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510(k) Data Aggregation
(23 days)
SKINTACT AND VARIOUS OTHER TRADENAMES
ECG Skintact Electrodes are designed for use in general electrocardiographic procedures where ECG monitoring is deemed necessary and is ordered by a physician. Such procedures include in particular patient ECG surveillance and ECG diagnosis recording. Skintact ECG Electrodes are single use, non-sterile and disposable and are to be used on intact (uninjured) skin.
All Skintact® ECG Tab Electrodes are self-adhesive, non-sterile, single use disposable electrodes. The Skintact® ECG Tab Electrodes with KH06D Gel are composed of the same materials as the predicate devices by Leonhard Lang except the modified gel.
Here's an analysis of the provided 510(k) summary regarding the Skintact® ECG Tab Electrodes with KH06D Gel, focusing on acceptance criteria and the study proving device performance:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (Standard) | Reported Device Performance |
---|---|
Biocompatibility: ISO 10993 for intact skin | Cleared and passed ISO 10993; materials confirmed biocompatible; change does not introduce new risks. |
Electrical Performance: ANSI/AAMI EC12:2000/(R)2005 | Met specifications as established in the standard. Additionally, the predicate device (K030509) also met this standard. |
Shelf Life: Tested in accelerated aging | Tested in the same manner as the predicate device (K030509). |
2. Sample Size Used for the Test Set and Data Provenance
The provided text does not specify a sample size for the test set.
The data provenance is not explicitly stated in terms of country of origin or whether it was retrospective or prospective. Given the nature of performance testing against established standards (biocompatibility, electrical performance, shelf life), it's highly likely this was prospective testing conducted by the manufacturer to verify compliance.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Their Qualifications
For this specific device (ECG electrodes), the "ground truth" is typically established by objective measurements and standardized tests rather than expert interpretation of images or patient data. The provided documentation does not mention using experts to establish ground truth for the performance testing. Instead, the ground truth is defined by the requirements of the standards (ISO 10993, ANSI/AAMI EC12).
4. Adjudication Method for the Test Set
As the "ground truth" is based on objective measurements against industry standards, an adjudication method like "2+1" or "3+1" (which typically applies to human interpretation tasks) is not applicable here and is not mentioned in the document.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. This type of study is relevant for AI-powered diagnostic devices where human readers interpret medical images or data. The device in question is a medical accessory (ECG electrode), and its performance is evaluated through technical standards.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
Yes, the studies described are essentially standalone performance assessments of the device itself (the ECG electrode). The biocompatibility, electrical performance, and shelf-life tests involve the device operating on its own or in a controlled environment, without a human-in-the-loop for its basic function.
7. The Type of Ground Truth Used
The ground truth used for the performance testing is based on objective technical standards and material properties:
- Biocompatibility: Conformance to ISO 10993 standards.
- Electrical Performance: Conformance to ANSI/AAMI EC12:2000/(R)2005 specifications.
- Shelf Life: Results of accelerated aging tests, compared to the predicate device's established shelf life.
8. The Sample Size for the Training Set
The concept of a "training set" is relevant for machine learning or AI algorithms. As this device is an ECG electrode and not an AI/ML diagnostic tool, there is no training set in the conventional sense mentioned or implied for its development or testing.
9. How the Ground Truth for the Training Set Was Established
Since there is no training set mentioned, the question of how its ground truth was established is not applicable.
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(14 days)
SKINTACT AND VARIOUS OTHER TRADENAMES
Skintact ECG Electrodes are designed for use in general electrocardiographic procedures where ECG monitoring is deemed necessary and is ordered by a physician. Such procedures include in particular patient ECG surveillance and ECG diagnosis recording. Skintact ECG Electrodes are single use, non-sterile and disposable and are to be used on intact (uninjured) skin.
All Skintact® ECG Electrodes are self-adhesive, non-sterile, single use disposable electrodes. The Skintact® ECG Electrodes with Conductive Adhesive are composed of the same naterials as the predicate devices by Leonhard Lang except the gel, which is made by AmGel Technologies.
Here's a breakdown of the acceptance criteria and study information for the Skintact® ECG Electrodes with Conductive Adhesive, based on the provided 510(k) summary:
1. Table of Acceptance Criteria and Reported Device Performance
Performance Metric/Criteria | Acceptance Criteria (Set by ANSI/AAMI EC12:2000) | Reported Device Performance |
---|---|---|
Biocompatibility | Meets ISO 10993 standards for intact skin. | "Biocompatibility testing was the same as predicate devices and passed ISO 10993 for intact skin." The new device's gel, made by AmGel Technologies, had been previously cleared in a submission by the manufacturer, implying its biocompatibility was established. |
Electrical Performance (Initial) | Meets specifications as established in ANSI/AAMI EC12:2000. This standard covers areas like DC offset voltage, combined offset instability and internal noise, AC impedance, and defibrillation overload recovery. | "The performance data of Skintact® ECG Electrodes with Conductive Adhesive and the predicate devices (K023503, K040249) met specifications as established in ANSI/AAMU EC12:2000." This indicates the device performed within the limits defined by the standard for electrical characteristics. |
Electrical Performance (After Shelf-Life) | Meets specifications as established in ANSI/AAMI EC12:2000 after accelerated aging. | "The shelf life of Skintact® ECG Electrodes with Conductive Adhesive was tested in accelerated aging in the same manner as the predicate devices." The implication, given the overall substantial equivalence claim, is that the device also met ANSI/AAMI EC12:2000 specifications after accelerated aging, demonstrating stability over its claimed shelf life. |
2. Sample Size Used for the Test Set and Data Provenance
The 510(k) summary does not explicitly state the sample size for the test set used in the performance testing. It refers to "performance data" and "biocompatibility testing."
Regarding data provenance:
- Country of Origin: Not explicitly stated, but the submitter (Leonhard Lang GmbH) is based in Austria. The testing itself could have been conducted anywhere.
- Retrospective or Prospective: Not explicitly stated. For performance standards like ANSI/AAMI EC12:2000, testing typically involves prospective laboratory measurements of electrode characteristics. Biocompatibility testing is also generally prospective lab testing.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This type of information is not applicable to this 510(k) submission. ECG electrodes are physical medical devices, and their "ground truth" for performance is established by objective measurements against recognized engineering and safety standards (like ISO 10993 for biocompatibility and ANSI/AAMI EC12:2000 for electrical performance). There are no experts establishing "ground truth" in the way one would for diagnostic image interpretation.
4. Adjudication Method for the Test Set
This is not applicable. As discussed above, the "truth" is determined by objective measurements against established standards, not by expert consensus or adjudication.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No, an MRMC comparative effectiveness study was not done. This type of study is primarily relevant for diagnostic imaging systems or AI algorithms where human interpretation is a key component and the AI's effect on human performance is being evaluated. This 510(k) is for a disposable ECG electrode, a hardware component.
6. If a Standalone (i.e., algorithm-only without human-in-the-loop performance) Was Done
No, a "standalone" study in the context of an algorithm's performance was not done. This 510(k) is for a hardware device, not an algorithm. The performance evaluation focuses on the physical and electrical characteristics of the electrode itself.
7. The Type of Ground Truth Used
The "ground truth" for this device's performance is based on objective measurements against recognized industry standards:
- Biocompatibility: Conformance to ISO 10993 standards.
- Electrical Performance: Conformance to ANSI/AAMI EC12:2000 for ECG electrodes.
8. The Sample Size for the Training Set
This is not applicable. This submission is for a physical medical device (ECG electrode), not an AI algorithm or a diagnostic system that uses a "training set."
9. How the Ground Truth for the Training Set Was Established
This is not applicable as there is no training set for this type of device.
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