Bioflux Software II

K201040 · Biotricity · DSH · Jul 29, 2020 · Cardiovascular

Device Facts

• Record ID: K201040
• Device Name: Bioflux Software II
• Applicant: Biotricity
• Product Code: DSH · Cardiovascular
• Decision Date: Jul 29, 2020
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 870.2800
• Device Class: Class 2
• Attributes: Software as a Medical Device

Intended Use

Bioflux Software II is intended to be used to view and annotate data acquired from diagnostic ECG sources of 1 to 3-leads. Bioflux Software II is operated in a web browser and data is accessed via the users' credentials on the hardware platform running the web browser. It will be used by cardiologists, general practitioners, cardiac, ECG technicians, nurses, monitoring service technicians, and other cardiac related institutions. Bioflux Software II will be used in independent clinical testing facilities. clinics, hospitals, physician's offices, or anywhere a physician or qualified practitioners deem appropriate. Bioflux Software II does not offer diagnosis, or medical alarms. It is intended that competent human intervention be involved before any impact on health occurs. Clinical judgement and experience are used to check and interpret the data.

Device Story

Browser-based ECG viewer; displays 1-3 lead ECG records; enables manual annotation, storage, and reporting. Inputs: ECG files via manual upload or API integration from third-party devices. Operation: runs in Chrome/Firefox; user accesses data via credentials. Output: visual ECG waveforms on monitor or printed reports. Usage: clinical settings (hospitals, clinics, physician offices) by trained clinicians (cardiologists, technicians, nurses). Clinical utility: provides tools for manual interval measurement and beat analysis; supports clinical decision-making by facilitating review of diagnostic data. Benefits: enables efficient remote or local review of ECG recordings; ensures human oversight in interpretation.

Clinical Evidence

Bench testing only. No clinical data presented. Verification activities included scenario validations, beat marker confirmation testing, and functional testing across supported web browsers (Chrome and Firefox). Device complies with AAMI EC11, AAMI EC38, IEC60601-2-25, and IEC60601-2-47 standards.

Technological Characteristics

Browser-based software; compatible with Google Chrome and Firefox (2018+). Supports JSON ECG data formats. Features manual beat calipers and horizontal calipers for heart rate averaging. Complies with IEC60601-2-47 and IEC60601-2-25. Operates on standard hardware platforms via web browser.

Indications for Use

Indicated for viewing and annotating 1 to 3-lead diagnostic ECG data. Used by cardiologists, GPs, cardiac/ECG technicians, nurses, and monitoring technicians in clinical facilities, hospitals, or physician offices. No diagnosis or medical alarms provided; requires human interpretation.

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.

Predicate Devices

• Bioflux Software (K162571)

Submission Summary (Full Text)

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July 29, 2020

Biotricity Spencer Ladow VP of Engineering 275 Shoreline Drive, Suite 150 Redwood City, California 94065

Re: K201040

Trade/Device Name: Bioflux Software II Regulation Number: 21 CFR 870.2800 Regulation Name: Medical Magnetic Tape Recorder Regulatory Class: Class II Product Code: MWJ Dated: June 29, 2020 Received: July 2, 2020

Dear Spencer Ladow:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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

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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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email ([e-mail]) or phone [phone] or 301-796-7100).

Sincerely,

Jennifer Shih Assistant Director Division of Cardiac Electrophysiology, Diagnostics and Monitoring Devices Office of Cardiovascular Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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### Indications for Use

510(k) Number (if known) K201040

Device Name Bioflux Software II

#### Indications for Use (Describe)

Bioflux Software II is intended to be used to view and annotate data acquired from diagnostic ECG sources of 1 to 3leads. Bioflux Software II is operated in a web browser and data is accessed via the users' credentials on the hardware platform running the web browser. It will be used by cardiologists, general practitioners, cardiac, ECG technicians, nurses, monitoring service technicians, and other cardiac related institutions.

Bioflux Software II will be used in independent clinical testing facilities. clinics, hospitals, physician's offices, or anywhere a physician or qualified practitioners deem appropriate.

Bioflux Software II does not offer diagnosis, or medical alarms. It is intended that competent human intervention be involved before any impact on health occurs. Clinical judgement and experience are used to check and interpret the data.

| Type of Use (Select one or both, as applicable) | |
|------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------|
| <div style="display:flex; align-items:center;"><span style="font-size:20px;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D)</div> | <div style="display:flex; align-items:center;"><span style="font-size:20px;">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C)</div> |

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# 510(k) SUMMARY (as required by 807.92)

# 1. SUBMITTER

Biotricity

275 Shoreline Drive, Suite 150

Redwood City CA 94065

1-650-832-1626

Contact: Spencer LaDow

Date Prepared: June 28, 2020

## 2. DEVICE

Name of Device: Bioflux Software II Classification Name: Medical Magnetic Tape Recorder Classification Number: 21 CFR 870.2800 Device Panel: Cardiovascular Regulatory Class: Class II Product Code: MWJ

# 3. PREDICATE DEVICE

Name of Device: Bioflux Software Classification Name: Medical Magnetic Tape Recorder Classification Number: 21 CFR 870.2800 Device Panel: Cardiovascular Regulatory Class: Class II Product Code: DSH 510(k): K162571

## 4. DEVICE DESCRIPTION

Bioflux Software II is a browser based ECG viewer software that displays ECG records and provides tools for trained clinicians to annotate (store, retrieve and report) those ECG

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recordings. It is utilized by manually opening ECG files of supported formats or through an API that allows for third parties to integrate their devices and directly push ECG files into the viewer.

Bioflux Software II fulfills all of the following:

- 1. It is a cardiology software product, running locally in a browser.
- 2. Bioflux Software II operates on 2018 or later versions of Chrome and Firefox browsers.
- 3. The data can be opened manually or entered via keyboard, mouse or touchscreen where upon it gets opened in the browser for viewing and storage.
- 4. Information can be displayed on the computer monitor or printed on paper using the web browser.

## 5. Indications for USE

Bioflux Software II is intended to be used to view and annotate data acquired from diagnostic ECG sources of 1 to 3-leads. Bioflux Software II is operated in a web browser and data is accessed via the users' credentials on the hardware platform running the web browser. It will be used by cardiologists, general practitioners, cardiac, ECG technicians, nurses, monitoring service technicians, and other cardiac related institutions.

Bioflux Software II will be used in independent clinical testing facilities, clinics, hospitals, physician's offices, or anywhere a physician or qualified practitioners deems appropriate.

Bioflux Software II does not offer diagnosis, or medical alarms. It is intended that competent human intervention be involved before any impact on health occurs. Clinical judgement and experience are used to check and interpret the data.

| Product/<br>510(k) # | BioFlux Software II/<br>K201040 (under review) | BioFlux Software/<br>K162571 |
|----------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | Bioflux Software II is intended to be used<br>to view and annotate data acquired from<br>diagnostic ECG sources of 1 to 3-leads.<br>Bioflux Software II is operated in a web<br>browser and data is accessed via the users'<br>credentials on the hardware platform<br>running the web browser. It will be used<br>by cardiologists, general practitioners,<br>cardiac, ECG technicians, nurses,<br>monitoring service technicians, and other<br>cardiac related institutions. | Bioflux software is intended to be used to<br>analyze, view, and report ECG data acquired<br>from a variety of ECG sources including<br>single and 3-lead ECG devices. Bioflux<br>software is operated locally in a browser and<br>data is accessed via the users' credentials on<br>the hardware platform running the browser.<br>It will be used by cardiologists, general<br>practitioners, cardiac, or ECG technicians,<br>nurses, monitoring service technicians, and<br>other cardiac related institutions, or care<br>givers, in independent clinical testing<br>facilities, clinics, hospitals, physician's<br>offices, or anywhere a physician or qualified<br>non-physician practitioners deems<br>appropriate. |
| | Bioflux Software II will be used in<br>independent clinical testing facilities,<br>clinics, hospitals, physician's offices, or<br>anywhere a physician or qualified<br>practitioners deem appropriate. | |
| | Bioflux Software II does not offer<br>diagnosis, or medical alarms. It is intended | Bioflux software does not offer diagnosis, or<br>medical alarms. It is intended that<br>competent human intervention be involved |

#### Indications for Use Comparison Table:

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| that competent human intervention be<br>involved before any impact on health<br>occurs. Clinical judgement and experience<br>are used to check and interpret the data. | before any impact on health occurs. Clinical<br>judgement and experience are used to check<br>and interpret the data. |
|------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------|
|------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------|

# 6. SUMMARY OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATED DEVICE

The Bioflux Software II is substantially equivalent in intended use and similar technological characteristics of Bioflux Software cleared under K162571.

| Category | Bioflux Software II | Bioflux Software |
|----------------------------------------------------------------------------------------------|--------------------------------------------------------------|-----------------------------------------------------------------------|
| 510(k) Number | K201040 | K162571 |
| Classification Name | Medical Magnetic Tape Recorder | Medical Magnetic Tape Recorder |
| Classification Number | 21 CFR 870.2800 | 21 CFR 870.2800 |
| Product Code | MWJ | DSH |
| Intended Use | View and annotate data acquired from diagnostic ECG sources. | Analyze, view and report data acquired from a variety of ECG sources. |
| The ECG Viewer will meet the IEC60601-2-47. | Yes | Yes |
| The ECG Viewer will meet the IEC60601-2-25 Standard. | Yes | Yes |
| ECG viewer will view and annotate data acquired from diagnostic ECG sources of 1 to 3-leads. | Yes | Yes |
| ECG viewer will be compatible with web browsers | Yes– Google Chrome and FireFox 2018 | Yes- Google Chrome and FireFox 2015 |
| Software will support import of ECG data formats. | Yes- JSON | Yes- GVX, MIT, RES, SCP |
| Interval Measurement | Yes - manual | Yes - automated |
| Beat Caliper, Manual tool to place six vertical | Yes | Yes |

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| lines and adjust<br>beat calipers. | | |
|----------------------------------------------------------------|-----|------------------------------------------------------------------------|
| Horizontal<br>Caliper Heart<br>Rate Averaging,<br>Manual tool. | Yes | No - Bioflux software does not have<br>this manual horizontal caliper. |

# 7. PERFORMANCE TESTING

The Bioflux Software II device was tested and complies with AAMI EC11, AAMI EC38, IEC60601-2-25 and IEC60601-2-47 standards. The Bioflux Software II was verified in both of its operating environments of Firefox and Google Chrome. Verification activities related to the device modification were performed on the applicant device, and the predetermined acceptance criteria were met in all cases. The activities included scenario validations, beat marker confirmation testing, and device functional testing.

## 8. CONCLUSIONS

The conclusions drawn from the indications for use and testing demonstrates that Bioflux Software II exhibits comparable indications for use, technological, and design characteristics to the predicate (Bioflux Software). Based on this, the Bioflux Software II is as safe, and effective, and performs as well as the legally marketed device predicate. The Bioflux Software II is substantially equivalent to the predicate device.