K152626 · Mortara Instrument, Inc. · MWJ · Feb 26, 2016 · Cardiovascular
Device Facts
Record ID
K152626
Device Name
H3+ Holter Recorder
Applicant
Mortara Instrument, Inc.
Product Code
MWJ · Cardiovascular
Decision Date
Feb 26, 2016
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 870.2800
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The H3+ Holter recorder is intended to acquire, record and store continuous ECG data as directed by a clinician from adult, adolescent, pediatric, infant and neonate patient populations for a maximum recording time of 14 days in a hospital, clinic or home environment. The H3+ is intended to be used with a compatible ambulatory ECG (Holter) analysis system which will analyze the recorded data. The H3+ data and the data analysis are then reviewed by trained medical personnel for the purpose of forming a clinical diagnosis. The H3+ Holter Recorder is not a life-supporting device.
Device Story
H3+ Holter Recorder is a small, lightweight, battery-powered device for continuous multi-day ECG data acquisition and storage. It features a graphic display for lead connection quality checks and waveform preview, and a patient-activated event button. The device records ECG data to internal non-volatile memory; data is subsequently transferred via USB to a compatible Holter analysis system (e.g., HScribe or Vision). It is operated by clinicians for patient hook-up and by patients for event marking. The recorded data is analyzed by external software and reviewed by medical personnel to assist in clinical diagnosis. The device provides pacemaker spike detection markers. It is not life-supporting.
Clinical Evidence
No clinical data was required to support substantial equivalence. Performance was verified through bench testing, software validation, and compliance with recognized international standards (IEC 60601-1, IEC 60601-2-47, IEC 60601-1-2, IEC 62304).
Technological Characteristics
Digital Holter recorder; 3-channel ECG acquisition; 180 sps sampling rate; 12-bit resolution; 6.25 uV amplitude resolution; internal flash memory storage; USB connectivity; powered by 1 AAA alkaline battery; graphic LCD display; 1-button keypad; compliant with IEC 60601-1, IEC 60601-2-47, and IEC 60601-1-2.
Indications for Use
Indicated for adult, adolescent, pediatric, infant, and neonate patients requiring continuous ECG monitoring for up to 14 days in hospital, clinic, or home settings.
Regulatory Classification
Identification
A medical magnetic tape recorder is a device used to record and play back signals from, for example, physiological amplifiers, signal conditioners, or computers.
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Image /page/0/Picture/1 description: The image shows the logo for the Department of Health & Human Services - USA. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized graphic of three human profiles facing to the right, stacked on top of each other, with flowing lines extending from the bottom profile.
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
February 26, 2016
Mortara Instrument, Inc. Margaret Mucha Director of Global Regulatory Affairs 7865 North 86th St. Milwaukee, Wisconsin 53224
Re: K152626
Trade/Device Name: H3+ Holter Recorder Regulation Number: 21 CFR 870.2800 Regulation Name: Medical Magnetic Tape Recorder Regulatory Class: Class II Product Code: MWJ Dated: December 22, 2015 Received: December 23, 2015
Dear Margaret Mucha:
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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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.
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 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. 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 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 yours,
Mitchell Stein
for Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
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#### Indications for Use
510(k) Number (if known) K152626
Device Name H3+ Holter Recorder
#### Indications for Use (Describe)
The H3+ Holter recorder is intended to acquire, record and store continuous ECG data as directed by a clinician from adult, adolescent, pediatric, infant and neonate patient populations for a maximum recording time of 14 days in a hospital, clinic or home environment. The H3+ performs no analysis by itself and is intended to be used with a compatible ambulatory ECG (Holter) analysis system which will analyze the recorded data. The H3+ data analysis are then reviewed by trained medical personnel for the purpose of forming a clinical diagnosis. The H3+ Holter Recorder is not a life-supporting device.
| Type of Use (Select one or both, as applicable) | |
|--------------------------------------------------------------------------------------|-----------------------------------------------|
| <span style="font-size: 16px;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) | ☐ Over-The-Counter Use (21 CFR 801 Subpart C) |
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Image /page/3/Picture/0 description: The image shows a white heart shape inside of a blue square. The heart shape is formed by two curved lines that meet at the bottom and extend upwards to form the top of the heart. Below the image is the text "K152626".
## Section 5
# 510(k) Summary Statement
## 1. Submitter
| Mortara Instrument, Inc.<br>7865 North 86th Street<br>Milwaukee, WI 53224 | Primary Contact<br>Margaret Mucha<br>Director of Global Regulatory<br>Affairs<br>meg.mucha@mortara.com |
|---------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------|
| Telephone 414-354-1600<br>Fax 414-354-4760 | Secondary Contact<br>Eleanore Dias<br>Regulatory Specialist<br>eleanore.dias@mortara.com |
#### 2. Product Names
Device Trade Name Common/ Usual Name Classification
H3+ Holter Recorder Holter Recorder Medical Magnetic Tape Recorder 870.2800 MWJ Cardiovascular
### 3. Predicate Device to which this is Substantially Equivalent
H3+ Holter Recorder
K043010
#### 1. Device Description
The H3+ Holter Recorder is part of a Holter Analysis system. The H3+ Holter Recorder provides multiple channels of continuous multi-day ECG data recording and pacemaker spike detection markers.
The H3+ Holter Recorder is extremely small and lightweight. The H3+ includes a display that allows the clinician to confirm patient identification, preview the waveform, and check the quality of lead connections during patient hook-up. The H3+ also has a patient activated event button which allows the insertion of event marks into the recorded data if directed by the clinician.
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The H3+ uses a single battery and stores acquired data in digital form on internal, non-volatile memory. Stored data is then imported for analysis at a compatible Holter analysis system [ e.g. HScribe (K004017) or Vision (K945985)]. The recorded data will remain in memory until it has been cleared by the clinician.
The data provided by H3+ to the Holter Analysis system is used by trained medical personnel to assist in the diagnosis of patient conditions.
#### 2. Intended Use
The H3+ Holter recorder is intended to acquire, record and store continuous ECG data as directed by a clinician from adult, adolescent, pediatric, infant and neonate patient populations for a maximum recording time of 14 days in a hospital, clinic or home environment. The H3+ is intended to be used with a compatible ambulatory ECG (Holter) analysis system which will analyze the recorded data. The H3+ data and the data analysis are then reviewed by trained medical personnel for the purpose of forming a clinical diagnosis.
The H3+ Holter Recorder is not a life-supporting device.
#### 3. Technological characteristics
The H3+ is employs the same functional scientific technology as its predicate device H3+ (K043010).
#### 4. Determination of Substantial Equivalence - Non-clinical
The H3+ was designed and tested for compliance with the applicable clauses of the following standards:
- . IEC 60601-1::2012 reprint) -- Medical electrical equipment Part 1: General requirements for basic safety and essential performance
- IEC 62304:2006, Medical device software -- Software life cycle processes ●
- IEC 60601-2-47:2012, Medical Electrical Equipment -- Part 2-47: Particular . Requirements for the Basic Safety and Essential Performance of Ambulatory Electrocardiographic Systems. (Cardiovascular)
- IEC 60601-1-2: 2007, Medical Electrical Equipment part 1: 2. Electromagnetic ● Compatibility
The H3+ was designed and manufactured by Mortara Instrument according to 21 CFR Part 820. The H3+ has undergone software validation as well as performance verification and validation to ensure it meets all design inputs and performance requirements.
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# K152626
The H3+ is substantially equivalent to its predicate device H3+ (K043010) as shown in the table below.
| HOLTER<br>RECORDER<br>MODEL | Predicate Device | Current Device | Change<br>explanation |
|-------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------|
| COMPANY | H3+ version 2.09<br>Mortara Instrument, Inc. | H3+ version 3.0.0<br>Mortara Instrument, Inc. | Identical |
| 510 (K)<br>Number | K043010 | Present Application | NA |
| Indications for<br>Use | The H3+ Holter recorder is<br>intended to acquire, record<br>and store up to 48 hours of<br>ECG data of patients that<br>have been connected to the<br>Mortara H3+ recorder and<br>are undergoing Holter<br>monitoring. The H3+<br>performs no cardiac analysis<br>by itself and is intended to be<br>used with the Mortara H-<br>Scribe Holter analysis<br>system(K0040170) or other<br>compatible Holter Analyzer.<br>ECG data prerecorded by the<br>H3+ is acquired and analyzed<br>by the H-Scribe. In turn the<br>cardiac data and analysis<br>provided by H-Scribe Holter<br>system will be reviewed,<br>confirmed, and used by<br>trained medical personnel in<br>the diagnosis of patients with<br>various rhythm patterns. | The H3+ Holter recorder is<br>intended to acquire, record<br>and store continuous ECG<br>data as directed by a<br>clinician from adult,<br>adolescent, pediatric, infant<br>and neonate patient<br>populations for a maximum<br>recording time of 14 days in<br>a hospital, clinic or home<br>environment. The H3+ is<br>intended to be used with a<br>compatible ambulatory ECG<br>(Holter) analysis system<br>which will analyze the<br>recorded<br>data. The H3+ data and the<br>data analysis are then<br>reviewed by trained medical<br>personnel for the purpose of<br>forming a clinical diagnosis.<br>The H3+ Holter Recorder is<br>not a life-supporting device. | Equivalent,<br>Indications<br>for use<br>updated to<br>include<br>patient<br>population<br>and use<br>environment |
| Type | Digital | Digital | Identical |
| Record<br>duration | 24 and 48 Hours | Up to 14 days | Equivalent<br>technology<br>but larger<br>storage<br>capacity |
| Recording<br>medium | Internal Flash Memory | Internal Flash Memory | Identical |
| Data transfer<br>method | Via USB port | Via USB port | Identical |
| Signal<br>compression | Yes | Yes | Identical |
| Channels | 2 or 3 | 3 | Identical<br>equivalent,<br>removed 2-<br>channel<br>functionality |
| sampling rate | 180 sps | 180 sps | Identical |
| Frequency<br>Response | Meets the requirements of<br>ANSI/AAMI EC38 | Meets the requirements of<br>IEC 60601-2-47 | equivalent |
| HOLTER<br>RECORDER<br>MODEL | Predicate Device<br>H3+ version 2.09 | Current Device<br>H3+ version 3.0.0 | Change<br>explanation |
| Dynamic<br>Range<br>Amplitude (or<br>Digital)<br>Resolution | 12-bit | 12-bit | Identical |
| | 6.25 uV | 6.25 uV | Identical |
| Setup<br>ECG Channel<br>preview | With the graphic display and<br>Enter key / Automatic start<br>after 10 minutes | With the graphic display and<br>Enter key / Automatic start<br>after 10 minutes | Identical |
| | Yes | Yes | Identical<br>equivalent,<br>removed 2-<br>channel<br>functionality |
| Cable | 2-Channel 5-wires or 3-<br>Channel 5-wires | 3-Channel 5-wires | |
| Test Cable | No | No | Identical |
| Impedance<br>measurement | No | No | Identical |
| Power | 1 AAA Alkaline battery up to<br>48 H | 1 AAA Alkaline battery up to<br>14 days | equivalent |
| Pacemaker<br>Detection | Yes | Yes | Identical |
| Display | Graphic LCD | Graphic LCD | Identical |
| Time Displayed | Yes | Yes | Identical |
| Carrying Case | Pouch with Belt clip & strap | Pouch with Belt clip or single-<br>use pouch | Identical<br>reusable<br>pouch; added<br>disposable<br>pouch |
| Keyboard | 1-button keypad | 1-button keypad | Identical |
| Sound | No | No | Identical |
| Patient Event<br>Marker | Yes | Yes | Identical |
| Replay and<br>Analysis<br>system | H-Scribe | HScribe and Vision | equivalent-<br>added H3+<br>support in the<br>Vision<br>product |
| Weight | 28 grams | 28 grams | Identical |
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## 5. Determination of Substantial Equivalence – Clinical
The subject of this premarket notification did not require clinical data to support substantial equivalence
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#### 6. Conclusion
The H3+ Holter Recorder is now able to store data from ambulatory recordings for a maximum of 14 days whereas the previous version of H3+ could only store data for 24 to 48 hours. This change required an updated intended use which is reflected in this submission. Other changes that were incorporated into the H3+ include removal of the 2 channel 5 wires option, compatibility with HScribe and Vision Holter Analysis Systems, updated hardware components that meet the EU Restriction of Hazardous Substances Directive, addition of a Holter Prep kit and single use pouch to the list of accessories, and an added log file for service support for device use if needed.
Mortara has determined these changes did not impact the safety and efficacy of the H3+ Holter recorder. The H3+ Holter Recorder performance is substantially equivalent to the predicate device.
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.