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510(k) Data Aggregation

    K Number
    K103700
    Manufacturer
    Date Cleared
    2011-03-15

    (85 days)

    Product Code
    Regulation Number
    870.2700
    Reference & Predicate Devices
    Predicate For
    N/A
    Why did this record match?
    Reference Devices :

    K864730, K090785

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

    The MRI Patient Monitor (Model 865353) is intended to monitor vital signs for patients undergoing MRI procedures. The MRI Patient Monitor (Model 865353) is intended for use by healthcare professionals.

    Device Description

    The MRI Patient Monitor (Model 865353) is substantially equivalent to the cleared device. Invivo has marketed a stand-alone pulse oximeter for the last 20 years as cleared to market in K864730 (Invivo Pulse Oximeter, Model 4500). This technology is over 20 years old and has not changed in design or fundamental technology since cleared to market. Invivo has identified the need to market an improved standalone pulse oximeter as a replacement for this device. The modified device is predicated from the MRI Patient Monitoring System (Model 865214) which received clearance to market under 510(k) K090785 on December 15, 2009. The cleared device consists of a processing unit, display, and wireless SpO2 module which is directly connected to the patient by a fiber optic sensor, clip, and grip. All oximetry data collection and processing is completed by the wireless SpO2 module and fiber optic sensor. The module transmits the patient data to the processing unit using telemetry, and the processing unit transmits the data to the display using telemetry. The modified device incorporates the same wireless SpO2 module and fiber optic sensor that is currently used with the cleared device. In the modified device, the module transmits the data directly to the display using telemetry. The following modifications have been incorporated to create the modified device: The display was reduced in size and weight. The operator interface is a touch screen (instead of a rotary knob and keypad). SpO2, pulse rate (derived from SpO2), and perfusion index parameters only are measured and displayed. The following parameters are no longer measured and displayed: ECG, non-invasive blood pressure, invasive blood pressure, respiration, temperature, end-tidal CO2, and anesthetic agents concentrations. The device does not provide signals for synchronization for the MRI scanner ("gating"). "Gating", or lack thereof, has no effect on patient monitoring ability or quality. The display is battery-operated only. The display does not offer connections to AC mains. The radio printed circuit board layout was reduced in size to accommodate the smaller display size. The display radio antenna was reduced in size to accommodate the smaller display size and the antenna was concealed in the device handle. The module used with the device also communicates with the existing cleared MRI Patient Monitoring Systems, Models 865214 and 3160. The operating platform was modified to the MicroBlaze soft-core microprocessor running on the Spartan 6LX45 FPGA. The operational system was modified to the uC ("micro C") from company Micrium. The display was modified to provide unlatched alarms only. Latched alarms are no longer provided. The intelligent battery charger is located in the battery (instead of in the device). The modified device has the same performance specifications (SpO2 operating range and accuracy) and uses the same patient applied parts (wireless SpO2 module, fiber optic sensor, clips, and grips) as the cleared device. The MRI Patient Monitor consists of the following primary components: Display ("Vital Signs Viewer"), Wireless SpO2 Module, SpO2 Sensor, SpO2 Grips and Clips. The display and SpO2 module enclose the transceiver and antennas that support bi-directional 2.4 GHz wireless communication. The modified device's operator interface consists of a color 5.7-inch LCD display and touch screen. The modified device's display provides the same vital sign information regarding SpO2, generates the same types of alarms (audible, lights, and text), and controls the same functions (alarm limits, patient type, display setup, and network selection) as the cleared device.

    AI/ML Overview

    This document is a 510(k) summary for the Invivo Essential MRI Patient Monitor (Model 865353). It describes the device, its intended use, and its substantial equivalence to a previously cleared device (Invivo MRI Patient Monitoring System, Model 865214, K090785). The submission primarily focuses on demonstrating that modifications made to the predicate device do not raise new questions of safety or effectiveness.

    Here's an analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text:

    Important Note: This 510(k) submission primarily focuses on demonstrating substantial equivalence to a predicate device, not on proving general safety and effectiveness through de novo clinical trials. The document explicitly states: "The results do not raise issues regarding the safety and effectiveness of the device and clinical data was not required to substantiate claims of safety and effectiveness." Therefore, many of the typical clinical study components (like expert consensus for ground truth, MRMC studies, standalone performance studies with large patient datasets) are not applicable or not explicitly detailed in this type of submission. The focus is on demonstrating that the modified device's performance aligns with the predicate, especially in critical areas like SpO2 accuracy.


    1. Table of Acceptance Criteria and Reported Device Performance

    The document doesn't present a formal "acceptance criteria" table in the sense of a clinical trial endpoint. Instead, it refers to compliance with standards and equivalence to the predicate device's established performance. The key performance specifications for SpO2 are considered unchanged from the predicate device.

    Acceptance Criteria (Predicate Device Performance)Reported Device Performance (Modified Device)
    Pulse Oximetry (SpO2) Saturation Range: 1-100%IDENTICAL TO CLEARED DEVICE (1-100%)
    Pulse Oximetry (SpO2) Saturation Accuracy: ±3% at 70-100%IDENTICAL TO CLEARED DEVICE (±3% at 70-100%)
    Pulse Rate Range: 30-250 BPMIDENTICAL TO CLEARED DEVICE (30-250 BPM)
    Pulse Rate Accuracy: ±2% or 1 BPM, whichever is greaterIDENTICAL TO CLEARED DEVICE (±2% or 1 BPM, whichever is greater)
    MR Conditional: According to ASTM F2503Device is MR Conditional according to ASTM F2503
    Wireless Communication Functionality, Technology, Operating Performance: (Specifics on RF Output Power, Frequency Range, FCC Approvals for SpO2 Module)IDENTICAL TO CLEARED DEVICE (wireless SpO2 module including its radio)
    General Safety: Compliant to IEC 60601-1, -1-2, -1-4, -1-6, -1-8Complies to the requirements in these standards.
    Alarm System: Compliant to IEC 60601-1-8Compliant to IEC 60601-1-8 (unlatched alarms only)
    Biocompatibility: ISO 10993-1Demonstrated through risk management analysis and evaluation of modified device against history of cleared devices.
    Risk Management: ISO 14971Demonstrated by risk management summary.

    Explanation: The fundamental premise of this 510(k) is that the core SpO2 measurement technology (module, technology, patient-applied parts, algorithm, and software) is identical to the cleared predicate device. Therefore, its performance in these aspects is assumed to be the same and does not require re-validation. The validation efforts for the modified device focused on ensuring that the changes (smaller display, touch screen, reduced parameters, battery-operated display, modified radio layout, etc.) did not negatively impact safety or the existing performance specifications.


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

    Given this is a 510(k) for a modified device and "clinical data was not required," specific sample sizes for a traditional test set (e.g., patient data for algorithm evaluation) are not provided.

    The "test set" in this context refers to various engineering and functional tests:

    • Verification and validation of performance specifications: Protocols were established for modified specifications.
    • Verification and validation of MR conditions of use: This involved testing using "3.0T and 1.5T magnetic fields, simulators, and test equipment under the most extreme use conditions." No human subject sample size is mentioned for these MR compatibility tests.
    • Environmental testing: Conducted to confirm conformity over device use life.
    • Evaluation of wireless technology: FCC Part 15 testing and integrity validation of wireless communication.

    Data Provenance: The data provenance is from in-house engineering testing (Invivo Corporation) and third-party laboratory testing for standards compliance (e.g., IEC 60601 series). It is entirely prospective in the sense that the new device was built and then specifically tested against established standards and internal specifications. There is no mention of external data or patient data from a specific country of origin in the context of device performance evaluation.


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

    This information is not applicable and not provided in the document. For 510(k) submissions focusing on substantial equivalence of a modified device, especially one where "clinical data was not required," the ground truth is established by:

    • Engineering specifications and national/international standards (e.g., ISO 9919 for pulse oximeters, IEC standards for electrical safety).
    • The performance of the legally marketed predicate device.

    No medical experts are mentioned as establishing ground truth for performance testing of this device.


    4. Adjudication Method (e.g., 2+1, 3+1, none) for the Test Set

    This information is not applicable and not provided. Adjudication methods like "2+1" or "3+1" are typically used in clinical studies involving interpretation of medical images or patient outcomes, often with multiple human readers. The tests described are engineering and compliance tests (e.g., electrical safety, MR compatibility, wireless function), where results are objective and measured against predefined limits or standards, not subject to subjective expert interpretation requiring adjudication.


    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

    An MRMC comparative effectiveness study was not done. This type of study is relevant for AI/CADe devices that assist human interpretation of medical images. The Invivo MRI Patient Monitor is a vital signs monitor, not an imaging analysis device with an AI component designed to assist human readers, and it explicitly states that "clinical data was not required."


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

    A standalone performance evaluation of the SpO2 algorithm was not done for the modified device, per se. The document states: "Verification and validation of SpO2 accuracy in the modified device is not required because the SpO2 module, technology, patient-applied parts, algorithm, and software is the same as the cleared device." This implies that the standalone performance of the SpO2 algorithm was established during the clearance of the predicate device (K090785) and is considered identical in the modified device.

    The "standalone" performance that was evaluated for the modified device focused on its new components and functionalities separate from core SpO2 algorithm, such as:

    • The display (size, resolution).
    • The operator interface (touch screen).
    • The new radio layout and antenna.
    • The operating platform and system.
    • MR compatibility.

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

    The "ground truth" for the core physiological measurements (SpO2, pulse rate) relies on the established accuracy and performance of the predicate device's SpO2 module, technology, algorithm, and software, which are stated to be identical. This performance would have originally been validated against a reference standard for pulse oximetry, likely involving subjects in a controlled hypoxia study, as per ISO 9919. However, this specific validation against a "ground truth" was not repeated for the modified device.

    For the other aspects, the ground truth was based on:

    • National and international standards: e.g., IEC 60601 series for safety, ISO 9919 for pulse oximeters, ASTM F2503 for MR compatibility.
    • Internal performance specifications: Defined by Invivo Corporation based on market needs and risk management.
    • FCC regulations: For wireless technology evaluation.

    8. The Sample Size for the Training Set

    This information is not applicable and not provided. The device is not an AI/ML device that requires a "training set" in the conventional sense. The "algorithm" for SpO2 measurement is a mature, established technology from the predicate device.


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

    This information is not applicable and not provided as there is no "training set" for an AI/ML algorithm. The core SpO2 algorithm's performance would have been validated against a "ground truth" during its initial development and clearance, likely through controlled studies comparing measured SpO2 values to arterial blood gas measurements, as per relevant standards for pulse oximeters. This process is not described for the modified device as its algorithm is considered identical to the predicate.

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