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510(k) Data Aggregation

    K Number
    K211294
    Date Cleared
    2021-08-16

    (110 days)

    Product Code
    Regulation Number
    870.2900
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Multi-Link X2 ECG Cable and Leadwire System

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

    The Multi-Link X2 ECG Cable and Leadwire System is intended to transmit ECG signals from patient electrodes to patient monitors for monitoring purposes. The Multi-Link Cable and Lead Wire System is limited to indications for use of the connected monitoring equipment. The Multi-Link trunk cables) are reusable, nonsterile and can be reprocessed.

    Device Description

    The Multi-Link™ X2 ECG Cable and Leadwire System is a product portfolio that is intended to transmit signals from patient electrodes to various electrocardiograph recorders / monitors for monitoring purposes. The system consists of Reusable Trunk Cables (K980582, K101660, K162432), Reusable Leadwires (K980582) and Disposable Single Patient Use Leadwires (K101660, K162432). The existing portfolio is compatible with the following ECG monitoring platforms: Philips, Mindray, Nihon Kohden, GE, and Spacelabs. The subject device of this pre-market notification consists of a modified set of Reusable Trunk Cables that are designed to be compatible with the following cardiac defibrillation systems: Physio Control Lifepak, Zoll R, and Zoll X monitoring platforms. The subject device is used to transmit signals from patient electrodes and sensors to support continuous ECG monitoring only. The subject device does not interpret or deliver the shock applied when the defibrillators are in use.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for the "Multi-Link X2 ECG Cable and Leadwire System." This submission is to introduce a modified set of reusable trunk cables to expand system compatibility with additional FDA-cleared ECG monitoring platforms. The document outlines the device's intended use, indications for use, and a comparison to a predicate device (K162432).

    Crucially, this document is for a medical device that transmits ECG signals from electrodes to monitors, i.e., it's a cable system. It is not an AI/algorithm-based diagnostic device. Therefore, the concepts of "acceptance criteria" and a "study that proves the device meets the acceptance criteria" in the context of AI/algorithm performance (e.g., accuracy, sensitivity, specificity, expert ground truth, MRMC studies) are not applicable to this submission.

    Instead, the acceptance criteria for this device are related to its electrical and mechanical performance, and its ability to properly and safely transmit signals without interference or degradation. The "study" proving it meets these criteria is a series of non-clinical performance tests against established industry standards.

    Here's how to interpret the information provided in the context of the requested questions, noting where the requested information is not applicable:


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

    For a cable system, acceptance criteria are typically defined by performance standards. The reported performance is "Pass" for all tests, indicating it met the criteria defined by the applicable standards.

    Acceptance Criterion (Test Performed)Applicable StandardReported Device Performance
    Compatibility Testing with Zoll R, Zoll X and Physio Control SystemsANSI AAMI IEC 60601-2-27:2011(R)2016Pass
    Connector mating/unmating, Retention force and Contact Resistance for Instrument ConnectorsANSI AAMI EC53:2013Pass
    Connector mating/unmating, Retention force and Contact Resistance for Multilink Cable YokesANSI AAMI EC53:2013Pass
    Inspection of Air ClearanceANSI AAMI ES60601-1:2005/(R)2012 and A1:2012, C1:2009/(R)2012 and A2:2010/(R)2012 (Consolidated Text); ANSI AAMI IEC 60601-2-27:2011(R)2016Pass
    Cable Noise TestingANSI AAMI EC53:2013Pass
    Flex Life TestingANSI AAMI EC53:2013Pass
    Tensile Strength TestingANSI AAMI EC53:2013Pass
    Defibrillation Protection and Energy ReductionANSI AAMI ES60601-1:2005/(R)2012 and A1:2012, C1:2009/(R)2012 and A2:2010/(R)2012 (Consolidated Text); ANSI AAMI IEC 60601-2-27:2011(R)2016Pass
    Dielectric Withstand TestingANSI AAMI ES60601-1:2005/(R)2012 and A1:2012, C1:2009/(R)2012 and A2:2010/(R)2012 (Consolidated Text)Pass
    Leakage Current TestingANSI AAMI ES60601-1:2005/(R)2012 and A1:2012, C1:2009/(R)2012 and A2:2010/(R)2012 (Consolidated Text)Pass
    Storage Conditioning and Drop TestANSI AAMI ES60601-1:2005/(R)2012 and A1:2012, C1:2009/(R)2012 and A2:2010/(R)2012 (Consolidated Text)Pass
    Material Resistance for Cleaning and Disinfection StressANSI AAMI ES60601-1:2005/(R)2012 and A1:2012, C1:2009/(R)2012 and A2:2010/(R)2012 (Consolidated Text); ANSI AAMI EC53:2013Pass
    Resistance from electrosurgery interferenceANSI AAMI IEC 60601-2-27:2011(R)2016Pass
    Shock, Vibration and IP ClassificationIEC 60601-1-12:2014+AMD1:2020; IEC 60529:1989+A1:1999+A2:2013; IEC 60068-2-27:2008; IEC 60068-2-64:2008+AMD1:2019Pass

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

    • Sample size: Not explicitly stated in terms of number of cables tested, but the tests were performed on representative samples to demonstrate compliance with standards. For physical devices, sample sizes are typically determined by statistical methods or engineering judgment to ensure sufficient confidence in product safety and performance.
    • Data Provenance: The testing is non-clinical performance testing of the device itself (a cable system), not data from patient studies. Therefore, concepts like "country of origin of the data" or "retrospective/prospective" do not apply. The tests were performed in a lab setting to relevant international and national standards.

    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. This is a hardware device (cable system) for signal transmission, not an AI/algorithm. "Ground truth" in the context of expert review of images or data is not relevant here. The ground truth for cable performance is defined by the technical specifications and standards (e.g., voltage, resistance, signal integrity, mechanical strength).

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

    • Not Applicable. As explained above, this device does not involve human interpretation or subjective assessment of data for "ground truth" adjudication. The tests involve objective quantitative measurements against defined thresholds in relevant standards.

    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 is not an AI-assisted diagnostic device. MRMC studies are used to evaluate diagnostic accuracy and reader performance of AI systems.

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

    • Not Applicable. This is a physical cable system, not an algorithm.

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

    • The "ground truth" for this device's performance is established by international and national engineering and medical device standards (e.g., ANSI AAMI IEC 60601 series, ANSI AAMI EC53, IEC 60068 series, IEC 60529). These standards define the acceptable performance characteristics for ECG cables, including electrical properties, mechanical durability, and safety features like defibrillation protection. The device's performance is measured against the thresholds and methodologies specified in these standards.

    8. The sample size for the training set

    • Not Applicable. This device does not use a "training set" as it is not an AI/machine learning algorithm.

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

    • Not Applicable. As above, no training set is used.

    In summary, the document details the non-clinical performance testing of an ECG cable and leadwire system to demonstrate its substantial equivalence to a predicate device. The "acceptance criteria" are embodied by the various ANSI, AAMI, and IEC standards listed, and the "study" proving compliance is a series of laboratory tests where the device passed all criteria. The questions related to AI/algorithm development, such as "expert ground truth," "MRMC studies," and "training/test sets," are not relevant to this specific medical device submission.

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