ECG SENTINEL System

{0}------------------------------------------------ Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health and Human Services logo. To the right of that is the FDA logo, with the letters "FDA" in a blue box. To the right of the blue box is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue. October 18, 2017 Cardiomedix, Inc. % Mark Job Responsible Third Party Official Regulatory Technology Services, LLC 1394 25th Street, NW Buffalo, Minnesota 55313 Re: K172801 Trade/Device Name: ECG SENTINEL System Regulation Number: 21 CFR 870.2920 Regulation Name: Telephone Electrocardiograph Transmitter and Receiver Regulatory Class: Class II Product Code: DXH Dated: September 14, 2017 Received: September 18, 2017 Dear Mark Job: We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading. If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register. Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050. U.S. Food & Drug Administration 10903 New Hampshire Avenue Silver Spring, MD 20993 www.fda.gov {1}------------------------------------------------ If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education (DICE) at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevicesforYou/Industry/default.htm. Also, please note the regulation entitled. "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance. You may obtain other general information on your responsibilities under the Act from the Division of Industry and Consumer Education (DICE) at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Sincerely, M.A. Wilhelm for Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health Enclosure {2}------------------------------------------------ # Indications for Use 510(k) Number (if known) K172801 #### Device Name ECG SENTINEL System ### Indications for Use (Describe) The SENTINEL System is intended for use by patients who either have or are at risk of having cardiac disease and those that demonstrate intermittent symptoms indicative of cardiac disease and require cardiac monitoring on a continuing basis. The device continuously records the ECG data and transfers the data to the Server. Upon detection by an ECG analysis algorithm at the Server the recorded cardiac activity is flagged for review by a medical professional. The data received from the SENTINEL device can be used by another cleared device for arrhythmia analysis, reporting and signal measurements. The SENTINEL System is not intended to sound any alarms. The device does not deliver any therapy, administer any drugs, provide interpretative or diagnostic statements or provide for any life support. The SENTINEL System is for prescription use only. User Population: The SENTINEL is intended for use by adult or children when supervised by an adult. The Sentinel is intended for use on adults and infants weighing more than 10 kg (22 lbs.). Intended Operator Profile: The SENTINEL is intended for home use. The review and analysis of data is intended for use by an appropriately trained medical practitioner. Type of Use (Select one or both, as applicable) | <div><span style="font-size:100%;">☒</span> Prescription Use (Part 21 CFR 801 Subpart D)</div> | |------------------------------------------------------------------------------------------------| | <div><span style="font-size:100%;">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C)</div> | ### CONTINUE ON A SEPARATE PAGE IF NEEDED. This section applies only to requirements of the Paperwork Reduction Act of 1995. ### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.* The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to: > Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov "An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number." {3}------------------------------------------------ # TRADITIONAL 510(K) SUMMARY | Submitted by: | Cardiomedix, Inc. | |-----------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | Contact Person: | Zipora David<br>President<br>Cardiomedix, Inc.<br>1840 Oak Ave.<br>Evanston, IL 60201<br>Ph: 847 869 0230 x100<br>Fax: 847 869 0850<br>Email: zipora@cardiomedix.com | | Date of Summary: | October 17, 2017 | | Device Trade Name: | ECG SENTINEL System | | Common or Usual Name: | Mobile Cardiac Monitor | | Classification Name: | Telephone electrocardiograph transmitter and<br>receiver (21 CFR 870.2920) | | Class: | II | | Product Code: | DXH | | Predicate Device(s): | RhythmStar System (K141813) | | Device Description: | Cardiomedix ECG SENTINEL System is a self-use,<br>2-lead ECG continuous acquisition and transmission<br>system. The SENTINEL device connects via<br>Bluetooth to a proprietary mobile phone-based,<br>dedicated ECG acquisition, storage, and<br>transmission application. The phone application<br>facilitates the self-use of the device by providing<br>messages and alerts for specific parameters. | | | ECG SENTINEL System refers to the complete<br>system with all component parts. | | | SENTINEL refers to the monitoring device only.<br>The SENTINEL data is continuously (long-term)<br>transmitted by the phone to a designated server for<br>storage, analysis, decision support, and response by<br>a qualified and dedicated team. | | | The SENTINEL is intended for use on patients with<br>weighing more than 10 kg (22lbs) | {4}------------------------------------------------ Intended Use: The SENTINEL System is intended for use by patients who either have or are at risk of having cardiac disease and those that demonstrate intermittent symptoms indicative of cardiac disease and require cardiac monitoring on a continuing basis. The device continuously records the ECG data and transfers the data to the Server. Upon detection by an ECG analysis algorithm at the Server the recorded cardiac activity is flagged for review by a medical professional. The data received from the SENTINEL device can be used by another cleared device for arrhythmia analysis, reporting and signal measurements. The SENTINEL System is not intended to sound any alarms. The device does not deliver any therapy, administer any drugs, provide interpretative or diagnostic statements or provide for any life support. The SENTINEL System is for prescription use only. User Population: The SENTINEL is intended for use by adult or children when supervised by an adult. The Sentinel is intended for use on adults and infants weighing more than 10 kq (22 lbs.). Intended Operator Profile: The SENTINEL is intended for home use. The review and analysis of data is intended for use by an appropriately trained medical practitioner. Technoloqical Characteristics: The ECG SENTINEL System component parts include: The SENTINEL monitoring device --SENTINEL carrying pouch Smart phone with pre-installed dedicated । application for SENTINEL ECG acquisition, storage and transmission Smart phone charger and cable --Package of FDA Cleared ECG Electrodes Replacement batteries - - -User guide The SENTINEL monitoring device is a dedicated electronic device that records ECG and consists of {5}------------------------------------------------ electronic circuit board, batteries, a plastic enclosure, and lead wires. The data transmission to the smart phone is via low energy Bluetooth transmission. The smart phone mobile device acts as in in-home communication relay, stores the data, and transfers the data via the WEB, using secure communication, to a call center. The Call Center provides a service platform to monitor, analyze, store, and report ECG data sent from the patient. Performance Testing: The ECG SENTINEL System conforms to the following performance and safety tests: - AAMI/ANSI/IEC 60601-2-47:2012 Medical -Electrical Equipment - Part 2-47: Particular Requirements for the Basic Safety and Essential Performance of Ambulatory Electrocardiographic Systems - AAMI/ANSI ES 60601-1:2005/(R) 2012 & -A1:2012- Medical Electrical Equipment -Part 1: Medical Electrical Equipment - Part 1: General Requirements for Basic Safety and Essential Performance (IEC 60601-1:2005, mod). (General II (ES/EMC)) - IEC 60601-1-2, 4th Edition:2014-02 Medical -Electrical Equipment - Part 1-2: General Requirements for Basic Safety and Essential Performance - Collateral Standard: Electromagnetic Disturbances-Requirements and Tests - IEC 60601-1-11 Edition 2.0 2015-01 -Medical Electrical Equipment - General Requirements for Basic Safety and Essential Performance - Collateral Standard: Requirements for Medical Electrical Equipment and Medical Electrical Systems used in the Home Healthcare Environment - -IEC 62304 Edition 1.1 2015-06, medical device software - software life cycle processes. Bench testing verifies that the ECG SENTINEL System can record ECG signal, store data, transmit data to the Call Center, where the data can be analyzed. Test results confirm that the ECG SENTINEL System performs as designed. {6}------------------------------------------------ K172801 Substantial Equivalence The ECG SENTINEL System is substantially equivalent to the RhythmStar System (K141813), Rationale: manufactured by Rhythmedix, LLC. > The table, below, provides a side-by-side comparison between the ECG SENTINEL System and the RhythmStar System, with regards to the intended use, technology characteristics, principles of operation, and performance specifications. There are no fundamental differences between the ECG SENTINEL System and the predicate product, therefore supporting the final determination of substantial equivalence. | Device Attribute | ECG SENTINEL System<br>Cardiomedix, Inc. | RhythmStar System<br>Rhythmedix<br>(K141813) | Substantial Equivalence<br>Discussion | |--------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | Intended use | The ECG SENTINEL System is<br>intended for use by patients who<br>either have or are at risk of having<br>cardiac disease and those that<br>demonstrate intermittent<br>symptoms indicative of cardiac<br>disease and require cardiac<br>monitoring on a continuing basis.<br><br>The device continuously records<br>the ECG data and transfers the<br>data to the Server. Upon detection<br>by an ECG analysis algorithm at<br>the Server the recorded cardiac<br>activity is flagged for review by a<br>medical professional. | The RhythmStar System is<br>intended for use by patients who<br>either have or are at risk of having<br>cardiac disease and those that<br>demonstrate intermittent systems<br>indicative of cardiac disease and<br>require cardiac monitoring on a<br>continuing basis.<br><br>The device continuously records<br>ECG data and upon detection by<br>an ECG analysis algorithm or<br>manually initiated by the patient,<br>automatically delivers the<br>recorded cardiac activity to the<br>server where it is presented and<br>can be reviewed by a medical<br>professional | The intended use is<br>essentially the same. The<br>difference is that the<br>RhythmStar provides an<br>arrhythmia detection<br>algorithm on the data prior to<br>it being sent to the Server,<br>while the SENTINEL sends<br>all the data to the server and<br>performs arrhythmia analysis<br>at the server. Both devices<br>present the analyzed data to<br>a medical professional for<br>review. | | | The data received from the<br>SENTINEL device can be used by<br>another cleared device for<br>arrhythmia analysis, reporting and<br>signal measurements. The | The data received from the<br>RhythmStar device can be used<br>by another device for arrhythmia<br>analysis, reporting and signal<br>measurements. The RhythmStar | | | | SENTINEL System is not intended<br>to sound any alarms.<br><br>The device does not deliver any<br>therapy, administer any drugs,<br>provide interpretative or diagnostic<br>statements or provide for any life<br>support.<br>The SENTINEL System is for<br>prescription use only. | system is not intended to sound<br>any alarms.<br><br>The device does not deliver any<br>therapy, administer any drugs,<br>provide interpretive or diagnostic<br>statements or provide any life<br>support.<br>RhythmStar is for prescription use<br>only | | | Product Code | DXH | DXH | Same | | Regulation Name<br>and Number | Transmitters And Receivers,<br>Electrocardiograph, Telephone. 21<br>CFR 870.2920 | Same | | | Patient population | Adults and Infants weighing more<br>than 10Kg | Same | | | Environment for<br>Intended Use | Ambulatory, outpatient | Same | | | Ambulatory ECG<br>performance<br>standards | IEC 60601-2-47:2012 | Same | | | System<br>Description | 3 off the shelf electrodes, patient<br>pendant, cell phone, server,<br>display and reporting | 3 or 5 off the shelf electrodes,<br>ECG device, server, display and<br>reporting | The SENTINEL provides two<br>channels of ECG, using 3<br>ECG leads, while the<br>RhythmStar offers and<br>optional 5 lead cable for 3<br>channels of ECG. In<br>addition the RhythmStar has<br>a GPRS transmitter built into<br>the device to connect to the<br>WEB and the SENTINEL<br>uses an external Mobile<br>Phone as a bridge to the<br>WEB | | Basic Technology | Analog ECG front-end, flash data<br>storage, BT transmission to<br>(Android) cell phone, cellular<br>transmission to central server,<br>arrhythmia analysis on central<br>server | Analog ECG front-end together<br>with an Cellular GPRS modem<br>built into the device | The overall technology is the<br>same, Analog ECG front-end<br>to collect data that is sent to<br>the WEB. The main<br>technological difference is<br>that the ECG device worn by<br>the user transmits data via<br>Bluetooth to a Cell Phone<br>that then passes the data to<br>the Server, while the<br>RhythmStar contains the<br>Cellular modem inside the<br>device to directly send the<br>data to the Server. | | Energy Source | Two non-chargeable Zinc-Air<br>hearing aid batteries | Li-Ion externally chargeable<br>battery. | Both units require that the<br>user replace the batteries<br>periodically | | AC Powered | No | No<br>Uses an external battery charger<br>to charge the battery. | | | Channel<br>Recording | 2 | 2 or 3 | | | Bandwidth | 0.5Hz to 35Hz | 0.05Hz to 40Hz | Both units provide a<br>standard monitoring<br>bandwidth. The lower 0.05<br>provided by the RhythmStar<br>is typically required for S-T<br>measurements, but neither<br>units provides S-T<br>measurements | | Common-mode<br>rejection ratio<br>(CMRR) | Meets IEC60601-2-47 standards | same | | | Sampling Rate | Minimum 125 typical 250 Hz | same | | | Patient Cable | Built-in 3 lead cable | Detachable 3 or 5 lead cable | | | Lead off Detection | Yes | Yes | | | Accelerometer | No | Yes | | | Data<br>Transmission | Wireless, via mobile network using<br>Android phone | Same | | | Overall System<br>Design | PEMS and Software | PEMS and Software | | | Sterile | non-sterile | Same | | | Single Use | No | Same | | | Arrhythmia<br>Detection<br>Algorithm | On server, only. | In Device | | | Alarms | None | Same | | | User Event<br>Trigger | Continuous Recording and<br>Transmission | Algorithm based or user triggered<br>transmission | Continuous Transmission<br>allows all events to be seen<br>by the medical staff. | | Battery life | Typically 5 days | 72 hours (3 Days) | | | Dimensions | 7cm x 5cm x 1.5cm | 10cm x 6.6cm x 1.3cm | | | Weight<br>(with battery) | 85 gm | 90 gm | | | Operating<br>temperature | 10 °C to 45 °C | 0 °C to 40°C | | | Transport and<br>storage<br>temperature | -25 °C to 70 °C | -25 °C to 70 °C | | | Relative humidity | 10 % to 95 %, without<br>condensation | 10 % to 95 %, without<br>condensation | | ## Substantial Equivalence Table {7}------------------------------------------------ {8}------------------------------------------------ # K172801 {9}------------------------------------------------ # K172801 {10}------------------------------------------------ ## SUBSTANTIAL EQUIVALENCE ANALYSIS Similarities between the ECG SENTINEL System and the RhythmStar System: - 1. Both devices are small, lightweight ambulatory cardiac monitors, intended for the same patient population. - 2. Both devices have at least 2 channels and 3 ECG electrodes. - 3. The overall technology is the same, with analog ECG front-end to collect data that is sent to the WEB. - 4. RhythmStar has a GPRS transmitter built into the device to connect to the WEB and the ECG SENTINEL System uses an external Mobile Phone as a bridge to the WEB. - 5. Both devices are battery powered. The RhythmStar System utilizes a rechargeable Li-lon battery, while the ECG SENTINEL System used replaceable Zinc-Air batteries. - 6. Both units provide the standard monitoring bandwidth. There are known differences between the ECG SENTINEL System and the RhythmStar System that do not impact the safety or effectiveness: - 1. RhythmStar provides an arrhythmia detection algorithm on the data prior to it being sent to the server, while the ECG SENTINEL device sends all the data to the server and performs arrhythmia analysis at the server. Both devices present the analyzed data to a medical professional for review. - 2. The ECG SENTINEL System transmits data via Bluetooth to a Cell Phone that then passes the data to the server, while the RhythmStar contains the Cellular modem inside the device to directly send the data to the server. Both devices utilize a mobile network to deliver data to the server. - 3. The RhythmStar System incorporates an algorithm based or user triggered event trigger. The ECG SENTINEL System provides continuous recording and transmission of the data with an ECG analysis algorithm at the server. Both devices provide the ability for detection of arrhythmia events and activity identified for subsequent review by a medical professional. The analysis of the differences between the ECG SENTINEL System and RhythmStar system do not raise any new questions of safety and effectiveness. Both devices have or very similar functional, environmental, and electrical characteristics. The ECG SENTINEL System is safe, effective, performs within the design specifications, and is substantially equivalent to the predicate, RhythmStar System. {11}------------------------------------------------ Conclusion: Based on the non-clinical testing conducted, the ECG SENTINEL System is considered safe, and is effective when used as indicated. Therefore, ECG SENTINEL System is substantially equivalent to the legally marketed predicate device, RhythmStar System (K141813).