP10.
8. Sample Size for the Training Set:
- Not Applicable / Not Provided. This device uses the "oscillometric method," which is a well-known technique. While it involves a software algorithm, the document does not suggest an AI/ML model that requires a "training set" in the modern sense (i.e., for supervised learning with data-driven model training). The algorithm is described as a "well known technique," implying a predetermined, fixed algorithm rather than one developed through machine learning.
9. How the Ground Truth for the Training Set Was Established:
- Not Applicable. As explained above, there's no indication of a machine learning "training set" in the conventional sense for this device. The algorithm likely relies on established physiological principles and signal processing techniques for oscillometric blood pressure determination.
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(26 days)
The Microlife Wrist Watch Blood Pressure Monitor, Model BP3AX1-4U with semiconductor pressure sensor is a device intended to measure the systolic and diastolic blood pressure and pulse rate of an adult individual by using a technique in which an inflatable cuff is wrapped around the wrist.
The device can be used in connection with your personal computer (PC) running the Microlife Blood Pressure Analyzer (BPA) software. The memory data can be transferred to the PC by connecting the monitor via cable with the PC.
The Microlife Wrist Watch Blood Pressure Monitor, Model BP3AX1-4U is designed to measure the systolic and diastolic blood pressure and pulse rate of an individual by using a technique in which an inflatable cuff is wrapped around the wrist. Our method to define systolic and diastolic pressures is similar to the auscultatory method but uses an electronic semiconductor pressure sensor rather than stethoscope and mercury manometer. The sensor converts tiny alteration in cuff pressure to electrical signals; by analyzing those signals to define the systolic, diastolic and calculating pulse rate is a well known technique in the market called the "oscillometric method". The device can be used in connection with your personal computer (PC) running the Microlife Blood Pressure Analyzer (BPA) software. The memory data can be transferred to the PC by connecting the monitor via cable with the PC.
The provided 510(k) summary for the Microlife Wrist Watch Blood Pressure Monitor, Model BP3AX1-4U, focuses on demonstrating substantial equivalence to a predicate device (Microlife Wrist Watch Blood Pressure Monitor, Model BP3AX1, K#040002) rather than presenting a standalone study with detailed acceptance criteria and performance metrics for the modified device. The key takeaway is that the clinical performance of the modified device is addressed by relying on the predicate device's compliance with the ANSI/AAMI SP10-2002 standard.
Here's an attempt to extract and synthesize the requested information based on the provided text, noting where information is not explicitly available for the modified device's clinical performance:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria | Reported Device Performance (Reference) |
---|---|
Compliance with ANSI/AAMI SP10-2002 "National Standard for Manual, Electronic or Automated Sphygmomanometers" for determining systolic and diastolic blood pressure and pulse rate (specifically, "All relevant sections were addressed and testing conducted"). | The predicate device (Microlife Wrist Watch Blood Pressure Monitor, Model BP3AX1) met all relevant requirements of this standard. The modified device (BP3AX1-4U) is stated to also meet these requirements as clinical testing results were not affected by the changes to the modified device (which was the addition of a PC-link function). |
Electrical, Mechanical and Environmental Performance Requirements (as outlined in FDA November 1993 Draft "Reviewer Guidance for Premarket Notification Submissions", DCRND). | The Microlife Wrist Watch Automatic Blood Pressure Monitor, Model BP3AX1-4U met all relevant requirements of the conducted tests (Reliability Tests - Storage, Operating, Vibration, Drop, Life; EMC Test; PC-link software BPA Test). |
Note: The document explicitly states: "Repeat testing was not performed for the modified device, as clinical testing results were not affected by the changes to the modified device." This means the reported clinical performance refers to the predicate device's performance against the ANSI/AAMI SP10-2002 standard. Specific numerical performance metrics (e.g., mean difference, standard deviation) for blood pressure accuracy as per the AAMI standard are not provided in this summary for either the predicate or the modified device.
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size for Clinical Performance (Predicate Device): Not explicitly stated in the provided text for the clinical study that proved compliance with ANSI/AAMI SP10-2002.
- Data Provenance: Not explicitly stated for any clinical study. The summary focuses on non-clinical and technical tests for the modified device, and refers to clinical testing performed on the predicate device.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Their Qualifications
- For Clinical Performance (Predicate Device): Not specified in the provided text. The ANSI/AAMI SP10 standard typically involves comparison against mercury sphygmomanometry performed by trained observers, but the number and qualifications of these observers are not detailed here.
- For Non-Clinical Tests (Modified Device): No experts were involved in establishing ground truth for the non-clinical and technical tests (reliability, EMC, PC-link software).
4. Adjudication Method for the Test Set
- For Clinical Performance (Predicate Device): Not specified. Standard practice for AAMI SP10 validation involves specific procedures for comparing automated readings against auscultatory readings, often involving multiple observers, but the adjudication method (e.g., 2+1, 3+1) is not explicitly detailed.
- For Non-Clinical Tests (Modified Device): Not applicable. These tests are objective pass/fail based on engineering specifications.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, and the effect size of how much human readers improve with AI vs without AI assistance
- No such study was performed. This type of study is not relevant to a blood pressure monitor, which is a standalone measurement device, not an AI-assisted diagnostic tool for interpretation by human readers.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Yes, in essence. The blood pressure monitor itself is a standalone device that provides measurements via its internal algorithm. The "oscillometric method" is an algorithm. The clinical testing of the predicate device against the ANSI/AAMI SP10-2002 standard essentially represents a standalone performance evaluation of the device's algorithm against a recognized standard reference method (auscultatory measurement).
7. The Type of Ground Truth Used
- For Clinical Performance (Predicate Device): The ground truth for blood pressure measurement against the ANSI/AAMI SP10-2002 standard would typically be auscultatory blood pressure measurements performed by trained observers using mercury sphygmomanometers. This is generally considered an "expert consensus" or "reference standard" method in this context.
- For Non-Clinical Tests (Modified Device): The ground truths were engineering specifications and functional requirements (e.g., successful data transfer for PC-link).
8. The Sample Size for the Training Set
- Not applicable / Not specified. The device uses the "oscillometric method," which is a well-known, established algorithm, not typically "trained" in the sense of modern machine learning models with large datasets. If there were any algorithmic refinements based on data, the size of that data is not mentioned in the summary.
9. How the Ground Truth for the Training Set Was Established
- Not applicable / Not specified. As noted above, the "oscillometric method" is a long-established technique. The summary does not describe a machine learning training process.
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(80 days)
The Microlife Wrist Watch Blood Pressure Monitor, Model BP3AX1 is a device intended to measure the systolic and diastolic blood pressure and pulse rate of an adult individual by using a non-invasive technique in which an inflatable cuff is wrapped around the wrist.
The Microlife Wrist Watch Blood Pressure Monitor BP3AX1 is designed to measure the systolic, diastolic and pulse rate of an individual by using a non-invasive technique with an inflatable cuff wrapped around wrist. Our method to define systolic and diastolic pressure is similar to the auscultatory method but uses an electronic semiconductor pressure sensor instead of a stethoscope and uses an electronic convention to define the systolic, diastolic and electrical signals, by analyzing those signals. The method for calculating pulse rate is a well known technique in the market and is the so called "oscillometric method".
The provided text describes the Microlife Blood Pressure Monitor Model BP3AX1 and its 510(k) submission. However, it does not contain a detailed table of acceptance criteria, reported device performance metrics, or a comprehensive study report with the specific information requested in your prompt (e.g., sample sizes for test/training sets, ground truth establishment details, MRMC study results, etc.).
The document primarily focuses on demonstrating substantial equivalence to a predicate device (Microlife Wrist Watch Automatic Blood Pressure Monitor, Model BP-3BU1-5, K# 021305) and lists the non-clinical and clinical tests performed at a high level.
Here's what can be extracted and what is missing based on your request:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (from standard) | Reported Device Performance (from study) |
---|---|
Clinical Performance: Per ANSI/AAMI SP10-1992 "National Standard for Electronic or Automated Sphygmomanometers" | "All relevant sections were met" (for the clinical standard) |
Non-Clinical Performance: | |
- General Functions Test: (Met, implies compliance) | |
- Reliability Test Operation Conditions: (Met, implies compliance) | |
- Reliability Test Drop Testing: (Met, implies compliance) | |
- Reliability Test Storage: (Met, implies compliance) | |
- Reliability Test Vibrating Testing: (Met, implies compliance) | |
- EMC Test: (Met, implies compliance) | |
- IEC 60601-1 Safety Test: (Met, implies compliance) |
Missing Information: The document states that the device "met all relevant requirements" of AAMI SP10-1992. However, it does not provide the specific numerical acceptance criteria (e.g., mean difference, standard deviation limits) or the actual measured performance data (e.g., 2.3 mmHg ± 5.6 mmHg) from the clinical study. Similarly, for non-clinical tests, it only states "None of the testing demonstrated any design characteristics that violated the requirements" and "the relevant requirements...were met," without providing specific pass/fail criteria or quantitative results.
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Sample Size for Test Set: Not specified. The document mentions that ANSI/AAMI SP10-1992 testing was performed, but does not provide the number of subjects or measurements included in this clinical validation.
- Data Provenance: Not specified. The document does not mention the country of origin of the data or whether the study was retrospective or prospective. Given the nature of a clinical validation study for a blood pressure monitor, it would typically be prospective.
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)
Not applicable/Not specified. For a blood pressure monitor, "ground truth" during clinical validation is typically established by trained human observers using a mercury sphygmomanometer simultaneously or sequentially with the automated device on the same subject, following a standardized protocol like AAMI SP10. The document does not specify the number or qualifications of these human observers.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not specified. The document does not describe any specific adjudication method for discrepancies during the clinical testing. For AAMI SP10, there are specific requirements for agreement between observers, but the details of implementation are not provided here.
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 automated blood pressure monitor, not an AI-assisted diagnostic tool that would typically involve "human readers" or "AI assistance" in the sense of image interpretation or complex clinical decision support. Therefore, an MRMC study and effect size for human readers improving with AI are not relevant to this type of device.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Yes, effectively. The "standalone" performance here refers to the device's ability to accurately measure blood pressure on its own. The clinical testing against the ANSI/AAMI SP10-1992 standard is a standalone performance evaluation of the automated device against a reference standard (typically a trained human observer using a mercury sphygmomanometer). The results state that "All relevant sections were met," indicating its standalone performance was deemed acceptable.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
The ground truth for the clinical study would have been established by trained human observers using a reference standard (e.g., auscultation with a mercury sphygmomanometer), as prescribed by the ANSI/AAMI SP10-1992 standard. This is the accepted method for validating automated blood pressure devices.
8. The sample size for the training set
Not applicable/Not specified. This is an oscillometric blood pressure monitor, not a machine learning or AI-based device that typically requires a distinct "training set" in the context of model development. The algorithm for oscillometric measurement is well-established, and its "training" would be more akin to calibration and design refinement rather than statistical model training. If any internal data was used for initial algorithm development or parameter tuning, it is not disclosed as a "training set" here.
9. How the ground truth for the training set was established
Not applicable/Not specified. As mentioned above, a "training set" in the context of machine learning is not directly applicable here. The fundamental principles of oscillometric measurement are physics-based, and calibration procedures would rely on traceable pressure standards, not "ground truth" derived from clinical data in the same way an AI model's training data would be established.
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