The Cardiac Workstation is intended to acquire multi-channel ECG signals from adult and pediatric patients from body surface ECG electrodes, and to record, display, analyze and store these ECG signals for review by the user. They are to be used in healthcare facilities by trained healthcare professionals. Analysis of the ECG signals is accomplished with algorithms that provide measurements, data presentations, graphical presentations and interpretations for review by the user. The interpreted ECG with measurements and interpretive statements is offered to the clinician on an advisory basis only. It is to be used in conjunction with the clinician's knowledge of the patient, the results of the physical examination, the ECG tracings, and other clinical findings. A qualified physician is asked to over-read and validate (or change) the computer-generated ECG interpretation.
Device Story
Cardiac Workstation 5000/7000 are interpretive cardiographs for hospital/clinic use. Devices acquire multi-channel ECG signals via body surface electrodes; signals are amplified, digitized (24-bit, 1000 SPS), and processed. The Philips DXL ECG Algorithm (PH110C) analyzes up to 18 leads to interpret rhythm and morphology, providing measurements and interpretive statements. Output is displayed on integrated touchscreens (12.1" to 18.5") and can be printed or transmitted via LAN/Wi-Fi to EMR/ECG management systems. Operated by trained healthcare professionals. Interpretations are advisory; require physician validation. Benefits include efficient processing of large ECG volumes and improved diagnostic support through automated analysis.
Clinical Evidence
No clinical studies were conducted. Substantial equivalence is supported by non-clinical bench testing, including software verification, electrical safety (ANSI/AAMI ES60601-1), electromagnetic compatibility (ANSI AAMI IEC 60601-1-2), usability engineering (IEC 62366-1), and cybersecurity validation.
Technological Characteristics
Electrocardiograph with integrated display and printer. 24-bit A/D resolution, 1000 SPS sampling rate, 0.02Hz-300Hz bandwidth. Connectivity: LAN and 802.11ac Wi-Fi. OS: Linux. Safety: Class I, CF type applied part. EMC: Group I, Class B. Algorithm: Philips DXL ECG Algorithm (PH110C).
Indications for Use
Indicated for adult and pediatric patients requiring multi-channel ECG signal acquisition, recording, display, analysis, and storage in healthcare facilities.
Regulatory Classification
Identification
An electrocardiograph is a device used to process the electrical signal transmitted through two or more electrocardiograph electrodes and to produce a visual display of the electrical signal produced by the heart.
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Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, with the letters "FDA" in a blue square. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
December 17, 2024
Philips Medizin Systeme Böblingen GmbH Angel Ya Regulatory Affairs Manager Hewlett-Packard Strasse 2 Böblingen, 71032 Germany
Re: K241556
Trade/Device Name: Cardiac Workstation (5000); Cardiac Workstation (7000) Regulation Number: 21 CFR 870.2340 Regulation Name: Electrocardiograph Regulatory Class: Class II Product Code: DPS Dated: November 19, 2024 Received: November 19, 2024
Dear Angel Ya:
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 (the 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 available 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.
Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device"
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0812(download) and "Dogiding Whon to Submit o 5100) fono Softwong
(https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).
Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30. Design controls; 21 CFR 820.90. Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review. the OS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).
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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.
All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rue"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-devices/device-advicecomprehensive-regulatory-assistance/unique-device-identification-system-udi-system.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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 (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
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Sincerely,
# Jennifer W. Shih -S
Jennifer Kozen 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
Submission Number (if known)
K241556
Device Name
Cardiac Workstation (5000); Cardiac Workstation (7000)
Indications for Use (Describe)
The Cardiac Workstation is intended to acquire multi-channel ECG signals from adult and pediatric patients from body surface ECG electrodes, and to record, display, analyze and store these ECG signals for review by the user. They are to be used in healthcare facilities by trained healthcare professionals. Analysis of the ECG signals is accomplished with algorithms that provide measurements, data presentations, graphical presentations and interpretations for review by the user.
The interpreted ECG with measurements and interpretive statements is offered to the clinician on an advisory basis only. It is to be used in conjunction with the clinician's knowledge of the patient, the results of the physical examination, the ECG tracings, and other clinical findings. A qualified physician is asked to over-read and validate (or change) the computer-generated ECG interpretation.
Type of Use (Select one or both, as applicable)
X Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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# 510(k) Summarv
| 510(k) Summary | | | |
|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------|-----------------|
| I. SUBMITTER | | | |
| Date Prepared | 14 May 2024 | | |
| Submitter/Owner | Philips Medizin Systeme Böblingen GmbH<br>Hewlett-Packard Strasse 2<br>71032 Böblingen<br>GERMANY<br>Phone: +1 (949)-502-1823 | | |
| Key Contact | Angel Ya<br>Regulatory Affairs Mgr.<br>Email: angel.ya@philips.com | | |
| 510(k) Submission Type | This is a Traditional 510(k). | | |
| II. DEVICE | | | |
| Trade Name | Cardiac Workstation 5000 (aka: CW 5000)<br>Cardiac Workstation 7000 (aka: CW 7000) | | |
| Common Name | Cardiograph | | |
| Classification Name | Review Panel: Cardiovascular<br>Regulation Description: Electrocardiograph<br>21 CFR §870.2340<br>Regulatory Class: II<br>Product Code: DPS | | |
| III. PREDICATE DEVICE | | | |
| | 510(k) No. | Company Name<br>Device Name | Product<br>Code |
| Predicate Device | K210560 | Philips Medical Systems<br>PageWriter TC70 Cardiograph | DPS |
| Reference Device | K221141 | Philips Medizin Systeme<br>Böblingen GmbH<br>PageWriter TC35 Cardiograph | DPS |
| The Philips Cardiac Workstation 5000 and Cardiac Worksation 7000 are substantially equivalent to the<br>legally marketed predicate, PageWriter TC70 Cardiograph (K210560). | | | |
| IV. DEVICE DESCRIPTION | | | |
| Cardiac Workstation 5000 and Cardiac Workstation 7000 – description of the device per 21 CFR | | | |
Image /page/4/Picture/5 description: The image shows the Philips logo, which is a blue shield shape. Inside the shield, the word "PHILIPS" is written in white at the top. Below the text, there are two wavy lines and two stars, also in white. The overall design is simple and recognizable, representing the brand's identity.
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# 807.92(a) (4)
The Cardiac Workstation 5000 (aka: CW 5000) and Cardiac Workstation 7000 (aka: CW 7000) are intended to acquire multi-channel ECG signals from adult and pediatric patients from body surface ECG electrodes, and to record, display, analyze and store these ECG signals for review by the user. They are to be used in healthcare facilities by trained healthcare professionals. Analysis of the ECG signals is accomplished with algorithms that provide measurements, data presentations, graphical presentations for review by the user.
The interpreted ECG with measurements and interpretive statements are offered to the clinician on an advisory basis only. They are to be used in conjunction with the clinician's knowledge of the results of the physical examination, the ECG tracings, and other clinical findings. A qualified physician is asked to over-read and validate (or change) the computer-generated ECG interpretation.
The CW 5000 and CW 7000 are mid- and high-range interpretive cardiographs, differing primarily in display size, the number of standard options. Both devices offer a full array of features built on the Linux operating system, with touch screen operation, a configurable feature set, and interpretation from the clinically proven Philips DXL ECG Algorithm (K132068). They provide a cardiograph solution for hospitals and cardiology clinics in processing large volumes of ECGs. The DXL ECG algorithm in the software analyzes up-to 18 leads of simultaneously acquired ECG waveform to interpret rhythm and morphology for a variety of patient populations. The measurements are then analyzed by the DXL ECG Algorithm. The resulting ECG reports may include ECG measurements, reasons, or analysis statements. The algorithm covers both adult and pediatric populations.
The CW 5000 and CW 7000 consist of the following:
- An electrocardiograph device with integrated display and printer. CW 5000 provides 12.1'' display . panel. CW 7000 provides 15.6″ and 18.5″ options for the display panel.
- Optional Trolley (ordered via a separate part number)
The subject devices are further structured with options relating to software. Ul language, keyboard locale, and a wide range of other configuration choices to optimize the user's experience with the devices.
Image /page/5/Picture/11 description: The image shows the Philips logo, which is a blue shield with the word "PHILIPS" at the top. Inside the shield, there are two wavy lines and two four-pointed stars. The logo is simple and recognizable, representing the brand's identity.
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#### V. INDICATIONS FOR USE
| Comparison of Indications for Uses for Subject Device and Predicate | | |
|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------|
| PageWriter TC70 Cardiograph<br>Predicate, K210560 | Cardiac Workstation 5000 (aka: CW 5000)<br>Cardiac Workstation 7000 (aka: CW 7000)<br>Subject Device | Description of<br>differences |
| Philips PageWriter TC70 cardiograph is<br>intended to acquire multichannel ECG<br>signals from adult and pediatric patients<br>from body surface ECG electrodes and to<br>record, display, analyze and store these ECG<br>signals for review by the user. It is to be used<br>in healthcare facilities by trained healthcare<br>professionals. Analysis of the ECG signals is<br>accomplished with algorithms that provide<br>measurements, data presentations,<br>graphical presentations and interpretations<br>for review by the user. | The Cardiac Workstation is intended to acquire<br>multi-channel ECG signals from adult and pediatric<br>patients from body surface ECG electrodes, and to<br>record, display, analyze and store these ECG<br>signals for review by the user. They are to be used<br>in healthcare facilities by trained healthcare<br>professionals. Analysis of the ECG signals is<br>accomplished with algorithms that provide<br>measurements, data presentations, graphical<br>presentations and interpretations for review by<br>the user. | Identical except<br>for change to<br>product name. |
| The interpreted ECG with measurements and<br>interpretive statements is offered to the<br>clinician on an advisory basis only. It is to be<br>used in conjunction with the clinician's<br>knowledge of the patient, the results of the<br>physical examination, the ECG tracings, and<br>other clinical findings. A qualified physician is<br>asked to over read and validate (or change)<br>the computer generated ECG interpretation. | The interpreted ECG with measurements and<br>interpretive statements is offered to the clinician<br>on an advisory basis only. It is to be used in<br>conjunction with the clinician's knowledge of the<br>patient, the results of the physical examination,<br>the ECG tracings, and other clinical findings. A<br>qualified physician is asked to over-read and<br>validate (or change) the computer-generated ECG<br>interpretation. | |
#### COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE VI.
| Similarities | |
|---------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Item of Comparison | Description/Rationale |
| Indications for use | The CW 5000 and CW 7000 subject devices and the currently marketed predicate<br>device (K210560) PageWriter TC70 Cardiograph have the identical indications for<br>use. Both CW 5000 and CW 7000 and TC70 are intended to acquire multi-channel<br>ECG signals from patient and to record, display and store those signals to be<br>review by the user. The use environment is identical between CW 5000, the CW<br>7000, and the predicate device, TC70. They are all to be used in healthcare<br>facilities by professionals. |
Image /page/6/Picture/7 description: The image shows the Philips logo, which is a blue shield shape. Inside the shield, the word "PHILIPS" is written in white at the top. Below the text, there are two wavy lines and two four-pointed stars. The logo is simple and recognizable, representing the brand's identity.
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Image /page/7/Picture/0 description: The image shows the word "PHILIPS" in large, bold, blue letters. The letters are evenly spaced and appear to be a sans-serif font. The image is simple and focuses solely on the brand name.
| Fundamental scientific<br>technologies and<br>performances | Both CW 5000 and CW 7000 and PageWriter TC70 Cardiograph are similar with<br>respect to the fundamental scientific technologies. They are<br>electrocardiographs that collect multi-channel ECG signals of adult and<br>pediatric patients from body surface ECG electrodes. These ECG signals are<br>amplified, digitized, and processed in the digital domain. The cardiograph<br>records, displays, analyzes (through the cleared ECG algorithm in K132068),<br>and prints the processed ECG signals for review by the clinical operator.<br><br>The CW 5000 and CW 7000 use the same fundamental design as the TC70, but<br>also contain improvements to the user's experience by deploying updated<br>hardware and software technologies. The devices also incorporate minor<br>changes to the ECG signal processing approach and security improvements to<br>comply with widely recognized standards. Both devices use the same cleared<br>ECG algorithm (PH110C) for ECG measurement and interpretation. | |
|------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------|
| Patient Type | Adult and pediatric patients | |
| Patient Data Cable | The subject devices use the same patient cable cleared under K080999 with the<br>predicate device, PageWriter TC70 Cardiograph. The latest 510k for the<br>predicate device is K210560. | |
| Use Environment | The use environment is identical between the subject CW 5000 and CW 7000<br>devices and the predicate device (K210560) PageWriter TC70 Cardiograph. They<br>are intended for use in a professional healthcare facility. They are not for home<br>use, and not intended to be used together with any RF emitting equipment such<br>as high-frequency electrosurgical equipment, diathermy, or electrocautery. | |
| Connectivity | The subject CW 5000 and CW 7000, like the predicate device (K210560)<br>PageWriter TC70 Cardiograph, provide LAN and wireless connectivity. This<br>functionality is used to transmit ECG reports, patient order/ADT info, device<br>configuration details, and time sync between the Cardiac Workstation and ECG<br>Management Systems, Device Management Dashboard, and the hospital's EMR. | |
| ECG Performance | Compared to the predicate device (K210560), PageWriter TC70 Cardiograph, the<br>subject CW 5000 and CW 7000 devices provide similar performance on ECG<br>acquisition of up to 18 leads, algorithm interpretation, display accuracy, and ECG<br>report formats for printing and transmission purposes. | |
| Safety and EMC performance | The subject CW 5000, CW 7000, and predicate device (K210560) PageWriter<br>TC70 Cardiograph have the same level of safety and EMC performance. The<br>safety classification of both subject and predicate device (K210560) is class I, with<br>CF type of applied part. The EMC emission classification is Group I, Class B. | |
| Differences | | |
| Item of Comparison | Description/Rationale | |
| Physical features and parameters | The CW 5000 and CW 7000 device's physical features and size are similar to the predicate device (K210560) PageWriter TC70 Cardiograph. A picture of the subject devices and predicate is provided below. | |
| | Image: Cardiac Workstation 5000 | Image: Cardiac Workstation 7000 |
| | Image: Philips TC70 Cardiograph | |
| | Compared to the predicate device (K210560), the Cardiac Workstations have a similar product configuration, including an LCD touch screen, embedded printer, power supply module, PIM and Trolley. The CWs have an array of touchscreen options (12.1 in for CW5000, 15.6 in and 18.5 in for CW7000) and 2 optional trolley types: height-adjustable and fixed-height. The external ports are similar. The rear of the device provides the USB ports and connectors for LAN, PIM, and power cord. The right side houses the battery compartment door, and the left side has the paper drawer. | |
| ECG signal acquisition | Compared to the predicate device, PageWriter TC70 Cardiograph (K210560), the Cardiac Workstations provide improved ECG A/D signal processing resolution from 12 to 24 bit. The digital data processing rate has improved from 500 to 1000 SPS (Samples Per Second). ECG signal bandwidth has been improved from 0.05Hz~150 Hz to 0.02Hz~300 Hz. The subject device also supports the latest Philips ECG XML schema 1.04.04. The improved digital data processing and filter range are identical with reference device, Pagewriter TC35 (K221141). | |
| Radio connection | Compared to the predicate device, PageWriter TC70 Cardiograph (K210560), the wireless module used for the subject device provides updated compatibility to support communication protocol 802.11 ac (WiFi 5). The wireless module, wireless function, specification, transmitting data, and connecting system/application at the hospital environment are the same as the reference device, Pagewriter TC35 (K221141). | |
| Security Enhancement | Compared to the predicate device, PageWriter TC70 Cardiograph (K210560), the subject device provides improved cybersecurity risk control. The operating system has been changed from the "end of support" WinCE5/WinCE7 OS to the supported Linux OS. The device supports FIPS 140-2 for data encryption, user authentication, USB disk encryption and digital signature, and supports SMB | |
Image /page/7/Picture/4 description: The image shows the Philips logo, which consists of the word "PHILIPS" in a sans-serif font above a stylized shield-like shape. The shield is blue and contains two wavy lines that resemble sound waves or water. There are also four stars within the shield, two above the waves and two below, adding a celestial or technological element to the design.
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Image /page/8/Picture/0 description: The image shows the word "PHILIPS" in a large, sans-serif font. The word is written in a solid blue color. The letters are evenly spaced and the overall appearance is clean and modern.
Image /page/8/Picture/4 description: The image shows the Philips logo. The logo is a blue shield with the word "PHILIPS" in white at the top. Below the word are two wavy lines and two stars. The wavy lines are white, and the stars are white with a blue outline.
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V2/V3. The improved performance is identical to the reference device, Pagewriter TC35 (K221141).
### Substantial Equivalence Summary
Analysis of operational, technological and safety characteristics form the basis for the determination of substantial equivalence of the subject device, Cardiac Workstation 5000 and Cardaic Worksation 7000, with the legally marketed predicate device (K210560). The Cardiac Workstation 5000 and Cardiac Workstation 7000 are substantially equivalent to the predicate device.
#### PERFORMANCE DATA VII.
### Non-Clinical Tests – Harmonized Standards
The subject Cardiac Workstation 5000 and Cardiac Workstation 7000 have passed all safety, electromagnetic compatibility, and cybersecurity tests to demonstrate compliance with the harmonized standards below.
| Standard | FDA<br>Recognition # | Title |
|-----------------------------------------------------------------------------------------------------------------|----------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| ANSI/AAMI ES60601-<br>1:2005/A1:2012,<br>C1:2009/(R)2012 &<br>A2:2010/(R)2012 (Cons.<br>Text) [Incl. AMD2:2021] | 19-46 | Medical electrical equipment. Part 1: General requirements for basic<br>safety and essential performance |
| ANSI AAMI IEC 60601-1-<br>2:2014 [Including AMD<br>1:2021] | 19-36 | Medical electrical equipment. Part 1-2: General requirements for<br>basic safety and essential performance. Collateral<br>standard: Electromagnetic compatibility. Requirements and tests |
| ANSI AAMI IEC 60601-2-<br>25:2011/(R)2016 | 3-105 | Medical electrical equipment - Part 2-25: Particular requirements for<br>the basic safety and essential performance of electrocardiographs |
| IEC 60601-1-6:<br>2010+A1:2013+A2: 2020 | 5-132 | Medical electrical equipment - Part 1-6: General requirements for<br>basic safety and essential performance - Collateral standard:<br>Usability |
| IEC 62366-1: 2015+A1:<br>2020 | 5-129 | Medical devices. Part 1: Application of usability engineering to<br>medical devices |
| ANSI AAMI IEC<br>62304:2006/A1:2016 | 13-79 | Medical device software - Software life cycle processes |
| ANSI C63.27:2021 | 19-48 | American National Standard for Evaluation of Wireless<br>Coexistence |
Image /page/9/Picture/10 description: The image shows the Philips logo, which is a blue shield shape with the word "PHILIPS" at the top. Inside the shield, there are two wavy lines and two four-pointed stars. The logo is simple and recognizable, representing the brand's identity.
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Image /page/10/Picture/0 description: The image shows the word "PHILIPS" in large, bold, blue letters. The font is sans-serif and the letters are evenly spaced. The word is centered and takes up most of the frame.
| AAMI<br>TIR69:2017/(R2020) | 19-22 | Technical Information Report Risk management of radio-frequency<br>wireless coexistence for medical devices and systems |
|----------------------------|--------|------------------------------------------------------------------------------------------------------------------------------------|
| ASTM D4169:2022 | 14-576 | Standard Practice for Performance Testing of Shipping Containers and<br>Systems |
| ISO 14971:2019 | 5-125 | Medical devices - Application of risk management to medical devices |
| AIM 7351731:2021 | 19-45 | Medical Electrical Equipment and System Electromagnetic<br>Immunity Test for Exposure to Radio Frequency Identification<br>Readers |
| ISO 15223-1:2021 | 5-134 | Medical devices - Symbols to be used with information to be supplied<br>by the manufacturer - Part 1: General requirements |
| ISO 20417:2021 | 5-135 | Medical devices - Information to be supplied by the manufacturer |
## Non-clinical Bench Tests
Non-clinical bench testing activities established the performance, functionality, and reliability characteristics of the subject Cardiac Workstation 5000 and Cardiac Workstation 7000. This testing covered verification of performance in the domains of software, environment, reliability, mechanical, hardware, packaging, human factors and usability performance. The Cardiac Workstation 5000 and Cardiac Workstation 7000 were evaluated against all applicable external standards and successfully passed all verifications and validations. The results demonstrate that Cardiac Workstation 5000 and Cardiac Workstation 7000 meet the performance claims and support a determination of substantial equivalence to the predicate PageWriter TC70 Cardiograph (K210560).
## Clinical Studies
The Cardiac Workstation 5000 and Cardiac Workstation 7000, like the predicate device (K210560), did not require clinical studies to demonstrate substantial equivalence.
FDA recognized standards, FDA guidance documents, harmonized standards, verification and validation, software validation, usability validation, and risk management activities have all been applied/conducted for the Cardiac Workstation 5000 and Cardiac Workstation 7000.
Based upon the design, indications for use, classification, usability, and safety testing, the Cardiac Workstation 5000 and Cardiac Workstation 7000 are substantially equivalent to the predicate device (K210560).
Image /page/10/Picture/10 description: The image shows the Philips logo. The logo is a blue shield shape with the word "PHILIPS" in white letters at the top. Inside the shield, there are two white stars and two white wavy lines. The stars are positioned above and below the wavy lines.
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#### VIII. CONCLUSIONS
The results of the substantial equivalence assessment, evaluated alongside non-clinical bench testing, electrical safety, electromagnetic compatibility, software verification, human factors and usability, demonstrate that the Cardiac Workstation 5000 and Cardiac Workstation 7000 can be considered to be substantially equivalent to the predicate device (K210560). The subject devices perform as intended and have performance characteristics that are substantially equivalent to the PageWriter TC70 Cardiograph predicate device (K210560).
Image /page/11/Picture/5 description: The image shows the Philips logo, which is a blue shield shape. Inside the shield, there are two wavy lines and two four-pointed stars. The word "PHILIPS" is written in blue at the top of the shield.
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Part 1 — Search, results, and everyday workflows 16 min
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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.