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510(k) Data Aggregation

    K Number
    K191989
    Manufacturer
    Date Cleared
    2020-01-29

    (188 days)

    Product Code
    Regulation Number
    870.2300
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K123043, K103604

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

    The Wireless Vital Signs Monitor (WVSM) is intended to be used as an adult patient monitor. It is indicated as a single or multi-parameter vital signs monitor for ECG, noninvasive blood pressure (NIBP) and SpO2, with an optional accessory for capnography (ETCO2, RR). It may be used in the following locations: Hospitals, healthcare facilities, emergency medical applications, during transport, and other healthcare applications. The monitor uses wireless communications to transmit vital signs data to a handheld or PC computer.

    The monitor is intended to be used by trained healthcare providers.

    Device Description

    The WVSM Patient Monitor is a device that monitors physiological parameters associated with Electrocardiogram, Non-invasive Blood Pressure, pulse oximetry and carbon dioxide gas. The WVSM Patient Monitor is a multi-patient use non-sterile device. It utilizes embedded firmware. Patient applied parts are needed for physiological measurement and are provided via FDA cleared OEM accessories to the WVSM monitor. The modification to the WVSM includes: Adding an indication for capnography by interfacing with a FDA cleared accessory. Adding the capability to use the device while connected to the AC power adapter instead of only using the device on battery power.

    AI/ML Overview

    This document provides information about the Athena GTX Wireless Vital Signs Monitor (WVSM) RWC + miniCap, which is a modified version of a previously cleared device. The primary modifications are the addition of capnography functionality and the ability to operate while connected to an AC power adapter.

    Here's an analysis of the acceptance criteria and study data based on the provided text:


    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly present a table of acceptance criteria with specific numerical targets and corresponding performance results for each parameter. Instead, it states that "Key performance specifications are listed in the table in section VI below," which refers to the comparative table between the modified device and the predicate device. This table primarily highlights differences and similarities in technological characteristics.

    However, based on the text, the acceptance criterion for this 510(k) submission appears to be demonstrating that the modifications (capnography and AC power mode) do not adversely affect the safety and effectiveness of the device and that the new functionalities (capnography parameters) meet established standards.

    The document implicitly refers to compliance with industry standards for safety, EMC (Electromagnetic Compatibility), and essential performance as the main performance metric for the modified device.

    Implicit Acceptance Criteria and Reported Performance (Based on the provided text):

    Parameter / AspectAcceptance Criteria (Implied)Reported Device Performance
    Capnography FunctionalityIntegration of FDA cleared accessories (Masimo IRMA & ISA) without altering fundamental scientific technology.The WVSM was originally designed with an AUX port for future use. The capnography accessories are FDA cleared and specifically designed for medical monitors. This modification is largely an interface task to connect two cleared devices using a well-established interface protocol. The addition of the capnography accessory does not alter the fundamental scientific technology.
    AC Power ModeOperation using AC power adapter without altering fundamental scientific technology.An AC power adapter was already used for charging. The modification allows operation while plugged in. An equivalent and updated AC adapter is used. The addition of this AC power mode does not alter the fundamental scientific technology.
    Safety and Essential PerformanceCompliance with recognized national standards (e.g., IEC 60601-1)."Testing of the device modification (WVSM RWC + miniCap) has been completed to verify compliance with recognized national standards for safety and performance for medical devices, and particular requirements applicable to this device have not been affected by this modification including: IEC 60601-1 Basic safety and essential performance, IEC 60601-1-2 EMC."
    Adverse Effects of ModificationsModifications do not adversely affect the performance of the previously cleared device."Side-by-side comparison testing of the device modification (WVSM RWC + miniCap) and the previously cleared device (WVSM Battery operated) has been completed to verify that the devices modifications did not adversely affect the previously cleared device."
    BiocompatibilityNo adverse change to biocompatibility from previously cleared device."The device modification did not change or alter the biocompatibility of the previously cleared device."
    Software Verification and ValidationCompliance with FDA guidance for software in medical devices."Software verification and validation testing were conducted and documentation was provided as recommended by FDA's Guidance... The software for this device was considered as a 'moderate' level of concern." (Implies successful completion as per guidance, but no specific performance metrics are listed).
    Alarm System Delay (Capnography)Meet specified delay limits for IRMA and ISA capnography.IRMA Capnography: Alarm Condition delay
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    Why did this record match?
    Reference Devices :

    K123043, K103604, K040183, K053174, K002734, K110645

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

    The C50 and C80 patient monitors are intended to be used for monitoring, displaying, reviewing, alarming and storing of multiple physiological parameters as following: ECG (3-lead or 12-lead selectable, arrhythmia detection, heart rate (HR)), Respiration rate (RR), SpO2, pulse rate (PR), non-invasive blood pressure (NIBP), temperature (Temp), invasive blood pressure (IBP), carbon dioxide (CO2), anesthetic gas (AG), cardiac output (C.O.) for single patient. The C80 can also monitor the ICG (impedance cardiography) and BIS (bispectral index).

    All the parameters can be monitored on single adult, pediatric, and neonatal patients with the exception of the following:

    · The ICG monitoring is applicable to the adult patients of 122229cm in height and 30159Kg (67~341 pounds) in weight only;

    · NIBP measurement continual mode is not applicable to neonates;

    · Anesthetic depth (BIS) of the multi-parameter patient monitor is not intended for neonatal patients;

    The monitors are to be used in general healthcare facilities by clinical physicians or appropriate medical staff under the direction of physicians. The monitors are not intended for home use.

    Device Description

    The C50 and C80 patient monitors are intended to be used for monitoring, displaying, reviewing, alarming and storing of multiple physiological parameters as following: ECG (3-lead, 5-lead or 12-lead selectable, arrhythmia detection, heart rate (HR)), Respiration rate (RR), SpO2, pulse rate (PR), non-invasive blood pressure (NIBP), temperature (Temp), invasive blood pressure (IBP), carbon dioxide (CO2), anesthetic gas (AG), cardiac output (C.O.) for single patient. The C80 can also monitor the ICG (impedance cardiography) and BIS (bispectral index).

    All the parameters can be monitored on single adult, pediatric, and neonatal patients with the exception of the following:
    • The ICG monitoring is applicable to the adult patients of 122229cm in height and 30159Kg (67~341 pounds) in weight only;
    • NIBP measurement continual mode is not applicable to neonates;
    • Anesthetic depth (BIS) of the multi-parameter patient monitor is not intended for neonatal patients;
    Those monitors provide patient monitoring capabilities by using corresponding accessories.
    The multi-parameter Patient monitor, model: C50 and C80 have same design principle and technical characteristics:
    But the software in the host and modules and components are different.
    The differences between C50 and C80 are ICG, BIS and size of monitor.

    AI/ML Overview

    The provided document describes the acceptance criteria and a study proving the C50 and C80 Multi-parameter Patient Monitor meets these criteria.


    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria are generally established through adherence to recognized international standards and clinical performance metrics. The document details a comparison with a predicate device (K170876, Passport Series Patient Monitors). While explicit "acceptance criteria" for each parameter are not always separately listed with a single performance value from the new device, the "Comparison" column in the table below infers if the new device meets or exceeds the predicate's performance or if sufficient justification is provided for differences.

    FeaturePredicate Device (K170876) PerformanceSubject Device (C50 & C80) PerformanceComparison to Acceptance Criteria (Predicate) & Justification
    Monitor SizePassport 17m: 400x370x193mm; Passport 12m: 297x336x187mmC80: Approx. 344x291x165mm; C50: Approx. 291.7x250x187mmThe monitor size of the subject device is smaller than the predicate device, but it "won't affect the safety and effectiveness of the subject device." Implied acceptance: smaller size is acceptable if safety/effectiveness are not compromised.
    Integrated display & touch screenColor TFT LCD (17-inch, 1280x1024 pixels for 17m; 12-inch, 800x600 pixels for 12m)Color TFT LCD (C80: 12.1-inch, 800x600 pixels; C50: 10.4-inch, 800x600 pixels)Screen size is smaller, but resolution for C80/C50 is the same as Passport 12m. "Same. The screen of Subject device is smaller than predicate device. Complying with IEC 60601-1 and IEC 62366-1 also indicates the clinical use is safe and effective." Implied acceptance: smaller screen size is acceptable due to compliance with relevant IEC standards for safety and usability.
    Power supplyTwo rechargeable Lithium-ion batteries or AC for Passport 17m; One rechargeable Lithium-ion battery or AC for Passport 12mC50 and C80: Powered either by built-in battery or external AC."Same, both powered by battery and AC." Implied acceptance: functional equivalence.
    Battery11.1V, 4500mAh11.1V, 2200mAh/4400mAh"The battery capacity is different. The batteries of C50/C80 have complied with IEC 62133. C50 and C80 have conformed to IEC 60601-1." Implied acceptance: different capacity is acceptable as long as safety (IEC 62133, IEC 60601-1) is maintained.
    ECG3-lead, 5-lead and 12-lead selectable, heart rate (HR)3-lead, 5-lead and 12-lead selectable, heart rate (HR)"Same." Implied acceptance: functional equivalence.
    ECG (Arrhythmia Analysis)Asystole, VFib/VTac, Vtac, Vent. Brady, Extreme Tachy, Extreme Brady, PVC, Couplet, Bigeminy, Trigeminy, Ron T, Run PVCs, PVCs, Tachy, Brady, Missed Beats, Vent. Rhythm, PNP, PNC, Multif. PVC, Nonsus. Vtac, Pause, Irr. Rhythm, AFib (24 types)Asystole, ventricular fibrillation, R ON T, VT >2, Couplet, PVC, Bigeminy, Trigeminy, Brady (Bradycardia), PNC (Pacer Not Capture), PNP (Pacer Not Pace), Missed Beats, IHB (Irregular Heart Beat), VTAC (Ventricular Tachycardia), Tachy (Tachycardia), PVC Too High, Extreme Tachycardia, Extreme Bradycardia, Ventricular Rhythm, Heart Pause (20 types)"C50/C80 has 20 types of arrhythmias in total, 18 of which is same as the predicate device. The other two (underline) is supported by compliance with EC57." Implied acceptance: fewer types are acceptable as long as key arrhythmia detections are present and supported by EC57 compliance.
    RespirationMethod: Trans-thoracic impedance. Range: adult:0-120 rpm; pediatrics:0-150rpm; neonate:0-150rpm. Accuracy: 7 to 150rpm: ± 2rpm or ± 2%, whichever is greater. 0 to 6rpm: not specified.Method: Trans-thoracic impedance. Range: adult:0-120 rpm; pediatrics:0-150rpm; neonate:0-150rpm. Accuracy: 7 to 150rpm: ± 2rpm or ± 2%, whichever is greater. 0 to 6rpm: not specified."Same." Implied acceptance: functional and performance equivalence.
    Pulse oxygen saturation (SpO2)Method: red and infrared light method. Masimo SpO2: Range:1100%. Accuracy: No motion: 70-100% ±2%(adult/pediatric), ±3%(neonate); Motion: 70-100% ±3%. Nellcor SpO2: Range:0100%. Accuracy: 70-100% ±2%(adult/pediatric), ±3%(neonate). Mindray SpO2: Range:0~100%. Accuracy: 70-100% ±2%(adult/pediatric), ±3%(neonate).Method: same. Masimo SpO2: same range & accuracy. Nellcor SpO2: same range & accuracy. Comen SpO2: Range: 0%-100%. Accuracy: 70-100% ±2%(adult/pediatric, non-motion), ±3%(neonate, non-motion)."Same." (for Masimo and Nellcor modules). For their own Comen SpO2 module, it shows equivalent accuracy. Implied acceptance: performance equivalence with predicate's different OEM modules and new Comen module meets similar accuracy.
    Pulse rate (PR)From Mindray SpO2 (Range 20-254 bpm, Acc ±3 bpm), Masimo SpO2 (Range 25-240 bpm, Acc ±3 bpm no motion, ±5 bpm motion), Nellcor SpO2 (Range 20-300 bpm, Acc ±3 bpm for 20-250 bpm), IBP sensor (Range 25-350 bpm, Acc ±1 bpm or ±1%).From Masimo SpO2 (Range 25-240 bpm, Acc ±3 bpm no motion, ±5 bpm motion), Nellcor SpO2 (Range 20-300 bpm, Acc ±3 bpm for 20-250 bpm), Comen SpO2 (Range 20-254 bpm, Acc ±2 bpm), IBP sensor (Range 25-350 bpm, Acc ±1 bpm or ±1%), NIBP sensor (Range 40-240 bpm, Acc ±3 bpm or ±3%)."The PR from Comen SpO2 is more accuracy than the PR form Mindray SpO2. The PR form Masimo SpO2, Nellcor SpO2 and IBP sensor of C50 and C80 are the same with the predicate device. In addition, C50 and C80 have one more PR data source (NIBP) than predicate device. C50 and C80 have complied with ISO 80601-2-61." Acceptance criteria met or exceeded; added NIBP source (improvement). Adherence to ISO 80601-2-61.
    Non-invasive blood pressure (NIBP)Method: Oscillometry. Range: Adult (systolic 25-290mmHg, diastolic 10-250mmHg), pediatric (systolic 25-240mmHg, diastolic 10-200mmHg), neonate (systolic 25-140mmHg, diastolic 10-115mmHg). Accuracy: Max mean error: ±5 mmHg; Max standard deviation: 8 mmHg.Method: same. Range: Adult (systolic 40-270mmHg, diastolic 10-215mmHg), pediatric (systolic 40-200mmHg, diastolic 10-150mmHg), neonate (systolic 40-135mmHg, diastolic 10-100mmHg). Accuracy: 0-300mmHg: ±3mmHg."The NIBP measure range for adult/pediatric/neonate in C50 and C80 is smaller than that in predicate device. The C50 and C80 is more accuracy than predicate device. C50 and C80 have conformed to IEC 80601-2-30." Acceptance criteria met or exceeded in accuracy, and justification for smaller range implicitly accepted by meeting IEC 80601-2-30.
    Temperature (Temp)Method: Thermal resistance. Range: 0 ~ 50°C. Accuracy: ±0.1°C.Method: Thermal resistance. Range: 0 ~ 50°C. Accuracy: ±0.2°C."The predicate device is more accuracy than C50 and C80. C50 and C80 have complied with ISO 80601-2-56." Implied acceptance: slightly lower accuracy is acceptable as long as it complies with ISO 80601-2-56.
    Carbon dioxide (CO2)Method: Infrared absorption. Masimo CO2: Sidestream 0-99mmHg, AwRR 0-120rpm. Microstream 0-99mmHg, AwRR 0-150rpm. Accuracy: Sidestream 0-40mmHg ±2mmHg, 41-76mmHg ±5%, 77-99mmHg ±10%, AwRR ±2rpm. Microstream 0-38mmHg ±2mmHg, 39-99mmHg ±5% +0.08%, AwRR 0-70rpm ±1rpm, 71-120rpm ±2rpm, 121-150rpm ±3rpm.Method: same. Masimo CO2: Sidestream 0-190mmHg, 0-25% (760mmHg), AwRR 0-150rpm. Mainstream 0-190mmHg, 0-25% (760mmHg), AwRR 0-150rpm. Respironics CO2: Sidestream 0-150mmHg, 0-19.7%, AwRR 0, 2-150rpm. Mainstream 0-150mmHg, 0-19.7%, AwRR 0, 2-150rpm. Accuracy (Masimo): ±(2.25mmHg +reading x 4%), AwRR ±1rpm. Accuracy (Respironics): 0-40mmHg ±2mmHg, etc., AwRR ±1rpm."The C50 and C80 are more accuracy and measured wider than predicate device. For C50 and C80, Masimo CO2 module (K123043 and K103604) and Respironics CO2 module (K040183 and K053174) have been cleared. Both modules have complied with ISO 80601-2-55." Acceptance criteria met or exceeded; wider range and higher accuracy; existing modules previously cleared and comply with ISO 80601-2-55.
    Invasive blood pressure (IBP)Method: Direct invasive measurement. Range: -50 to 300 mmHg. Accuracy: ±2% or ±1 mmHg, whichever is greater (without sensor).Method: Direct invasive measurement. Range: -50 to 300 mmHg. Accuracy: ±2% or ±1 mmHg, whichever is greater (without sensor)."Same." Implied acceptance: functional and performance equivalence.
    Cardiac output (C.O.)Method: Thermodilution method. Range: 0.1 to 20 L/min. Accuracy: ±5% or ±0.1 L/min, whichever is greater.Method: Thermodilution method. Range: 0.1 to 20 L/min. Accuracy: ±5% or ±0.1 L/min, whichever is greater."Same." Implied acceptance: functional and performance equivalence.
    Anesthetic gas (AG)Method: Infrared absorption. Range (CO2, N2O, Hal, Enf, Iso, Sev, O2, AwRR). Accuracy (CO2 ±0.3% ABS, N2O ±(8%REL+2%ABS), Other AG 8%REL).Method: same. Range (CO2, N2O, Hal, Enf, Iso, Sev, O2, AwRR). Accuracy (CO2 0-15%: ±(0.2kPa+readingx2%), N2O ±(2 kPa+readingx2%), Hal/Enf/Iso 0-8%: ±(0.15%+readingx5%), Sev 0-10%: ±(0.15%+readingx5%), Des 0-22%: ±(0.15%+readingx5%), O2 ±(1%+readingx2%), Masimo AG AwRR ±1rpm)."For CO2/Enf/Hal/Iso/Sev/Des, The measurement range of C50 and C80 is smaller than the predicate device. For awRR, the measurement range of C80 is better than the predicate device. The C50 and C80 are more accuracy than predicate device. The measurement range of C50 and C80 is enough for most environments; it won't affect the safety and effectiveness. The C50 and C80 supports two AG modules: MASIMO ISA AX+ Sidestream module and Masimo IRMA AX+ Mainstream module, both of them have been cleared in K103604." Acceptance criteria: different ranges are acceptable with justification of sufficient range for most environments and high accuracy. Utilizes previously cleared and compliant modules.
    BIS (C80 only)Range: BIS, BIS L, BIS R: 0-100; SQI, SQI L, SQI R: 0-100%; EMG, EMG L, EMG R: 0-100 Db; SR, SR L, SR R: 0-100%; SEF, SEF L, SEF R: 0.5-30.0 Hz; TP, TP L, TP R: 40-100 Db; BC, BC L, BC R: 0-30; sBIS L, sBIS R: 0-10.0; Semg L, Semg R: 0-10.0; ASYM: 0-100%. Accuracy: 1% for BIS, SQI, EMG, ESR (implied).Range and Accuracy: BIS: same; accuracy: 1%. SQI: same; accuracy: 1%. EMG: same; accuracy: 1%. ESR: 0-100%; accuracy: 1%."The underline parameters are what C50 and C80 doesn't have. The BIS module and sensor have been cleared by FDA and its 510k numbers are K040183 and K002734." Acceptance criteria for essential parameters are met by using previously cleared FDA modules.
    ICG (C80 only)Method: Indirect impedance cardiograph measurement. Range: SV: 5-250 ml; HR: 44-2m; C.O. 1.4-15 L/min. Accuracy: SV: Not specified; HR: ±2 bpm; C.O. Not specified.Method: Indirect impedance cardiograph measurement. Range: HR: 40-250bpm; SV: 0-250mL; C.O.:0-30L/min; TFC: 5-150 /KΩ; SVR:0-3500 dyn・s ・ cm-5. Accuracy: SV: Not specified; HR: ±2 bpm; C.O. Not specified."The underline parameter is what C50 and C80 doesn't have. The ICG electrode cable and sensors are all cleared by FDA, 510(k) number of which is K110645." Acceptance criteria for essential parameters are met by using previously cleared FDA components.

    Study that Proves the Device Meets Acceptance Criteria

    The essential studies to prove the device meets acceptance criteria are divided into Non-Clinical Performance Data and Clinical Studies.

    Non-Clinical Performance Data:

    • Software Verification and Validation Testing: Conducted in accordance with FDA guidance "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices." Risk analysis was performed, and the software was deemed a "major" level of concern.
    • Electrical safety and Electromagnetic Compatibility (EMC): Testing conducted according to:
      • ANSI AAMI ES60601-1:2005/(R)2012 And A1:2012 (IEC 60601-1:2005, MOD)
      • IEC 60601-1-2 Edition 4: 2014-02
    • Bench Testing: Functional and system-level tests were performed, showing the devices meet specifications and perform equivalently to the predicate.
    • Biocompatibility Testing: Performed for patient-contacting components (ECG cable, SpO2 probes, temperature probes) that were not previously cleared. Cytotoxicity, sensitization, and irritation testing were conducted based on ISO 10993-1 and FDA's 2016 biocompatibility guidance.
    • Conformance with Applicable Standards: The device demonstrated compliance with numerous recognized consensus standards, in addition to those listed above for specific modules (e.g., ISO 80601-2-55 for Respiratory Gas Monitors, ISO 80601-2-56 for Thermometers, ISO 80601-2-61 for Pulse Oximeter Equipment, ANSI AAMI EC57:2012 for Cardiac Rhythm and ST-Segment measurement algorithms).

    Clinical Studies:

    1. NIBP Clinical Study - for adults and children

    • Device Parameter: Non-invasive Blood Pressure (NIBP)
    • Acceptance Criteria/Standard: Complies with ISO 81060-2 Second Edition 2013-05-01 "Non-Invasive Sphygmomanometers - Part 2: Clinical Validation Of Automated Measurement Type."
    • Sample Size: 25 patients (19 adults, 6 children).
      • Demographics: 10 men, 15 women. 6 patients aged 3-12, 2 aged 12-40, 10 aged 40-60, 7 above 60.
    • Data Provenance: Retrospective or Prospective not explicitly stated, but implies prospective data collection from "The Second Affiliated Hospital of Guangzhou Medical University and The First Affiliated Hospital of Guangzhou Traditional Chinese Medical University" from 2012 to 2013 (China).
    • Ground Truth: Implicitly referent method (e.g., auscultation by trained observers) as required by ISO 81060-2.
    • Adjudication Method: Not specified, but standard practice for NIBP clinical validation involves multiple observers for reference measurements.
    • Results: "The results are accurate and reliable, and the repeated measurement consistency is in good condition, within the measurement range. Moreover, No adverse events and side effects were found in clinical trials."

    2. NIBP Clinical Study - for neonate and infants

    • Device Parameter: Non-invasive Blood Pressure (NIBP)
    • Acceptance Criteria/Standard: Complies with ISO 81060-2 Second Edition 2013-05-01 "Non-Invasive Sphygmomanometers - Part 2: Clinical Validation Of Automated Measurement Type."
    • Sample Size: 20 subjects.
      • Demographics: 10 males, 10 females. 13 subjects
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    K Number
    K171121
    Manufacturer
    Date Cleared
    2017-11-17

    (214 days)

    Regulation Number
    870.2300
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K103604, K980327

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

    The Masimo Root Monitoring System and Accessories are indicated for use by healthcare professionals for the monitoring of multiple physiological parameters in healthcare environments. The Root Monitoring System, when used with the optional ISA module, is not intended to be used in road ambulances.

    The Masimo Root Monitoring System and Accessories can communicate with network systems for supplemental remote viewing and alarming (e.g., at a central station).

    The optional Masimo Radical-7 Pulse CO-Oximeter and Accessories are indicated for the continuous non-invasive monitoring of functional oxygen saturation of arterial hemoglobin (SpO2), pulse rate, carboxyhemoglobin saturation (SpCO), methemoglobin saturation (SpMet), total hemoglobin concentration (SpHb), and/or respiratory rate (RRa). The Masimo Radical-7 Pulse CO-Oximeter and accessories are indicated for use with adult, pediatric, and neonatal patients during both no motion and motion conditions, and for patients who are well or poorly perfused in hospitals, hospital-type facilities, mobile, and home environments. In addition, the Masimo Radical-7 Pulse CO-Oximeter and accessories are indicated to provide the continuous non-invasive monitoring data obtained from the Masimo Radical-7 Pulse CO-Oximeter and accessories of functional oxygen saturation of arterial hemoglobin (SpO2) and pulse rate to multiparameter devices for the display of those devices.

    The optional Masimo Radius-7 Wearable Pulse CO-Oximeter and Accessories are indicated for the continuous non-invasive monitoring of functional oxygen saturation of arterial hemoglobin (SpO2), pulse rate, carboxyhemoglobin saturation (SpCO), methemoglobin saturation (SpMet), total hemoglobin concentration (SpHb), and/or respiratory rate (RRa). The Masimo Radius-7 Wearable Pulse CO-Oximeter and accessories are indicated for use with adult and pediatric patients during both no motion and motion conditions, and for patients who are well or poorly perfused in hospitals and hospital-type facilities.

    The optional ISA product family consists of three types of sidestream gas analyzers (ISA CO2, ISA AX+ and ISA OR+) and accessories including Nomoline, intended to be connected to other medical backboard devices for monitoring of breath rate and the following breathing gases:

    ISA CO2: CO2

    ISA AX+: CO2, N2O, Halothane, Isoflurane, Enflurane, Sevoflurane and Desflurane

    ISA OR+: CO2, O2, N2O, Halothane, Isoflurane, Enflurane, Sevoflurane and Desflurane

    ISA CO2, ISA AX+ and ISA OR+ are intended to be connected to a patient breathing circuit for monitoring of inspired/expired gases during anesthesia, recovery and respiratory care. The intended environment is the operating suite, intensive care unit and patient room. ISA CO2 is also intended to be used in road ambulances. The intended patient population is adult, pediatric, infant, and neonatal patients.

    The optional SEDLine Sedation Monitor is indicated for use in the operating room (OR), intensive care unit (ICU), and clinical research laboratory. It is intended to monitor the state of the brain by real-time data acquisition and processing of EEG signals. The system includes the Patient State Index (PSI), a proprietary computed EEG variable that is related to the effect of anesthetic agents.

    The optional temperature module is indicated to measure temperature (oral, adult axillary, pediatric axillary, and rectal) of adult and pediatric patients. The device is intended to be used by clinicians and medically qualified personnel. It is available for sale only upon the order of a physician or licensed health care provider.

    The optional non-invasive blood pressure (NIBP) module is indicated for the noninvasive measurement of arterial blood pressure in healthcare environments. The NIBP module is designed to measure blood pressure for patient population described in the following table:

    Patient PopulationApproximate Age Range
    Newborn (neonate)Birth to 1 month of age
    Infant1 month to 2 years of age
    Child2 to 12 years of age
    Adolescent12-21 years of age
    Adult21 years of age and older
    Device Description

    The Masimo Root Monitoring System and Accessories (Root) is a multifunctional device that monitors vital signs for neonatal to adult patients. Parameters monitored by Root are from cleared measurement modules and their corresponding accessories, consisting of:

    • . Masimo Radical-7 and Radius-7 Pulse CO-Oximeter measurement modules and accessories (i.e. RD SET disposable sensors, RD Rainbow sensors, RAS-45 or RRa sensors) with technologies for the monitoring of non-invasive functional oxygen saturation of arterial hemoglobin (SpO2), pulse rate, carboxyhemoglobin saturation (SpCO), methemoglobin saturation (SpMet), total hemoglobin concentration (SpHb), and respiratory rate (RRa);
    • Masimo Sweden ISA-Infrared Sidestream Gas Analyzer measurement modules (ISA) and accessories (Nomoline product family) with technologies for breathing gases and respiratory rate monitoring, including inspired/expired gases during anesthesia, recovery and respiratory care;
    • Masimo Sedline Sedation Monitor measurement module and accessories (i.e. RD . Sedline EEG sensor) with technologies for state of the brain by real-time data acquisition and processing of EEG signals and Patient State Index (PSI) which is an EEG variable that is related to the effect of anesthetic agents;
    • Temperature measurement module and accessories (i.e. temperature probe) with technologies for oral/axillary body temperature measurements; and
    • . Non-invasive blood pressure measurement module and accessories (i.e. reuse and disposable pressure cuffs) with technologies for systolic, diastolic and mean arterial pressure (MAP) measurements.

    Root is intended to be used as a user interface to facilitate access control and monitoring device functions. Root displays patient monitoring information from the connected modules. Visual alarms are shown on the Root display and audible alarms are generated through the Root internal speaker. The user accesses the wired or wirelessly connected modules' monitoring functions, using the Root display. When the module is disconnected from Root, the monitoring information from the module is no longer displayed on Root. Data from connected modules, including patient monitoring data, can be communicated to network systems such as the Patient SafetyNet (K071047) and hospital EMR. Root also functions as a pass-through means for communicating information between connected devices and network systems.

    The Root under K151644 consists of various measurement modules, including the ISA product family (ISA) and corresponding accessories, Nomoline product family (Nomoline).

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for the Masimo Root Monitoring System and Accessories. It outlines the device's indications for use, technological characteristics, and a comparison to predicate devices, focusing on the ISA and Nomoline components.

    No clinical studies are mentioned for the subject device to support acceptance criteria within this document. The document explicitly states: "Clinical testing was not performed with the subject device, Root with ISA and Nomoline, to support substantial equivalence."

    Therefore, I can only provide information based on the non-clinical testing and general specifications mentioned.

    Here's a breakdown of the requested information based solely on the provided text:

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

    The document provides "Specifications" for the Root system and the ISA module, which can be interpreted as acceptance criteria for the non-clinical tests conducted. The "reported device performance" is implicitly that the device met these specifications, as the conclusion states the non-clinical testing "demonstrates that the subject device...is substantially equivalent to its predicate."

    Feature/ParameterAcceptance Criteria (Specification)Reported Device Performance (Implied)
    Root (General)
    DisplayColor LCD touchscreenMet specification
    Measurement modulesRadical-7; Radius-7; ISA; Sedline; temperature; NIBPMet specification
    Visual/audible alarmIEC-60601-1-8 compliantMet specification
    Storage/recordingTrend/data storageMet specification
    PowerAC power 100-240 volt, 47-63 Hz; Rechargeable batteryMet specification
    InterfaceWired/wireless; MOC-9; Iris; Nurse call; USB; SD card; temperature probe port; NIBP portMet specification
    Network connectivityEthernet; Wi-Fi, 802.11 a/b/g; Bluetooth 2.0Met specification
    Dimensions/Weight11 x 10.5 x 5.5 inch (27.9 x 26.7 x 14 cm)/ 3.37 kgMet specification
    Operating temperature50 to 104°F (10 to 40°C)Met specification
    Storage temperature-4 to 122°F (-20 to 50°C)Met specification
    Humidity15 to 95% non-condensing humidityMet specification
    Electrical safetyIEC-60601 compliantMet specification
    EMCIEC-60601 compliantMet specification
    Mode of operationContinuousMet specification
    ISA (Gas Analyzer)
    Patient populationAdult, pediatric, infant and neonate patientsMet specification
    Sampling flow rate50 ± 10 ml/minMet specification
    Respiration rate0 to 150 ± 10 breaths/minMet specification
    Rise time (CO2)≤ 250 msMet specification
    Rise time (N2O)≤ 350 msMet specification
    Rise time (O2)≤ 450 msMet specification
    Rise time (HAL, ISO, ENF, SEV, DES)≤ 350 msMet specification
    Accuracy (CO2)0-15 vol%; ±0.2 vol% + 2 % of readingMet specification
    Accuracy (O2)0-100 vol %; ±1 vol% + 2 % of readingMet specification
    Accuracy (N2O)0-100 vol%; ±(2 vol% + 2 % of reading)Met specification
    Accuracy (HAL/ISO/ENF)0-8 vol%; ±0.15 vol% + 5 % of readingMet specification
    Accuracy (SEV)0-10 vol%; ±0.15 vol% + 5 % of readingMet specification
    Accuracy (DES)0-22 vol%; ±0.15 vol% + 5 % of readingMet specification
    Agent identification threshold0.15 vol%Met specification
    Mixture agent threshold (secondary)0.2 vol% + 10% of total agent concentrationMet specification
    InterfaceMOC-9 or RS-232Met specification
    Dimensions/Weight (ISA CO2/AX+)1.3 x 3.1 x 1.9 inch (33 x 78 x 49 mm)/ 130 gMet specification
    Dimensions/Weight (ISA OR+)1.9 x 3.5 x 3.9 inch (49 x 90 x 100 mm)/ 420 gMet specification
    Operating temperature (ISA CO2)32 to 122°F (0 to 50°C)Met specification
    Operating temperature (ISA AX+/OR+)41 to 122°F (5 to 50°C)Met specification
    Storage temperature (ISA)-40 to 158°F (-40 to 70°C)Met specification
    Operating humidity (ISA)
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    K Number
    K153225
    Manufacturer
    Date Cleared
    2016-06-21

    (228 days)

    Product Code
    Regulation Number
    870.2300
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K110028, K103604, K051874, K071047

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

    The Masimo Root Monitoring System and Accessories are indicated for use by healthcare professionals for the monitoring of multiple physiological parameters in healthcare environments.

    The Masimo Root Monitoring System and Accessories can transmit data for supplemental remote viewing and alarming (e.g., at a central station).

    The optional Masimo Radical-7 Pulse CO-Oximeter and Accessories are indicated for the continuous non-invasive monitoring of functional oxygen saturation of arterial hemoglobin (SpO2), pulse rate, carboxyhemoglobin saturation (SpCO), methemoglobin saturation (SpMet), total hemoglobin concentration (SpHb), and/or respiratory rate (RRa). The Masimo Radical-7 Pulse CO-Oximeter and accessories are indicated for use with adult, pediatric, and neonatal patients during both no motion and motion conditions, and for patients who are well or poorly perfused in hospital-type facilities, mobile, and home environments. In addition, the Masimo Radical-7 Pulse CO-Oximeter and accessories are indicated to provide the continuous non-invasive monitoring data obtained from the Masimo Radical-7 Pulse CO-Oximeter and accessories of functional oxygen saturation of arterial hemoglobin (SpO2) and pulse rate to multi-parameter devices for the display of those devices.

    The optional Masimo Radius-7 Wearable Pulse CO-Oximeter and Accessories are indicated for the continuous noninvasive monitoring of functional oxygen saturation of arterial hemoglobin (SpO2), pulse rate, carboxyhemoglobin saturation (SpCO), methemoglobin saturation (SpMet), total hemoglobin concentration (SpHb), and/or respiratory rate (RRa). The Masimo Radius-7 Wearable Pulse CO-Oximeter and accessories are indicated for use with adult and pediatric patients during both no motion conditions, and for patients who are well or poorly perfused in hospitals and hospital-type facilities.

    The optional ISA product family consists of three types of sidestream gas analyzers (ISA CO2, ISA AX+ and ISA OR+), intended to be connected to other medical backboard devices for monitoring of breath rate and the following breathing gases:

    ISA CO2: CO2

    ISA AX+: CO2, N2O, Halothane, Isoflurane, Enflurane, Sevoflurane and Desflurane

    ISA OR+: CO2, O2, N2O, Halothane, Isoflurane, Enflurane, Sevoflurane and Desflurane

    ISA CO2, ISA AX+ and ISA OR+ are intended to be connected to a patient breathing circuit for monitoring of inspired/expired gases during anesthesia, recovery and respiratory care. The intended environment is the operating suite, intensive care unit and patient room. ISA CO2 is also intended to be used in road ambulances. The intended patient population is adult, pediatric and infant patients.

    The optional SEDLine Sedation Monitor is indicated for use in the operating room (OR), intensive care unit (ICU), and clinical research laboratory. It is intended to monitor the state of the brain by real-time data acquisition and processing of EEG signals. The system includes the Patient State Index (PSI), a proprietary computed EEG variable that is related to the effect of anesthetic agents.

    Device Description

    The Root Monitoring System (Root) is a multifunctional device that monitors vital signs of patients from neonates to adults. Parameters monitored by Root include non-invasive functional oxygen saturation of arterial hemoglobin (SpO2), pulse rate, carboxyhemoglobin saturation (SpCO), methemoglobin saturation (SpMet), total hemoglobin concentration (SpHb), respiratory rate (RRa), inspired/expired gases during anesthesia, recovery and respiratory care, state of the brain by real-time data acquisition and processing of EEG signals, and Patient State Index (PSI) which is an EEG variable that is related to the effect of anesthetic agents.

    Root is intended to be used with the previously FDA cleared measurement technologies for the modules of:

    • . Masimo Radical-7 Pulse CO-Oximeter (Radical-7 module), with cleared technologies of SpO2, pulse rate, SpCO, SpMet, SpHb and RRa monitoring per K110028.
    • Masimo Radius-7 Pulse Oximeter (Radius-7 module), with cleared technologies of ● SpO2, pulse rate, SpCO, SpMet, SpHb and RRa monitoring per K110028.
    • . ISA-Infrared Sidestream Gas Analyzer (ISA module), with cleared technologies of breathing gases and respiratory rate monitoring per K103604.
    • Sedline Sedation Monitor with Frontal PSI and SEDTrace EEG Electrode Set ● (Sedline module), with cleared technologies of EEG and PSI monitoring per K051874.

    Root is intended to be used as an alternative user interface to facilitate access control and monitoring device functions and to connect system networks such as the Patient SafetyNet (K071047).

    Root displays patient monitoring information from the connected modules. Visual alarms are shown on the Root display and audible alarms are generated through the Root internal speaker. When the module is disconnected from Root, the monitoring information from the module is no longer displayed on Root.

    Data from connected modules, including patient monitoring data, can be communicated to network systems. Root also functions as a pass-through means for communicating information between connected devices and network systems.

    The predicate device, Masimo Root Monitoring System (Root) was cleared in K142394, is the same as the subject device, Masimo Root Monitoring System (Root). Both the predicate and subject devices include the option to connect the Masimo Radius-7 Pulse Oximeter (Radius-7) module. The main difference is that the Radius-7 in the subject device now provides the same measurement functionality as the Radical-7 module.

    AI/ML Overview

    The Masimo Root Monitoring System and Accessories is a multifunctional device designed for monitoring multiple physiological parameters in healthcare environments.

    Here's an analysis of its acceptance criteria and supporting studies based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document describes performance in terms of compliance with various standards and successful completion of verification and validation activities. It doesn't list specific quantitative acceptance criteria for each physiological parameter (e.g., accuracy ranges for SpO2, pulse rate, etc.) for the Root system itself, as these are attributed to the individual modules (Radical-7, Radius-7, ISA, Sedline). The Root system primarily acts as an interface and data aggregator.

    Feature/StandardAcceptance CriteriaReported Device Performance
    Electrical SafetyCompliance with IEC60601-1Testing per IEC60601-1 performed; compliant.
    Electromagnetic Compatibility (EMC)Compliance with IEC-60601-1-2Testing per IEC-60601-1-2 performed; compliant.
    Alarm SystemCompliance with IEC-60601-1-8Testing per IEC-60601-1-8 performed; compliant.
    BiocompatibilityCompliance with ISO-10993Testing per ISO-10993 performed; compliant.
    UsabilityCompliance with FDA Human Factors and Usability Draft GuidanceUsability testing performed; compliant.
    Wireless FunctionalityCompliance with FDA Wireless GuidanceWireless testing performed; compliant.
    Software VerificationCompliance with FDA Software GuidanceSoftware verification performed; compliant.
    Mechanical and Environmental CharacteristicsCompliance with Mil-Std-810Mechanical and environmental testing performed; compliant.
    Functionality (Root as an interface)Alternative user interface to integrate modules, provide access/control/monitoring of measurement technologies (of connected modules), transmit data for remote viewing/alarming, communicate with network systems.Functions as intended, displays data from modules, handles alarms, communicates with networks.
    Modified Radius-7 Module PerformanceTo provide all measurements in the Radical-7 module (SpO2, pulse rate, SpCO, SpMet, SpHb, RRa).Thoroughly tested through verification and validation; all requirements and performance specifications satisfied.

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

    The document is for a 510(k) premarket notification, which often relies on non-clinical testing and substantial equivalence to a predicate device rather than extensive clinical trials for the primary monitor system itself.

    The document indicates that for the Root Monitoring System and the modified Radius-7 Module, "thoroughly tested through verification and validation" was performed. This suggests a series of engineering and performance tests on the device hardware and software.

    • Sample Size: Not explicitly stated in numerical terms within the provided text. The testing appears to be primarily laboratory-based and engineering verification rather than a patient-based test set.
    • Data Provenance: The nature of the tests (electrical, mechanical, software, etc.) implies that the data was generated internally by Masimo Corporation during product development and validation phases. No information about country of origin of data or whether it was retrospective or prospective is given, as it is non-clinical.

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

    This information is typically relevant for clinical studies or studies involving human judgment (e.g., image interpretation). Since the testing described is non-clinical (electrical safety, software verification, mechanical, etc.), the concept of "experts establishing ground truth for a test set" in the context of clinical outcomes or diagnostic accuracy doesn't directly apply.

    Instead, the "ground truth" for these engineering and performance tests would be established by:

    • Engineering specifications and design documents.
    • Applicable voluntary standards (e.g., IEC, ISO, Mil-Std).
    • FDA guidances (e.g., Human Factors, Wireless, Software).

    The "experts" would be the engineering and quality assurance teams responsible for designing, conducting, and evaluating these tests against established requirements and standards. Their qualifications would involve expertise in relevant engineering disciplines, regulatory compliance, and quality assurance.

    4. Adjudication Method for the Test Set:

    Adjudication methods (like 2+1, 3+1) are typically used in clinical trials or studies where human interpretation or endpoint determination is subjective and requires consensus. As the described testing is non-clinical, an adjudication method for a test set in this sense is not directly applicable.

    The verification and validation processes would involve:

    • Test protocols defining clear pass/fail criteria.
    • Independent review of test results.
    • Conformity assessment against standards.

    Any discrepancies or failures would likely be resolved through engineering review, root cause analysis, and retesting, rather than an adjudication panel.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:

    • No, an MRMC comparative effectiveness study was not done. The document explicitly states: "No clinical testing was done." The Masimo Root system functions as an interface and aggregator for other FDA-cleared modules; its primary mode of submission is through substantial equivalence based on non-clinical tests and its role not altering the intended use of the connected modules.

    6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study:

    The concept of "standalone" performance, often used for AI algorithms, isn't directly applicable here in the same way. The Masimo Root Monitoring System is a hardware device with software that integrates and displays data from other cleared modules. Its "performance" is in correctly displaying data, processing alarms, and interacting with devices and networks.

    • The non-clinical performance testing described (electrical, EMC, software, etc.) essentially assesses the system's "standalone" functional performance relative to its design specifications and applicable standards, without human intervention in the data generation process, but with a human-in-the-loop for monitoring.
    • However, if "standalone" refers to an algorithm making a diagnostic decision without human input, then no such study was done because this device is a monitoring system and not a diagnostic AI algorithm.

    7. Type of Ground Truth Used:

    For the non-clinical tests specified:

    • Engineering specifications and design requirements: For software verification, functional testing, mechanical characteristics, and interface performance.
    • Compliance with harmonized standards: For electrical safety (IEC60601-1), EMC (IEC-60601-1-2), alarm systems (IEC-60601-1-8), biocompatibility (ISO-10993).
    • Compliance with FDA Guidances: For Usability (Human Factors) and Wireless performance.
    • Predicate Device Equivalence: The foundation of the 510(k) submission is demonstrating substantial equivalence to a legally marketed predicate device (K142394 Masimo Root Monitoring System). The performance of the predicate device serves as an implicit "ground truth" for overall device function and safety. The modifications to the Radius-7 module were then tested to ensure they achieved the same performance as the Radical-7 module's existing cleared functionalities.

    8. Sample Size for the Training Set:

    This question is related to machine learning models. The Masimo Root Monitoring System is described as a medical device for monitoring and data integration, not as a device utilizing a machine learning algorithm that requires a "training set." Therefore, this information is not applicable and not provided in the document.

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

    As there is no indication of a machine learning algorithm or a "training set" in the context of this device, this question is not applicable. The device's foundational components (Radical-7, Radius-7, ISA, Sedline modules) are previously cleared technologies with their own established ground truths for their respective physiological measurements, which the Root system then displays and manages.

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    K Number
    K142394
    Manufacturer
    Date Cleared
    2014-11-25

    (90 days)

    Regulation Number
    870.2300
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K110028, K103604, K051874, K071047

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

    The Masimo Root Monitoring System is indicated for use by healthcare professionals for the monitoring of multiple physiological parameters in healthcare environments.

    The Masimo Root Monitoring System can transmit data for supplemental remote viewing and alarming (e.g., at a central station).

    The optional Masimo Radical-7 Pulse CO-Oximeter and Accessories are indicated for the continuous non-invasive monitoring of functional oxygen saturation of arterial hemoglobin (SpO2), pulse rate, carboxyhemoglobin saturation (SpCO), methemoglobin saturation (SpMet), total hemoglobin concentration (SpHb), and/or respiratory rate (RRa). The Masimo Radical-7 Pulse CO-Oximeter and accessories are indicated for use with adult, pediatric, and neonatal patients during both no motion and motion conditions, and for patients who are well or poorly perfused in hospitals, hospital-type facilities, mobile, and home environments. In addition, the Masimo Radical-7 Pulse CO-Oximeter and accessories are indicated to provide the continuous non-invasive monitoring data obtained from the Masimo Radical-7 Pulse CO-Oximeter and accessories of functional oxygen saturation of arterial hemoglobin (SpO-) and pulse rate to multi-parameter devices for the display of those devices.

    The optional Masimo Radius-7 Wearable Pulse Oximeter and Accessories are indicated for the continuous non-invasive monitoring of functional oxygen saturation of arterial hemoglobin (SpO2), pulse rate, and/or respiratory rate (RRa). The Masimo Radius-7 Wearable Pulse Oximeter and accessories are indicated for use with adult and pediatric patients during both no motion and motion conditions, and for patients who are well or poorly perfused in hospitals and hospital-type facilities.

    The optional ISA product family consists of three types of sidestream gas analyzers (ISA CO2, ISA AX+ and ISA OR+), intended to be connected to other medical backboard devices for monitoring of breath rate and the following breathing gases:

    ISA CO2: CO2

    ISA AX+: CO2, N2O, Halothane, Isoflurane, Enflurane, Sevoflurane and Desflurane

    ISA OR+: CO2, O2, N2O, Halothane, Isoflurane, Enflurane, Sevoflurane and Desflurane

    ISA CO2. ISA AX+ and ISA OR+ are intended to be connected to a patient breathing circuit for monitoring of inspired/expired gases during anesthesia, recovery and respiratory care. The intended environment is the operating suite, intensive care unit and patient room. ISA CO2 is also intended to be used in road ambulances. The intended patient population is adult, pediatric and infant patients.

    The optional SEDLine Sedation Monitor is indicated for use in the operating room (OR). intensive care unit (ICU), and clinical research laboratory. It is intended to monitor the state of the brain by real-time data acquisition and processing of EEG signals. The system includes the Patient State Index (PSI), a proprietary computed EEG variable that is related to the effect of anesthetic agents.

    Device Description

    The Root Monitoring System (Root) is a multifunctional device that monitors vital signs of patients from neonates to adults. Parameters monitored by Root include non-invasive functional oxygen saturation of arterial hemoglobin (SpO2), pulse rate, carboxyhemoglobin saturation (SpCO), methemoglobin saturation (SpMet), total hemoglobin concentration (SpHb), respiratory rate (RRa), inspired/expired gases during anesthesia, recovery and respiratory care, state of the brain by real-time data acquisition and processing of EEG signals, and Patient State Index (PSI) which is an EEG variable that is related to the effect of anesthetic agents.

    Root displays patient monitoring information from the connected modules. Visual alarms are shown on the Root display and audible alarms are generated through the Root internal speaker. When the module is disconnected from Root, the monitoring information from the module is no longer displayed on Root.

    Data from connected modules, including patient monitoring data, can be communicated to network systems. Root also functions as a pass-through means for communicating information between connected devices and network systems.

    AI/ML Overview

    The provided document describes the Masimo Root Monitoring System and its accessories. The submission is for a device modification and new indications for use, specifically the addition of the Masimo Radius-7 Pulse Oximeter module. The document focuses on demonstrating substantial equivalence to a previously cleared predicate device (K140188).

    Here's an analysis of the acceptance criteria and study information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly present "acceptance criteria" in a typical quantitative format (e.g., target specificity, sensitivity, or quantifiable error rates for a diagnostic device). Instead, the performance is evaluated through various verification and validation tests against established standards and the functionality of the predicate device. The acceptance criterion for each test appears to be "Pass," indicating successful completion and meeting predefined internal requirements.

    Monitored ParameterTest DescriptionTest ObjectiveStudy EndpointsResults SummaryConclusion
    SpO2, PR, and RRaDisplay verification of Root and Radius-7 moduleTo verify Root user interface when connected to Radius-7Test personnel began and ended test cases for the Root with Radius-7 user interface, and recorded the test results per test procedures.PassRoot correctly displayed monitoring information from Radius-7.
    SpO2, PR, PI, PVI and RRaDisplay validation of Radius-7 moduleTo validate human factors/usabilityClinicians (users) started and completed the usability test cases and recorded the test results per test procedures.PassRadius-7's ease of use was validated by the clinicians.
    SpO2, PR, and RRaDisplay validation of Radius-7 module (for Root and Radius-7)To validate human factors/usability for Root and Radius-7Clinicians (users) started and completed the usability test cases and recorded the test results per test procedures.PassRadius-7's ease of use was validated by the clinicians.
    N/A (General battery)Battery life and operation verification for Radius-7 moduleTo verify battery life and operation for Radius-7Test personnel began and ended battery life/operation test cases, and recorded the test results per test procedures.PassRadius-7's battery life and operation was verified to work properly.
    N/A (Display/speaker)Visual/audio alarm verification for Radius-7 moduleTo verify visual/audio alarm compliance to IEC 60601-1-8Test personnel began and ended visual/audio alarm test cases per the IEC standards, and recorded test results.PassRadius-7 visual/audio alarms are compliant to IEC60601-1-8.
    SpO2, PR, and RRaVisual/audio alarm verification for Root and Radius-7To verify audio and visual alarms on RootTest personnel began and ended audio/visual alarm verification test cases, and recorded test results per test procedures.PassRoot correctly generated visual/audio alarms from Radius-7.
    N/A (General wireless)Wireless (Bluetooth) connection verification for Root and Radius-7To verify Bluetooth connection between Root and Radius-7Test personnel began and ended Bluetooth verification test cases, and recorded test results per test procedures.PassRoot properly connected to Radius-7 via Bluetooth connection.
    N/A (General wireless)Wireless connection verification for Root and Radius-7To verify wireless co-existence per FDA Wireless GuidanceTest personnel began and ended wireless co-existence testing per FDA Guidance, and recorded the test results.PassRoot with Radius-7 met FDA Wireless Guidance requirements for wireless co-existence testing.
    N/A (General wireless)Wireless connection verification for Root and Radius-7To verify wireless quality of service per FDA Wireless GuidanceTest personnel began and ended wireless quality of service testing verification per FDA Guidance, and recorded test results.PassRoot with Radius-7 met FDA Wireless Guidance requirements for wireless quality of service testing.
    SpO2, PR, SpCO, SpMet, SpHb, RRaDisplay verification of Root and Radical-7 moduleTo verify Eagle (Root) user interfaceTest personnel began and ended test cases for the Root user interface, and recorded the test results per test procedures.PassRoot correctly displayed monitoring information from the connected modules.
    SpO2, PR, SpCO, SpMet, SpHb, RRa, Breathing Gases, RR, EEG and PSIDisplay validation of Root and Radical-7, ISA, and Sedline modulesTo validate human factors/usabilityClinicians (users) started and completed the usability test cases and recorded the test results per test procedures.PassRoot's ease of use was validated by the clinicians.
    EEG and PSIDisplay verification of Root and Sedline moduleTo verify Sedline indicator and displayTest personnel began and ended test cases for indicator/display verification, and recorded the test results per test procedures.PassRoot correctly displayed monitoring information from the Sedline module.
    Breathing Gases and RRDisplay verification of Root and ISA moduleTo verify ISA module indicator and displayTest personnel began and ended test cases for indicator/display verification, and recorded the test results per test procedures.PassRoot correctly displayed monitoring information from the ISA module.
    N/A (General wireless)Wireless interface verification of information from any connected moduleTo verify the wireless communication between a module fixture and RootTest personnel began and ended test cases for the wireless interface verification, and recorded the test results per test procedures.PassA module fixture wirelessly connected to Root in the similar communication as a wired connection.
    N/A (General docking)Docking station function verification for Root and Radical-7To verify battery managementTest personnel began and ended battery management test cases, and recorded the test results per test procedures.PassRoot docking station interfaced correctly with the Radical-7 module.
    EEG and PSIMOC-9 interface verification for Root and Sedline moduleTo verify MOC-9 Port EEPROMTest personnel began and ended MOC-9 EEPROM verification test cases, and recorded the test results per test procedures.PassThe MOC-9 interface functioned correctly in EEPROM identification.
    Breathing gases, RR, EEG and PSMOC-9 interface verification for Root and ISA and Sedline modulesTo verify EEPROM Identification for Iris and MOC-9Test personnel began and ended EEPROM Identification test cases for Iris and MOC-9, and recorded test results per test procedures.PassThe MOC-9 and Iris interfaces functioned correctly in EEPROM identification for connected modules.
    Breathing Gases and RRRoot and ISA module verificationTo verify Root/PhaseIn (ISA) capnography module integrationTest personnel began and ended ISA integration test cases, and recorded the test results per test procedures.PassRoot correctly displayed monitoring information from the ISA module.
    EEG and PSIRoot and Sedline module verificationTo verify Root/Sedline integrationTest personnel began and ended Sedline integration test cases, and recorded the test results per test procedures.PassRoot correctly displayed monitoring information from the Sedline module.
    EEG and PSIRoot and Sedline module verificationTo verify Sedline board communicationTest personnel began and ended Sedline board communication test cases, and recorded test results per test procedures.PassRoot correctly communicated with the Sedline module.
    N/A (Display/speaker)Visual/audio alarm verification for RootTo verify visual/audio alarm compliance to IEC 60601-1-8Test personnel began and ended visual/audio alarm test cases per the IEC standards, and recorded test results.PassRoot visual/audio alarms are compliant to IEC60601-1-8.
    SpO2, PR, SpCO, SpMet, SpHb, RRa, Breathing Gases, RR, EEG and PSIVisual/audio alarm verification for Root and Radical-7, ISA, and Sedline modulesTo verify visual/audio alarm acknowledgmentTest personnel began and ended visual/audio alarm acknowledgment test cases, and recorded the test results per test procedures.PassRoot correctly generated visual/audio alarms from the connected modules.
    SpO2, PR, SpCO, SpMet, SpHb, RRa, Breathing Gases, RR, EEG and PSIVisual/audio alarm verification for Root and Radical-7, ISA, and Sedline modulesTo verify audio and visual alarmsTest personnel began and ended audio/visual alarm verification test cases, and recorded test results per test procedures.PassRoot correctly generated visual/audio alarms from the connected modules.
    SpO2, PR, SpCO, SpMet, SpHb, RRa, Breathing Gases, RR, EEG and PSIAlarm limit controls verification for Root and Radical-7, ISA, and Sedline modulesTo verify alarm limit controlsTest personnel began and ended alarm limit controls verification test cases, and recorded test results per test procedures.PassRoot correctly generated alarm limits from the connected modules.
    N/A (General wired)Wired connection verification for RootTo verify Ethernet connectionTest personnel began and ended Ethernet verification test cases, and recorded test results per test procedures.PassRoot functioned correctly in its connectivity via the Ethernet.
    N/A (General wired)Wired connection verification for RootTo verify Iris connectivity to network systemTest personnel began and ended Iris/Patient SafetyNet connectivity test cases, and recorded test results per test procedures.PassRoot's Iris interface functioned correctly in its connectivity to system networks such as the Patient SafetyNet.
    N/A (General wireless)Wireless connection verification for RootTo verify internal radio moduleTest personnel began and ended radio module verification test cases, and recorded test results per test procedures.PassRoot's internal radio module performed correctly.
    N/A (General wireless)Wireless connection verification for RootTo verify wireless co-existence per FDA Wireless GuidanceTest personnel began and ended wireless co-existence testing per FDA Guidance, and recorded the test results.PassRoot met FDA Wireless Guidance requirements for wireless co-existence testing.
    N/A (General wireless)Wireless connection verification for RootTo verify wireless quality of service per FDA Wireless GuidanceTest personnel began and ended wireless quality of service testing verification per FDA Guidance, and recorded test results.PassRoot met FDA Wireless Guidance requirements for wireless quality of service testing.

    2. Sample Size for the Test Set and Data Provenance

    The document does not specify a quantitative "sample size" in terms of patients or cases for most of the tests. The tests are described as functional verification and usability studies.

    • For "Display validation of Radius-7 module" and "Display validation of Root and Radical-7, ISA, and Sedline modules": The document mentions "Clinicians (users)" participated in usability tests. The exact number of clinicians is not provided.
    • For all other verification tests: "Test personnel" conducted the tests. No specific number is provided.
    • Data Provenance: The studies appear to be internal, non-clinical (laboratory/in-house) verification and validation tests, not involving real-world patient data collection from a specific country or in a retrospective/prospective manner.

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

    This section is not applicable in the traditional sense for this type of device submission. The "ground truth" for these functional and usability tests is established by adherence to engineering specifications, regulatory standards (like IEC 60601-1-8), and successful operation as designed.

    • Usability testing: Involved "Clinicians (users)," implying healthcare professionals as experts for evaluating usability. Specific qualifications (e.g., years of experience, specialty) are not detailed.
    • For other verification tests, "Test personnel" are likely engineers or technicians qualified to conduct technical evaluations.

    4. Adjudication Method for the Test Set

    No formal adjudication method like "2+1" or "3+1" is described. The acceptance criterion for all tests is simply "Pass," meaning the device either successfully performed the function or met the standard, or it did not. This implies a binary outcome based on whether the test objectives and endpoints were met, likely determined by the test personnel or clinicians involved.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No MRMC comparative effectiveness study was done or mentioned. This type of study is typically performed for diagnostic devices where human readers interpret patient data (e.g., images) with and without AI assistance to measure improvement in diagnostic accuracy. The Masimo Root Monitoring System is a monitoring system and user interface, not a diagnostic imaging AI algorithm.

    6. Standalone Performance (Algorithm Only Without Human-in-the-Loop) Performance

    The device itself is a "monitoring system and accessories" that functions as a user interface and communication hub for previously cleared modules. Its primary function is to display data, generate alarms, and connect to networks. Therefore, "standalone" performance in the context of an algorithm's diagnostic accuracy without human involvement is not a relevant metric for this device. The performance evaluated here is the functionality and safety of the monitoring system itself, especially its new integration with the Radius-7 module.

    7. Type of Ground Truth Used

    The "ground truth" is based on:

    • Engineering specifications and design requirements: For successful display, connectivity, and communication functions.
    • Regulatory standards: Such as IEC 60601-1-8 for alarm compliance, IEC 60601-1 and IEC 60601-1-2 for electrical safety and EMC, ISO-10993 for biocompatibility, and FDA guidances for Usability, Wireless, and Software.
    • Functionality of previously cleared predicate devices/modules: The Root system primarily integrates and acts as a user interface for these existing, cleared technologies.

    8. Sample Size for the Training Set

    The document does not describe any machine learning or AI components that would require a "training set" in the conventional sense. The device's functionality is based on established hardware and software integration, not data-driven model training.

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

    As no training set is mentioned or implied for machine learning, this question is not applicable.

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    K Number
    K140188
    Manufacturer
    Date Cleared
    2014-06-25

    (152 days)

    Product Code
    Regulation Number
    870.2300
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K121013, K110028, K103604, K051874

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

    The Masimo Root Monitoring System is indicated for use by healthcare professionals for the monitoring of multiple physiological parameters in healthcare environments.

    The Masimo Root Monitoring System can communicate with network systems for supplemental remote viewing and alarming (e.g., at a central station).

    The optional Masimo Radical 7 Pulse CO-Oximeter and Accessories are indicated for the continuous non-invasive monitoring of functional oxygen saturation of arterial hemoglobin (SpO2), pulse rate, carboxyhemoglobin saturation (SpCO), methemoglobin saturation (SpMet), total hemoglobin concentration (SpHb), and/or respiratory rate (RRa). The Masimo Radical 7 Pulse CO-Oximeter and accessories are indicated for use with adult, pediatric, and neonatal patients during both no motion conditions, and for patients who are well or poorly perfused in hospital-type facilities, mobile, and home environments. In addition, the Masimo Radical 7 Pulse CO-Oximeter and accessories are indicated to provide the continuous non-invasive monitoring data obtained from the Masimo Radical 7 Pulse CO-Oximeter and accessories of functional oxygen saturation of arterial hemoglobin (SpO2) and pulse rate to multi-parameter devices for the display of those devices.

    The optional ISA product family consists of three types of sidestream gas analyzers (ISA CO2. ISA AX+ and ISA OR+), intended to be connected to other medical backboard devices for monitoring of breath rate and the following breathing gases:

    ISA CO2: CO2

    ISA AX+: CO2, N2O, Halothane, Isoflurane, Enflurane, Sevoflurane and Desflurane

    ISA OR+: CO2, O2, N2O, Halothane, Isoflurane, Enflurane, Sevoflurane and Desflurane

    ISA CO2, ISA AX+ and ISA OR+ are intended to be connected to a patient breathing circuit for monitoring of inspired/expired gases during anesthesia, recovery and respiratory care. The intended environment is the operating suite, intensive care unit and patient room. ISA CO2 is also intended to be used in road ambulances. The intended patient population is adult, pediatric and infant patients.

    The optional SEDLine Sedation Monitor is indicated for use in the operating room (OR), intensive care unit (ICU), and clinical research laboratory. It is intended to monitor the state of the brain by real-time data acquisition and processing of EEG signals. The system includes the Patient State Index (PSI), a proprietary computed EEG variable that is related to the effect of anesthetic agents.

    Device Description

    The Root Monitoring System (Root) is a multifunctional device that monitors vital signs of patients from neonates to adults. Parameters monitored by Root include non-invasive functional oxygen saturation of arterial hemoglobin (SpO2), pulse rate, carboxyhemoglobin saturation (SpCO), methemoglobin saturation (SpMet), total hemoglobin concentration (SpHb), respiratory rate (RRa), inspired/expired gases during anesthesia, recovery and respiratory care, state of the brain by real-time data acquisition and processing of EEG signals, and Patient State Index (PSI) which is an EEG variable that is related to the effect of anesthetic agents.

    Root displays patient monitoring information from the connected modules. Visual alarms are shown on the Root display and audible alarms are generated through the Root internal speaker. When the module is disconnected from Root, the monitoring information from the module is no longer displayed on Root.

    Data from connected modules, including patient monitoring data, can be communicated to network systems. Root also functions as a pass-through means for communicating information between connected devices and network systems.

    AI/ML Overview

    Here's an analysis of the provided text regarding the Masimo Root Monitoring System's acceptance criteria and studies:

    1. Table of Acceptance Criteria and Reported Device Performance

    Monitored ParameterTest DescriptionTest ObjectiveStudy Endpoints (Acceptance Criteria)Results Summary (Reported Performance)Conclusion
    SpO2, PR, SpCO, SpMet, SpHb and RRaDisplay verificationTo verify Root user interfaceTest personnel began and ended test cases for the Root user interface, and recorded the test results per test procedures.PassRoot correctly displayed monitoring information from the connected modules.
    SpO2, PR, SpCO, SpMet, SpHb, RRa, Breathing Gases, RR, EEG and PSIDisplay validation of Radical 7, ISA and Sedline modulesTo validate human factors/ usabilityClinicians (users) started and completed the usability test cases and recorded the test results per test procedures.PassRoot's ease of use was validated by the clinicians.
    SpO2, PR, SpCO, SpMet, SpHb, RRa, Breathing Gases, RR, EEG and PSIDisplay validationTo validate human factors/ usabilityClinicians (users) started and completed the usability test cases and recorded the test results per test procedures.PassRoot's ease of use was validated by the clinicians.
    EEG and PSIDisplay verification of Sedline moduleTo verify Sedline indicator and displayTest personnel began and ended test cases for indicator/display verification, and recorded the test results per test procedures.PassRoot correctly displayed monitoring information from the Sedline module.
    Breathing Gases and RRDisplay verification of ISA moduleTo verify ISA module indicator and displayTest personnel began and ended test cases for indicator/display verification, and recorded the test results per test procedures.PassRoot correctly displayed monitoring information from the ISA module.
    N/A. General wireless functionsWireless interface verification of information from any connected moduleTo verify the wireless communication between a module fixture and RootTest personnel began and ended test cases for the wireless interface verification, and recorded the test results per test procedures.PassA module fixture wirelessly connected to Root in the similar communication as a wired connection.
    N/A. General docking functionsDocking station function verificationTo verify battery managementTest personnel began and ended battery management test cases, and recorded the test results per test procedures.PassRoot docking station interfaced correctly with the Radical 7.
    EEG and PSIMOC-9 interface verificationTo verify MOC-9 Port EEPROMTest personnel began and ended MOC-9 EEPROM verification test cases, and recorded the test results per test procedures.PassThe MOC-9 interface functioned correctly in EEPROM identification.
    N/A. Breathing gases, RR, EEG and PSIMOC-9 interface verificationTo verify EEPROM Identification for Iris and MOC-9Test personnel began and ended EEPROM Identification test cases for Iris and MOC-9, and recorded test results per test procedures.PassThe MOC-9 and Iris interfaces functioned correctly in EEPROM identification for connected modules.
    Breathing Gases and RRRoot and ISA module verificationTo verify Root/PhaseIn (ISA) capnography module integrationTest personnel began and ended ISA integration test cases, and recorded the test results per test procedures.PassRoot correctly displayed monitoring information from the ISA module.
    EEG and PSIRoot and Sedline module verificationTo verify Root/Sedline integrationTest personnel began and ended Sedline integration test cases, and recorded the test results per test procedures.PassRoot correctly displayed monitoring information from the Sedline module.
    EEG and PSIRoot and Sedline module verificationTo verify Sedline board communicationTest personnel began and ended Sedline board communication test cases, and recorded test results per test procedures.PassRoot correctly communicated with the Sedline module.
    N/A. General display and speaker functionsVisual/audio alarm verificationTo verify visual/audio alarm compliance to IEC 60601-1-8Test personnel began and ended visual/audio alarm test cases per the IEC standards, and recorded test results.PassRoot visual/audio alarms are compliant to IEC60601-1-8.
    SpO2, PR, SpCO, SpMet, SpHb, RRa, Breathing Gases, RR, EEG and PSIVisual/audio alarm verificationTo verify visual/audio alarm acknowledgmentTest personnel began and ended visual/audio alarm acknowledgment test cases, and recorded the test results per test procedures.PassRoot correctly generated visual/audio alarms from the connected modules.
    SpO2, PR, SpCO, SpMet, SpHb, RRa, Breathing Gases, RR, EEG and PSIVisual/audio alarm verificationTo verify audio and visual alarmsTest personnel began and ended audio/visual alarm verification test cases, and recorded test results per test procedures.PassRoot correctly generated visual/audio alarms from the connected modules.
    SpO2, PR, SpCO, SpMet, SpHb, RRa, Breathing Gases, RR, EEG and PSIAlarm limit controls verificationTo verify alarm limit controlsTest personnel began and ended alarm limit controls verification test cases, and recorded test results per test procedures.PassRoot correctly generated alarm limits from the connected modules.
    N/A. General wired connectionWired connection verificationTo verify Ethernet connectionTest personnel began and ended Ethernet verification test cases, and recorded test results per test procedures.PassRoot functioned correctly in its connectivity via the Ethernet.
    N/A. General wired connectionWired connection verificationTo verify Iris connectivity to network systemTest personnel began and ended Iris/Patient SafetyNet connectivity test cases, and recorded test results per test procedures.PassRoot's Iris interface functioned correctly in its connectivity to system networks such as the Patient SafetyNet.
    N/A. General wireless connectionWireless connection verificationTo verify internal radio moduleTest personnel began and ended radio module verification test cases, and recorded test results per test procedures.PassRoot's internal radio module performed correctly.
    N/A. General wireless connectionWireless co-existence per FDA Wireless GuidanceTo verify wireless co-existence per FDA Wireless GuidanceTest personnel began and ended wireless co-existence testing per FDA Guidance, and recorded the test results.PassRoot met FDA Wireless Guidance requirements for wireless co-existence testing.
    N/A. General wireless connectionWireless quality of service per FDA Wireless GuidanceTo verify wireless quality of service per FDA Wireless GuidanceTest personnel began and ended wireless quality of service testing verification per FDA Guidance, and recorded test results.PassRoot met FDA Wireless Guidance requirements for wireless quality of service testing.

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

    The provided document refers to "test cases" for various verifications. However, the exact sample sizes (number of test cases or specific data points) for the test sets are not explicitly mentioned for most tests. The provenance of the data is not specified in terms of country of origin, nor is it explicitly stated whether the data was retrospective or prospective. The tests appear to be laboratory/engineering verification tests rather than clinical studies with patient data.

    For "Display validation of Radical 7, ISA and Sedline modules" and "Display validation" related to human factors/usability, it states "Clinicians (users) started and completed the usability test cases...". This suggests prospective testing with users.

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

    For the majority of the tests (display verification, interface verification, alarm verification, etc.), the ground truth was established based on the expected functional behavior of the device according to its design specifications and relevant standards (e.g., IEC standards). The document indicates "Test personnel began and ended test cases... and recorded the test results per test procedures." These "test personnel" would be the experts verifying against the predetermined criteria. Their specific qualifications (e.g., experience level, specific certifications) are not detailed.

    For the "Display validation (human factors/usability)" tests, the ground truth was established by "Clinicians (users)." Their specific number or qualifications (e.g., "radiologist with 10 years of experience") are not detailed, beyond being identified as "clinicians."

    4. Adjudication Method for the Test Set

    The document states that "Test personnel began and ended test cases... and recorded the test results per test procedures." This implies that the results were observed and recorded, likely against a predefined set of expected outcomes for each test case. There is no mention of an adjudication method like "2+1" or "3+1" that would typically involve multiple independent reviewers resolving discrepancies through consensus or a tie-breaker. This suggests a direct pass/fail determination by the test personnel.

    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

    No MRMC comparative effectiveness study was done. The device (Masimo Root Monitoring System) is a patient monitor, essentially an alternative user interface and aggregation system for existing cleared modules. It is not an AI-assisted diagnostic tool that would typically undergo an MRMC study comparing human reader performance with and without AI. The studies focused on verifying the functionality, usability, and compliance of the Root system itself.

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

    This refers to the performance of the device itself, functioning independently. The tests for "Display verification," "Wireless interface verification," "Docking station function verification," "MOC-9 interface verification," "Root and ISA module verification," "Root and Sedline module verification," "Visual/audio alarm verification," "Alarm limit controls verification," and "Wired connection verification" all assess the standalone performance of the Root system and its integration with modules.

    The overall conclusion is that "the subject device, Masimo Root Monitoring System, is substantially equivalent to its predicates with respect to safety and effectiveness, based on the nonclinical tests discussed above." This implies that its standalone performance was deemed acceptable and comparable to existing devices.

    7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.)

    The ground truth used for these tests was primarily:

    • Design Specifications and Expected Functional Behavior: For tests like display verification, interface verification, communication, and alarm functionalities, the device's output and behavior were compared against predefined engineering and operational specifications.
    • Compliance with Standards: For alarms and wireless functionalities, the ground truth was adherence to international standards like IEC60601-1-8 and FDA Wireless Guidance.
    • User Feedback/Usability: For the human factors/usability tests, the ground truth was established by the "clinicians (users)" validating the "ease of use." This could be considered a form of expert feedback.

    No pathology or outcomes data was used as ground truth, as this device itself does not diagnose or determine clinical outcomes independently, but rather displays data from other monitoring modules.

    8. The Sample Size for the Training Set

    The document explicitly states "No clinical testing was done." This implies that there was no "training set" in the context of a machine learning or AI algorithm that typically requires large datasets for training. The device's functionality is based on established engineering principles and interaction with pre-cleared modules, rather than models trained on clinical data.

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

    Since "No clinical testing was done" and there's no mention of a training set, this question is not applicable in the context of this submission. The device's functionality relies on established principles and integration with pre-existing, cleared technologies, rather than being a novel algorithm requiring a training phase with a specific ground truth.

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