V2.7 SOFTWARE FOR THE LABSYSTEM PRO EP RECORDING SYSTEM
K141185 · Boston Scientific Corp · DQK · Jun 6, 2014 · Cardiovascular
Device Facts
Record ID
K141185
Device Name
V2.7 SOFTWARE FOR THE LABSYSTEM PRO EP RECORDING SYSTEM
Applicant
Boston Scientific Corp
Product Code
DQK · Cardiovascular
Decision Date
Jun 6, 2014
Decision
SESE
Submission Type
Special
Regulation
21 CFR 870.1425
Device Class
Class 2
Indications for Use
The LabSystem™ EP Laboratory is a computer and software driven data acquisition and analysis tool designed to facilitate the gathering, display, analysis by a physician, pace mapping and storage of cardiac electrophysiologic data. When integrated with the Biosense Webster® CARTO™ 3 system, the Bard® LabSystem™ PRO EP Recording System is designed to: a) send patient demographics to Biosense Webster® CARTO™ 3, and b) acquire (from Biosense Webster® CARTO™ 3), store and display: i) synchronized 3D mapping events, ii) stimulation pacing data, and iii) images of completed 3D electro-anatomical maps of the human heart. The 3D mapping events and images are created by the Biosense Webster® CARTO™ 3 device and stored on the Bard® LabSystem™ PRO EP Recording System for review and insertion into the final clinical report. Integration also supports bidirectional communication of stimulation pacing channel selection and information sharing between the two systems.
Device Story
Microprocessor-based data acquisition system for electrophysiology procedures; acquires ECG, intracardiac, pressure, and digital data from external devices (fluoroscopy, RF generators) via amplifiers and catheters. Used in clinical EP labs by physicians/technicians. Transforms raw electrical signals into visual displays, measurements (diastolic/systolic/mean BP, heart rate, cycle length), and reports. Integrates with Biosense Webster CARTO 3 for bidirectional data sharing (demographics, 3D mapping events, pacing data, images). Does not perform arrhythmia detection or transmit alarms. V2.7 software update migrates platform from Windows XP to Windows 7; no changes to fundamental scientific technology or clinical functionality. Benefits include centralized data management and streamlined reporting for cardiac electrophysiology studies.
Clinical Evidence
Bench testing only. Software verification and validation performed in accordance with IEEE standards (730, 829, 1012, 830, 1008) and IEC 62304. EMC and electrical safety testing conducted per EN 60601-1-2 and EN 60601-1. No clinical data presented.
Technological Characteristics
Microprocessor-based data acquisition system. Connectivity: Networked integration with external medical devices (e.g., CARTO 3, RF generators). Software: V2.7 running on Microsoft Windows 7 platform. Electrical safety: Type CF patient leakage current (50uA) per EN 60601-1. Standards: IEEE 730, 829, 1012, 830, 1008; IEC 62304; EN 60601-1-2; EN 60601-1.
Indications for Use
Indicated for use by physicians in electrophysiology laboratories to acquire, display, analyze, and store cardiac electrophysiologic data, including ECG, intracardiac, and pressure signals. No specific patient population age or gender restrictions; no contraindications.
Regulatory Classification
Identification
A programmable diagnostic computer is a device that can be programmed to compute various physiologic or blood flow parameters based on the output from one or more electrodes, transducers, or measuring devices; this device includes any associated commercially supplied programs.
V2.6 Software for the Bard LabSystem PRO EP Recording System (K113811)
Submission Summary (Full Text)
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# JUN 0 6 2014 K141185
Page 1 of 5
## 510(k) SUMMARY
This 510(k) Summary is provided per the requirements of section 807.92(c).
| Owner Name: | Boston Scientific Corporation |
|----------------------|------------------------------------------------------------------|
| Address: | 55 Technology Drive |
| | Lowell, MA 01851 |
| Phone Number: | 978-323-2293 |
| Fax Number: | 978-323-2222 |
| Contact Person: | Robin M. Mulvey |
| | Regulatory Affairs, Specialist II |
| | Email address: robin.mulvery@bsci.com |
| Alternate Contact: | Julie Broderick |
| | Vice President, Regulatory Affairs |
| | PH: 978-323-2220 |
| | FX: 978-323-2222 |
| | Email address: julie.broderick@bsci.com |
| Date of Summary: | 2 May 2014 |
| Device Trade Name: | LabSystem™ PRO EP Recording System |
| | Device Common Name: Programmable Diagnostic Computer |
| Classification Name: | Programmable Diagnostic Computer |
| Product Code: | DQK |
| Predicate Device(s): | Bard LabSystem PRO EP Recording System<br>(K031000/June 3, 2003) |
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K141185
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V2.6 Software for the Bard LabSystem PRO EP Recording System (K113811/April 3, 2012)
## Device Description:
The V2.7 software for the LabSystem™ PRO EP Recording System is substantially similar to the currently commercialized software (V2.6a) with the difference that the V2.7 software runs on a Microsoft Windows 7 platform as compared to V2.6a which runs on a Windows XP platform. Other than the platform update, there are no changes to the LabSystem PRO EP Recording System software functionality. There are no changes to the fundamental scientific technology of the device nor are there any changes to the intended use.
The LabSystem™ PRO EP Recording System is a microprocessor based data acquisition system that is used during electrophysiology procedures to acquire ECG, intracardiac, pressure and digital data from other devices like fluoroscopic systems and RF generators. The ECG, intracardiac and pressure data are acquired by an amplifier that is connected to the patient via ECG leadwires and catheters. It does not transmit alarms and does not have arrhythmia detection capabilities.
## Indications for Use:
The LabSystem EP Laboratory is a computer and software driven data acquisition and analysis tool designed to facilitate the gathering, display, analysis by a physician, pace mapping and storage of cardiac electrophysiologic data. When integrated with the Biosense Webster® CARTO™ 3 system, the Bard® LabSystem™ PRO EP Recording System is designed to: a) send patient demographics to Biosense Webster® CARTO™ 3, and b) acquire (from Biosense Webster® CARTO™ 3), store and display: i) synchronized 3D mapping events, ii) stimulation pacing data, and iii) images of completed 3D electro-anatomical maps of the human heart. The 3D mapping events and images are created by the Biosense
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K141185 Page 3 of 5
Webster® CARTO™ 3 device and stored on the Bard® LabSystem™ PRO EP Recording System for review and insertion into the final clinical report. Integration
also supports bidirectional communication of stimulation pacing channel selection and information sharing between the two systems.
#### Comparison to Predicate Devices:
The predicate devices for this 510(k) Premarket Notification are the LabSystem™ PRO EP Recording System (K031000), and the V2.6 Software for the LabSystem PRO EP Recording System (K113811). The Indications for Use between the V2.6 software and the proposed software, V2.7, are identical.
All of these devices are electrophysiology recording systems that are used for the same intended purpose. These systems are intended for use under the direct supervision of a licensed healthcare practitioner to acquire, filter, digitize, amplify, and record electrical signals obtained during electrophysiological studies and related procedures conducted in an electrophysiological laboratory. The systems acquire signal types which include ECG signals, direct cardiac signals, and pressure recordings. The systems obtain physiological parameters such as diastolic, systolic and mean blood pressure, heart rate and cycle length which are derived from the signal data, displayed and recorded. The systems allow the user to monitor the acquisition of data, review the data, store the data, perform elementary caliper-type measurements of the data and generate reports on the data. The systems acquire, amplify, display and record data received from other medical devices typically used during these procedures, such as imaging devices and RF generators. The systems do not transmit alarms and do not have arrhythmia detection capabilities.
V2.6 software (K113811) and the proposed V2.7 software have the capability to integrate with the Biosense Webster®, CARTO™ 3 system, to send patient demographics to Biosense Webster® CARTO™ 3, and acquire (from Biosense
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Webster® CARTO™ 3), store and display: i) synchronized 3D mapping events, ii) stimulation pacing data, and iii) images of completed 3D electro-anatomical maps of the human heart. The 3D mapping events and images are created by the Biosense Webster® CARTO™ 3 device and stored on the Bard® LabSystem™ PRO EP Recording System for review and insertion into the final clinical report. Integration also supports bidirectional communication of stimulation pacing channel selection between the two systems.
The hardware, base software and firmware that are currently utilized in the LabSystem PRO EP Recording System (K031000 and K113811) are substantially equivalent to the base software and firmware for the V2.7 software for the LabSystem PRO EP Recording System.
#### Summary of Non-Clinical Testing:
The LabSystem™ PRO EP Recording System is developed and produced in accordance with 21 CFR 820.30 Quality System Regulations. The software product is developed and tested in accordance with the following industry standards. Use of the IEEE standards is voluntary.
| IEEE Standard 730-2002 | Software Quality Assurance Plans |
|-------------------------|---------------------------------------------------------------|
| IEEE Standard 829-2008 | Software Test Documentation |
| IEEE Standard 1012-2012 | Software Verification and Validation Plans |
| IEEE Standard 830-1998 | Software Requirement Specifications |
| IEEE Standard 1008-1987 | Software Unit Testing |
| EN 60601-1-2:2007 | EMC, Radiated emissions and Conducted emissions requirements |
| EN 60601-1:2005 | Patient Leakage current (Section 19, Table IV, Type CF, 50uA) |
| IEC 62304:2006 | Medical Device Software - Software Life Cycle Processes |
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K141185
#### Page 5 of 5
Software qualification is performed in-house on the System with results that meet acceptance criteria, thus confirming the safety and effectiveness of each functional aspect of the LabSystem™ PRO EP Recording System.
## Substantial Equivalence:
The LabSystem™ PRO EP Recording System, subject of this 510(k), is substantially equivalent to the predicate devices. They have the same Indications for Use and principles of operation, and the technological characteristics support a determination of substantial equivalence.
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Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center . WO66-G609 Silver Spring, MD 20993-0002
June 6, 2014
Boston Scientific Corp. Ms. Robin Mulvey Regulatory Affairs, Specialist II 55 Technology Drive Lowell, Massachusetts 01851
Re: K141185
> Trade/Device Name: LabSystem™ PRO EP Recording System V2.7 Regulation Number: 21 CFR 870.1425 Regulation Name: Programmable Diagnostic Computer Regulatory Class: Class II Product Code: DOK Dated: May 5, 2014 Received: May 7, 2014
Dear Ms. Mulvey:
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 (reporting of medical devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in
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Page 2 - Ms. Robin Mulvey
the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/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 Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638 2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
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forBram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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#### K141185
#### Indications for Use
510(k) Number (if known):
Device Name: LabSystem™ PRO EP Recording System
#### Indications for Use:
V2.7 software for the LabSystem™ PRO EP Recording System Indication: The LabSystem™ EP Laboratory is a computer and software driven data acquisition and analysis tool designed to facilitate the gathering, display, analysis by a physician, pace mapping and storage of cardiac electrophysiologic data.
When integrated with the Biosense Webster® CARTO™ 3 system, the Bard® LabSystem™ PRO EP Recording System is designed to: a) send patient demographics to Biosense Webster® CARTO™ 3, and b) acquire (from Biosense Webster® CARTO™ 3), store and display: i) synchronized 3D mapping events, ii) stimulation pacing data, and iii) images of completed 3D electro-anatomical maps of the human heart. The 3D mapping events and images are created by the Biosense Webster® CARTO™ 3 device and stored on the Bard® LabSystem™ PRO EP Recording System for review and insertion into the final clinical report. I Integration also supports bidirectional communication of stimulation pacing channel selection and information sharing between the two systems.
#### Contraindications: None
Prescription Use イ (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
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2 May 2014
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.