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510(k) Data Aggregation

    K Number
    K213233
    Date Cleared
    2022-06-23

    (266 days)

    Product Code
    Regulation Number
    870.2910
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K121319

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

    EZYPRO ECG Recorder (Model: UG02) is a prescription-only, single-patient-use, continuously recording single-lead cardiac thythm recorder that can be worn up to 14 days each time through recharge. It is indicated for use on patients who are older than 21 years old. At the end of the recorded ECG data can be transferred in an available file on PC via the USB connection.

    During wearing, EZYPRO ECG Recorder (Model: UG02) can digitally transmit ECG data to the mobile device with the APP (EZY iSee) embedded through Bluetooth technology, supporting spot checks on signals. EZY iSee does not contain diagnostic interpretation.

    UG02 setting tool is a program executed on the Windows OS platform and to provide an interface for setting up operational parameters of EZYPRO ECG Recorder (Model: UG02) and downloading the recorded ECG data.

    Device Description

    EZYPRO ECG Recorder (Model: UG02) can record cardiac rhythm up to 14 days. Wearing duration is adjustable based on different needs of the physicians.

    The recorder is lightweight, wire free, and easy to carry around; Will not interfere patient's daily routine or any activities.

    Patient's symptomatic episodes can be marked by proactive pressing the blue button on the recorder; Physicians could later look back at the data and use it in the diagnosis.

    EZYPRO ECG Recorder is solely intended for manual interpretation of the recorded ECG and heart rate detection using the integrated software. The ECG signal recorded by this device is not intended for automated analysis.

    AI/ML Overview

    The provided text describes the regulatory clearance of the EZYPRO ECG Recorder (Model: UG02) and its substantial equivalence to a predicate device. It details non-clinical testing performed but does not include information about acceptance criteria for performance metrics (like sensitivity, specificity, accuracy) based on clinical data or a study describing how these criteria were met.

    The document explicitly states: "No clinical test data was used to support the decision of substantial equivalence." This means that a study proving the device meets performance-based acceptance criteria (as typically understood in terms of diagnostic accuracy or reader improvement for AI devices) was not conducted or submitted for this 510(k) clearance.

    Therefore, many of the requested items cannot be answered from the provided text.

    Based on the available information:

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

    The document does not provide specific performance-based acceptance criteria for diagnostic accuracy metrics (e.g., sensitivity, specificity for arrhythmia detection) as no clinical trials were conducted to assess these aspects. The "acceptance criteria" referred to in the document relate to the successful completion of various non-clinical engineering and safety tests.

    Acceptance Criteria CategoryReported Device Performance
    Reliability TestMet requirements
    Reliability Evaluation (ME)Met requirements
    Reliability (500 cycles reusable)Met requirements
    Shelf Life TestMet requirements
    BiocompatibilityMet requirements
    In Vitro Cytotoxicity Test (Agar Diffusion)Met requirements
    Intracutaneous Irritation Study in RabbitsMet requirements
    Skin Sensitization Study in Guinea Pigs (Maximization Test)Met requirements
    Software ValidationMet requirements
    Recorder Firmware ValidationMet requirements
    EZY iSee Software ValidationMet requirements
    UG02 Setting Tool Software ValidationMet requirements
    Cybersecurity ManagementMet requirements
    EMC and Electrical SafetyMet requirements
    IEC 60601-1 TestMet requirements
    EMC TestMet requirements
    Radio Spectrum TestMet requirements
    SAR EvaluationMet requirements
    Safety Requirements for Portable Sealed Secondary CellsMet requirements
    Lithium Polymer Battery Safety TestMet requirements
    IEC 60601-1-11 TestMet requirements
    Energy Reduction TestMet requirements
    Medical Electrical Equipment PerformanceMet requirements
    IEC 60601-2-47 TestMet requirements
    Product Function Test (EE)Met requirements
    Disposable ECG electrodes TestMet requirements
    QRS and Heart Rate AccuracyMet requirements
    HFE/UEMet requirements
    MR Unsafe EvaluationMet requirements
    RF Wireless EvaluationMet requirements

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

    Not applicable, as no clinical test data was used for a test set. The non-clinical tests were performed on the device itself.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

    Not applicable, as no clinical test data requiring expert review for ground truth was used.

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

    Not applicable, as no clinical test data requiring adjudication was used.

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

    Not applicable. The device is for recording and manual interpretation of ECG; there is no mention of AI assistance or a comparative effectiveness study.

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

    Not applicable. The device explicitly states: "EZYPRO ECG Recorder is solely intended for manual interpretation of the recorded ECG and heart rate detection using the integrated software. The ECG signal recorded by this device is not intended for automated analysis." Therefore, a standalone algorithm performance evaluation would not be relevant.

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

    Not applicable, as no clinical data requiring ground truth for performance evaluation was used. The "ground truth" for non-clinical tests would be defined according to the specific test standards (e.g., electrical safety standards, biocompatibility standards).

    8. The sample size for the training set

    Not applicable, as there is no mention of a training set for an algorithm. The device is not intended for automated analysis.

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

    Not applicable.

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    K Number
    K143513
    Date Cleared
    2015-06-19

    (190 days)

    Product Code
    Regulation Number
    870.2800
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K121319, K121628

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

    The ZIO® SR ECG Monitoring Service is intended to capture, and report symptomatic and/or continuous electrocardiogram (ECG) information for long-term monitoring (up to 14 days). It is indicated for use on adult patients 18 years or older who may be asymptomatic or who may suffer from transient symptoms such as palpitations, shortness of breath, dizziness, light-headedness, pre-syncope, syncope, fatigue, or anxiety. The reported ECG metrics include single-lead analysis on a beat by beat basis, heart rate measurement and rhythm analysis. The report does not contain diagnostic interpretation; the reported analysis is provided for review by the intended user to render a diagnosis based on clinical judgment and experience.

    Device Description

    The ZIO® SR ECG Monitoring Service consists of three components: (1) ZIO SR Patch Recorder with Bluetooth technology, (2) ZIO SR Wireless Gateway, and (3) ZIO ECG Utilization Service System.

    The ZIO® SR Patch is a single-patient-use ECG monitor that provides a continuous, singlechannel recording in addition to symptomatic data transmission for up to 14 days. The ZIO® SR Patch records ECG without patient interaction, with the goal of improving patient compliance via simplicity of operation. Patients have the option of pressing a convenient trigger button which marks the continuous record and initiates a wireless transfer of an ECG strip of 90-second duration. The wireless transfer of data is enabled by the ZIO® SR Gateway, which requires proximity and reception but no patient interaction. The patient is encouraged to fill out a log to document symptomatic events, which will support symptom-rhythm correlation in the ZIO SR Report. Alternatively, the patient can enter symptom logs and view received transmissions via an online patient portal.

    At the conclusion of the wear period (up to 14 days), the patient removes the ZIO® SR Patch and returns it by mail to an iRhythm data processing center.

    Upon receipt of symptomatic or continuous ECG data at iRhythm's Clinical Center (iCC) the ECG data is downloaded, the data is processed through the algorithm and delivered to the QA Tool module where the results are reviewed and/or adjusted by iRhythm Certified Cardiographic Technicians (CCT's) for accuracy. iRhythm employed and trained Patch in-take and CCT personnel follow internal procedures for processing and are of algorithm performance anomalies. Any software anomalies are visible to and manually corrected by iRhythm Technologies CCT's during the QA review and/or Patch Report edits. The CCT generates a final report of the ECG findings contained within the data; thereby enabling the provision of a complete ECG processing and analysis service.

    Upon explicit request from a clinician responsible for the patient's healthcare, longer segments of ECG data from the continuous recording on the Patch can also be wirelessly retrieved during the wear period.

    Automated ECG analysis performance was quantified for any claimed analysis metrics. The resulting statistics demonstrate sensitivity and positive predictivity levels which satisfy requirements and minimize safety or efficacy concerns.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and study information based on the provided text, recognizing that certain specific details (like exact performance metrics or sample sizes for specific training sets) are not explicitly stated in this 510(k) Summary document but can be inferred or acknowledged as missing from this specific submission.

    1. Table of Acceptance Criteria and Reported Device Performance

    Performance MetricAcceptance CriteriaReported Device Performance
    Automated ECG Analysis Performance for Analysis MetricsSatisfy requirements to minimize safety or efficacy concerns."The resulting statistics demonstrate sensitivity and positive predictivity levels which satisfy requirements and minimize safety or efficacy concerns." (Specific numerical targets for sensitivity and positive predictivity are not provided in this document.)
    All Necessary Performance Testing (covering areas like electrical safety, EMC, biocompatibility)Met requirements of recognized consensus standards (listed below)."All necessary performance testing was conducted on the ZIO® SR ECG Monitoring Service to support determination of substantial equivalence to the predicate devices. The results confirm by examination and provision of objective evidence that the design output met the design input requirements in conformance with the following list of recognized consensus standards."

    List of Recognized Consensus Standards (which define performance requirements):

    • ISO 14971:2007/(R)2010 (Medical devices - applications of risk management)
    • IEC 60601-1:2005/(R)2012 and A1:2012, c1:2009/(r)2012 and a2:2010/(r)2012 (Medical electrical equipment - general requirements for basic safety and essential performance)
    • IEC 60601-1-2:2007 (Medical electrical equipment - electromagnetic compatibility)
    • IEC 60601-1-11 Edition 1.0 2010-04 (Medical electrical equipment - requirements for home healthcare environment)
    • IEC 60601-2-47:2012 (Medical electrical equipment - requirements for ambulatory electrocardiographic systems)
    • EC12:2000/(R)2010 (Disposable ECG electrodes)
    • ISO 10993-1:2009/(R) 2013 (Biological evaluation of medical devices - biocompatibility)

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

    • Sample Size: Not explicitly stated in the provided text. The document refers to "Automated ECG analysis performance was quantified for any claimed analysis metrics" but does not give a specific number of records or patients/recordings used for the test set.
    • Data Provenance: Not explicitly stated in the provided text. It does not mention the country of origin or whether the data was retrospective or prospective.

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

    • Number of Experts: Not explicitly stated for the test set ground truth establishment.
    • Qualifications of Experts: The document mentions that the results of the algorithm are reviewed and/or adjusted by "iRhythm Certified Cardiographic Technicians (CCT's) for accuracy." While these CCTs perform review and correction of general algorithm output, it's not explicitly stated if they were the ones establishing the gold standard/ground truth for the test set used to validate the algorithm itself, or if a different set of more senior experts (e.g., cardiologists) were involved in creating the ground truth for an independent test set.

    4. Adjudication Method for the Test Set

    • Adjudication Method: Not explicitly stated for the test set ground truth establishment. The document describes a post-processing step where "results are reviewed and/or adjusted by iRhythm Certified Cardiographic Technicians (CCT's) for accuracy" in the Clinical Center. This sounds like an internal quality assurance step, but not necessarily the method for establishing a blinded, adjudicated ground truth for a formal validation study.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

    • MRMC Study: No, the provided text does not describe a multi-reader multi-case (MRMC) comparative effectiveness study comparing human readers with AI assistance versus without AI assistance. The described process involves CCTs reviewing and potentially adjusting the algorithm's output, implying a form of human-in-the-loop, but not a formal comparative effectiveness study as typically defined for MRMC.
    • Effect Size of Improvement: Since no MRMC study is described, no effect size of human reader improvement with AI assistance is provided.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

    • Standalone Performance: Yes, standalone algorithm performance appears to have been evaluated. The text states: "Automated ECG analysis performance was quantified for any claimed analysis metrics. The resulting statistics demonstrate sensitivity and positive predictivity levels which satisfy requirements and minimize safety or efficacy concerns." This strongly suggests a standalone evaluation of the algorithm's output before any human review or adjustment.

    7. The Type of Ground Truth Used

    • Type of Ground Truth: The document implies an expert consensus or expert review process for establishing ground truth, as it mentions CCTs reviewing and adjusting algorithm output for accuracy. However, it's not explicitly stated whether this was strictly expert consensus from multiple independent reviewers, or a single expert's review, or another form of ground truth like pathology or outcomes data. Given the "CCT's for accuracy" statement, it leans towards expert review.

    8. The Sample Size for the Training Set

    • Sample Size for Training Set: Not explicitly stated in the provided text.

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

    • Ground Truth Establishment for Training Set: Not explicitly stated in the provided text. The document focuses on the operational workflow and validation of the device, not the specifics of the AI model training data or its annotation process.
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