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510(k) Data Aggregation

    K Number
    K220530
    Manufacturer
    Date Cleared
    2022-08-17

    (174 days)

    Product Code
    Regulation Number
    868.2775
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K172690, K122439, K161531, K210906

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

    The TetraGraph Neuromuscular Transmission (NMT) Monitor is indicated for monitoring the relaxation of the patient when neuromuscular blockade is administered.

    Device Description

    The TetraGraph Neuromuscular Transmission (NMT) Monitor (TetraGraph) is a portable, batteryoperated EMG-based neuromuscular transmission monitor for use perioperative and in recovery and critical care environments following or during the application of Neuromuscular block. TetraGraph undertakes this function by electrical stimulation of the peripheral nerve and directly measuring the evoked response of the muscles (Muscle Action Potential (MAP)), thus providing a quantitative and automatic measurement of muscle response to a stimulus using electromyography (EMG). The TetraGraph is a prescription-only medical device and is indicated for use in hospitals. TetraGraph consists of the following main components: TetraGraph Monitor, TetraSens Electrode, TetraSens Pediatric Electrode (new accessory), Philips Interface (new and optional accessory), and Pole clamp kit (optional accessory).

    AI/ML Overview

    The provided text describes the 510(k) premarket notification for the Senzime AB TetraGraph Neuromuscular Transmission Monitor, specifically for the addition of new accessories: the TetraSens Pediatric electrode and the Philips Interface. The submission aims to demonstrate substantial equivalence to a legally marketed predicate device (TetraGraph Neuromuscular Transmission Monitor, K190795).

    Based on the provided document, here's an analysis of the acceptance criteria and the study that proves the device meets them:

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

    The document does not explicitly present a table of acceptance criteria with corresponding performance results in a clear, summarized format. Instead, it refers to generalized performance testing.

    However, it implicitly states that performance testing was conducted for the TetraGraph with the new TetraSens Pediatric electrodes and that "all of the acceptance criteria for this device" were met. These criteria are noted to be "the same or very similar to the predicate device's specifications."

    The types of performance testing mentioned are:

    Acceptance Criteria TypeReported Device Performance
    BiocompatibilityMet compliance in accordance with ISO 10993-1, including cytotoxicity, sensitization, and irritation.
    Electrode Performance (General)Met compliance with ANSI/AAMI EC12: 2000 for Disposable ECG Electrodes.
    EMG Evoked Response DetectionCompleted testing, and acceptance criteria were met.
    Electrode Tensile StrengthCompleted testing, and acceptance criteria were met.
    Other Performance TestingCompleted and met all acceptance criteria (e.g., shelf life, software, electrical and EMC).

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

    The document does not specify the sample sizes used for any of the performance tests mentioned (biocompatibility, electrode testing, EMG detection, tensile strength, shelf life, software, electrical, EMC).

    The data provenance is not explicitly stated in terms of country of origin or whether it was retrospective or prospective. It implies internal testing conducted by the manufacturer or their designated testing facilities.

    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):

    This information is not provided in the document. The tests described are largely bench-top and engineering performance tests, which typically do not involve experts to establish ground truth in the same way clinical studies or image-based diagnostics would.

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

    This information is not applicable/not provided as the tests described are technical performance tests rather than clinical evaluations requiring adjudication of subjective outcomes.

    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:

    This type of study is not applicable and was not conducted. The device is a neuromuscular transmission monitor, not an AI-assisted diagnostic tool that aids human readers. The document explicitly states: "There was no clinical testing required to demonstrate that TetraGraph with the new TetraSens Pediatric electrodes is substantial equivalent to the predicate device as the predicate has similar technological characteristics."

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

    The device itself is a measurement and monitoring device, an "algorithm only" or "standalone" performance would refer to its accuracy and reliability in measuring neuromuscular transmission. The performance testing (EMG evoked response detection, compliance with standards) serves this purpose by demonstrating the technical capabilities of the device in isolation, even though it's used by humans. The document confirms that "performance testing made for the device" was completed and met acceptance criteria.

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

    For the described performance tests, the "ground truth" would be established by:

    • Scientific Standards: For biocompatibility (ISO 10993-1) and electrode testing (ANSI/AAMI EC12: 2000), the ground truth is defined by the requirements and test methods outlined in these international and national standards.
    • Engineering Specifications: For EMG evoked response detection, electrode tensile strength, and other performance tests, the ground truth is based on the device's design specifications and expected technical performance against which the measured results are compared.

    8. The sample size for the training set:

    This information is not applicable/not provided. The TetraGraph is a measurement device and the data provided does not suggest it uses machine learning or AI models that require a "training set" in the conventional sense. The submission focuses on hardware accessories and their technical performance.

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

    This information is not applicable/not provided for the same reasons as in point 8.

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    Why did this record match?
    Reference Devices :

    K131829, K131913, K122439

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

    Avalon Fetal/Maternal Monitor FM20:

    Indicated for use by trained health care professionals whenever there is a need for monitoring of the physiological parameters uterine activity, heart rate, oxygen saturation, noninvasive blood pressure, pulse rate and temperature of pregnant women and the fetal heart rates of single fetuses, twins, and triplets in labor and delivery rooms, in antepartum testing areas, in private households and during transports in healthcare facilities.

    Avalon Fetal/Maternal Monitor FM30:

    Indicated for use by trained health care professionals whenever there is a need for monitoring of the physiological parameters uterine activity, heart rate, electrocardiography (ECG), oxygen saturation, noninvasive blood pressure, pulse rate and temperature of pregnant women and the fetal heart rates of single fetuses, twins, and triplets in labor and delivery rooms, in antepartum testing areas, in private households and during transports in healthcare facilities.

    Avalon Fetal/Maternal Monitor FM40:

    Indicated for use by trained health care professionals whenever there is a need for monitoring of the physiological parameters uterine activity, heart rate, oxygen saturation, noninvasive blood pressure, pulse rate and temperature of pregnant women and the fetal heart rates of single fetuses, twins, and triplets in labor and delivery rooms and in antepartum testing areas.

    Avalon Fetal/Maternal Monitor FM50:

    Indicated for use by trained health care professionals whenever there is a need for monitoring of the physiological parameters uterine activity, heart rate, electrocardiography (ECG), oxygen saturation, noninvasive blood pressure, pulse rate and temperature of pregnant women and the fetal heart rates of single fetuses, twins, and triplets in labor and delivery rooms and in antepartum testing areas.

    Device Description

    The legally marketed Philips Avalon fetal/maternal monitors FM20. FM30. FM40. and FM50 offer monitoring of fetal and maternal heart rates, uterine activity, maternal electrocardiography (ECG) wave, maternal noninvasive blood pressure (NIBP), oxygen saturation (SpO2) with pulse rate and temperature, during antepartum testing and labor and delivery.

    The Avalon Fetal/Maternal Monitor FM20 provides the following external measurement parameters:

    • Up to three Fetal Heart Rates (FHR) via Ultrasound (US) -
    • Fetal Movement Profile -
    • Uterine activity via external Toco -
    • -Maternal nulse rate
    • -Maternal Heart Rate via maternal ECG
    • Noninvasive blood pressure (NBP) -
    • Maternal temperature -
    • Pulse oximetry (maternal SpO2) -

    The Avalon Fetal/Maternal Monitor FM30 shares all the features and capabilities of the Avalon FM20. In addition, the Avalon FM30 provides the following external and internal measurement parameters:

    • One Fetal Heart Rate and one fetal DECG wave via direct ECG (DECG) *) -
    • -Uterine activity via intrauterine pressure (IUP)
    • -Maternal ECG (MECG) wave

    *) Note: maximum three fetal heart rates can be monitored.

    The Avalon Fetal/Maternal Monitor FM40 provides the following external measurement parameters:

    • Up to three Fetal Heart Rates (FHR) via Ultrasound (US) -
    • Fetal Movement Profile -
    • Uterine activity via external Toco -
    • -Maternal Pulse Rate
    • Maternal Heart Rate via maternal ECG -
    • -Noninvasive blood pressure (NBP)
    • -Maternal temperature
    • -Pulse oximetry (maternal SpO2)

    The Avalon Fetal/Maternal Monitor FM50 shares all the features and capabilities of the Avalon FM40. In addition, the Avalon FM50 provides the following external and internal measurement parameters:

    • One Fetal Heart Rate and one fetal DECG wave via direct ECG (DECG) *) -
    • Uterine activity via intrauterine pressure (IUP) -
    • -Maternal ECG (MECG) wave

    *) Note: maximum three fetal heart rates can be monitored.

    AI/ML Overview

    This document describes the Philips Avalon Fetal/Maternal Monitors (FM20, FM30, FM40, and FM50) with software revision J.30.

    The document does not explicitly list acceptance criteria in a table format with reported device performance alongside it. Instead, it states that "Pass/Fail criteria were based on the specifications cleared for the predicate devices" and that "The test results are passed and showed substantial equivalence."

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

    Based on the provided text, a specific table of acceptance criteria and reported device performance is not explicitly given. The document generally states that the device "passed" tests based on the specifications of predicate devices.

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

    The document mentions "Bench testing included the use of previously recorded patient raw signals and traces." However, it does not specify the sample size for the test set or the data provenance (e.g., country of origin, retrospective/prospective).

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    The document does not provide information regarding the number of experts, their qualifications, or how they established ground truth for any test set.

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

    The document does not describe any adjudication method used for a test set.

    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:

    This document describes a medical device for monitoring physiological parameters, not an AI-assisted diagnostic tool. Therefore, an MRMC comparative effectiveness study involving human readers and AI assistance is not applicable and not mentioned.

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

    The document describes performance verification and validation. While software testing was performed ("Software verification and validation testing were conducted"), it primarily focuses on the device's functionality and safety in relation to its predicate devices, rather than a standalone algorithm performance in a diagnostic context. The device is a "monitor" and its modifications are related to interfaces and measuring capabilities. There is no explicit mention of a standalone algorithm-only performance study.

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

    The document mentions "previously recorded patient raw signals and traces" were used for bench testing. The quality and origin of these 'raw signals' as ground truth are not further specified beyond being "previously recorded."

    8. The sample size for the training set:

    The document does not mention a training set as this is not an AI/machine learning device in the typical sense that would require a distinct training set.

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

    As no training set is discussed, information on how ground truth was established for it is not applicable and not provided.


    Summary of Acceptance Criteria and Study:

    The primary "acceptance criteria" appear to be meeting the specifications cleared for the predicate devices, and the "study" involved a series of non-clinical verification and validation activities.

    Verification and Validation Activities Included:

    • Biocompatibility testing (Cytotoxicity, Irritation, Delayed Type Hypersensitivity, Chemical characterization)
    • Testing of new or impacted hazards from risk management analysis
    • Software performance and regression verification and validation
    • Performance and regression verification testing of wireless functionality
    • Verification according to applicable EMC, safety, and performance standards (e.g., AAMI/ANSI ES60601-1, IEC 60601-1-2, IEC 60601-1-6, IEC 60601-1-8, IEC 60601-2-27, IEC 80601-2-30, IEC 60601-2-37, ISO 80601-2-56, ISO 80601-2-61, IEC 62304, AAMI ANSI ISO 10993-1)
    • Bench testing using previously recorded patient raw signals and traces.

    The conclusion states that these non-clinical tests demonstrated that the modified devices are "as safe, as effective, and perform as well or better as the predicate devices" and "do not introduce new questions concerning the safety or effectiveness." No clinical studies were deemed necessary.

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