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510(k) Data Aggregation

    K Number
    K180479
    Device Name
    ReDS System
    Date Cleared
    2019-02-28

    (371 days)

    Product Code
    Regulation Number
    870.2770
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    ReDS System

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

    The ReDS System is intended for use by qualified healthcare practitioners, under the direction of a physician, in hospitals, hospital-type facilities and home environments, for the non-invasive monitoring and management of patients with fluid management problems in a variety of medically accepted clinical applications. The ReDS System is indicated for patients:

    • With fluid management problems
    • Taking diuretic medication
    • Living with heart failure
    • Recovering from a coronary artery disease-related event
    Device Description

    The ReDS System ("ReDS" or "ReDS System") is a non-invasive thoracic base wave impedance monitor that provides measurement of patient lung fluid content. ReDS™ technology measures wave impedance of biological tissues. Low power electromagnetic (EM) signals are emitted into the body, and intercepted by sensors on the body. The wave impedance is a function of the distributed tissue conductivity and capacitance properties, and is representative of tissue fluid content.

    The system consists of a Sensor Unit connected to a bedside console, as well as a cloud application. The Sensor Unit encases two sensors and an attachment mechanism. The Bedside Console is an enclosure housing the electronic modules, an embedded computer and a touch-screen display. The device software provides the management of the device as well as analysis of the measured signals, graphic display of readings, reporting, and communications functionality to enable remote patient monitoring.

    AI/ML Overview

    The provided document is a 510(k) summary for the ReDS System V2.7, seeking substantial equivalence to a predicate device, the ReDS Wearable System V2.6. As such, the study described focuses on demonstrating that the new device (V2.7) performs equivalently to the existing cleared device (V2.6), rather than establishing de novo performance criteria against a specific medical condition's ground truth.

    Therefore, the acceptance criteria and study design are framed around equivalence to a predicate device, not necessarily absolute clinical accuracy or performance based on an independent ground truth outside of this comparison.

    Here's an analysis of the document to address your request:

    Acceptance Criteria and Reported Device Performance

    The acceptance criteria are implicitly defined by demonstrating "substantial equivalence" to the predicate device (ReDS V2.6). The performance reported is in terms of this equivalence, rather than specific numerical thresholds for diagnostic accuracy against a disease state.

    Acceptance Criteria (Implied for Equivalence)Reported Device Performance (ReDS System V2.7 in comparison to ReDS V2.6)
    Functional Equivalence: The ReDS System V2.7 should perform the same intended function as the ReDS V2.6 predicate device (non-invasive monitoring and management of patients with fluid management problems by measuring lung fluid content).Met: "ReDS System V2.7 has the same intended use and similar indications for use, technological characteristics, and principles of operation as the predicate device, ReDS System V2.6." (Page 6)
    Safety and Effectiveness Equivalence: Minor differences between V2.7 and V2.6 should not raise new questions of safety or effectiveness. Performance tests must confirm that these differences do not adversely impact safety or performance.Met: "Any minor differences between the two generation of devices do not raise any new questions of safety or effectiveness. Performance tests, confirm that these differences do not adversely impact safety or performance." (Page 6). This was supported by non-clinical (biocompatibility, software, electrical safety, bench) and clinical testing.
    Biocompatibility: Device materials must be biocompatible for intended use.Met: ISO 10993 testing (cytotoxicity, skin irritation, sensitization) demonstrated "all passing results, supporting the biocompatibility of the device for its intended use." (Page 5)
    Software Validation: Software must be validated and verified as appropriate for release, with hazard analysis performed.Met: "Software validation and verification testing was conducted for the ReDS System software. Results demonstrated that the software was appropriate for release. The software hazard analysis was performed in accordance with ISO 14971:2007." (Page 5)
    Electrical Safety and EMC: Device must comply with applicable electrical safety and electromagnetic compatibility standards.Met: "Results demonstrated that the system complies with the applicable testing standards (IEC 60601-1, IEC 60601-1-11, IEC 60601-1-2, IEC 60601-1-6, and IEC 62366)." (Page 5)
    Bench Testing Performance: Demonstrate substantial equivalence to the predicate for mechanical durability, packaging, transportation, quality feedback, cleaning, disinfection, and usability. All performance testing passed according to defined acceptance criteria.Met: "Bench testing, demonstrating substantial equivalence to the predicate device, provided verification and validation of mechanical durability, packaging and transportation, quality feedback mechanisms, and cleaning and disinfection. Usability testing was also conducted... All performance testing passed according to defined acceptance criteria, demonstrating that the device performs as expected." (Page 5)
    Clinical Performance Equivalence: Clinical data must show equivalent performance between ReDS System V2.7 and ReDS System V2.6, and consistency with non-clinical findings. No device-related adverse events reported.Met: "Clinical data was provided to further assess the ReDS System V2.7 equivalency to ReDS System V2.6. Results showed equivalent performance of the two ReDS System generations. The equivalency presented in the clinical setting was consistent with the findings of the nonclinical studies. No device-related adverse events were reported." (Page 5)
    Expanded Patient Anatomy Range (Specific to V2.7 improvement): The system should be suitable for a slightly expanded height range and for patients with higher BMI within certain chest size ruler values.Met: Changed from "height of between 155 cm (5' 1'') to 190 cm (6' 3'')" (V2.6) to "155 cm (5' 1'') to 195 cm (6' 5''). Patients within the height range having a BMI of 36 to 38 can use the system if their chest size ruler value (as measured by the unit) is 39 or less." (V2.7) (Page 7). This is an improvement, not a criterion to be met by a study.
    Sensor Attachment Configuration Change (Specific to V2.7 change): The new clip-like sensor unit must not negatively impact performance.Met: The change from "2 non-touch sensors embedded in a wearable vest" (V2.6) to "2 non-touch sensors embedded in a clip-like sensor unit" (V2.7) was assessed and deemed not to raise new safety/effectiveness questions (Page 5). This would have been covered by the clinical equivalence study.
    Algorithm Change (Specific to V2.7 change): The "stricter signal quality assessment mechanism" in V2.7 should not negatively impact overall performance or safety.Met: This algorithm change was part of the overall device and covered by the clinical equivalence study and software validation. The document states "Algorithm: Same with a stricter signal quality assessment mechanism" (Page 7), implying it's an enhancement that doesn't hinder performance.

    Study Details:

    The document describes a comparison study to demonstrate substantial equivalence, rather than a de novo clinical trial establishing absolute accuracy against a gold standard for a specific disease or outcome.

    1. Sample size used for the test set and the data provenance:

      • Test Set (Clinical Data): The document states "Clinical data was provided to further assess the ReDS System V2.7 equivalency to ReDS System V2.6." However, it does not specify the sample size for this clinical test set.
      • Data Provenance: The document does not explicitly state the country of origin or whether the data was retrospective or prospective for the clinical testing.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • Given that this is an equivalence study between two versions of the same device, and not a study validating the device's accuracy against a specific physiological ground truth (e.g., direct measurement of lung fluid volume), the concept of "experts establishing ground truth for the test set" in the traditional sense (e.g., radiologists annotating images) is not directly applicable here.
      • The "ground truth" for this study is essentially the performance of the predicate device (ReDS V2.6). The clinical study aimed to show that V2.7's performance was equivalent to V2.6's.
    3. Adjudication method (e.g., 2+1, 3+1, none) for the test set:

      • Not applicable in the context of this equivalence study. There is no mention of independent reviewers or an adjudication process for clinical "ground truth" labels, as the study's goal was to compare the two device versions.
    4. 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 conducted or described. The ReDS System measures lung fluid content; it is not described as an AI-assisted diagnostic imaging tool where human readers "improve with AI assistance." The device is a direct measurement system.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • The ReDS System itself is a standalone device that measures lung fluid content algorithmically. It's described as a "non-invasive thoracic base wave impedance monitor that provides measurement of patient lung fluid content." The "clinical data" section (Page 5) effectively serves as a standalone performance assessment in comparison to the predicate device. The performance of the algorithm within V2.7 was assessed as part of the overall device performance against V2.6.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

      • For the clinical study's "ground truth," the performance of the predicate device (ReDS V2.6) was implicitly used as the reference point for comparison. The study aimed to show that the new device (V2.7) did not significantly differ in its measurements or clinical utility from the established V2.6.
      • The document does not detail a separate, independent "gold standard" for fluid assessment (e.g., invasive measurements, specific clinical outcomes data) against which both devices were tested. The core claim is equivalence to the predicate.
    7. The sample size for the training set:

      • Not applicable / Not explicitly stated. This document describes the validation of a medical device hardware and software system, not the training of a machine learning model. While an internal algorithm exists (which was updated with a "stricter signal quality assessment mechanism" in V2.7), the summary does not suggest a discrete "training set" in the common machine learning sense. The development of the algorithm would have involved internal data sets, but these are not reported as a "training set" in the context of this 510(k) summary.
    8. How the ground truth for the training set was established:

      • Not applicable. As above, the summary does not detail a machine learning training process or corresponding ground truth establishment.
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