MARS UNITY WORKSTATION WITH HEART RATE VARIABILITY (HRV) OPTION
K991786 · General Electric Medical Systems Information Techn · DPS · Nov 18, 1999 · Cardiovascular
Device Facts
Record ID
K991786
Device Name
MARS UNITY WORKSTATION WITH HEART RATE VARIABILITY (HRV) OPTION
Applicant
General Electric Medical Systems Information Techn
Product Code
DPS · Cardiovascular
Decision Date
Nov 18, 1999
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 870.2340
Device Class
Class 2
Attributes
Software as a Medical Device, Pediatric
Indications for Use
The MARS Unity Workstation is intended to acquire, analyze, edit, review, report and store ambulatory and monitoring network ECG and multiparameter data. The MARS Unity Workstation is intended to be used by trained operators under the direct supervision of a licensed health care practitioner in a hospital or clinic environment. Patient population includes both adult and pediatric. The Heart Rate Variability (HRV) Option is intended to be used for the analysis of the variability in RR intervals (heart rate) and to report measurements of the variability heart rate data. Heart Rate Variability (HRV) Option is intended to provide only HRV measurements and is not intended to produce any interpretation of those measurements or any kind of diagnosis. The HRV measurements produced by Heart Rate Variability (HRV) Option are intended to be used by qualified personnel in evaluating the patient in conjunction with patient's clinical history, symptoms, other diagnostic tests, as well as the professional's clinical judgement. The HRV feature of this device has not been shown to be safe and effective for a specific clinical diagnosis.
Device Story
MARS Unity Workstation is an off-the-shelf computer platform for Holter analysis and clinical review of ECG and multiparameter data; inputs include data from solid-state electronic ECG recorders, tape recorders, and real-time monitoring networks. The system performs acquisition, analysis, editing, review, reporting, and storage. The HRV software option calculates RR interval variability using Time Domain (simple statistics) or Spectral mode (power spectrum). Used in hospitals or clinics by trained operators under physician supervision. Output consists of ECG waveforms and HRV measurements; clinicians use these to support clinical judgment alongside patient history and other tests. The device does not provide automated diagnosis or interpretation of HRV data.
Clinical Evidence
No clinical data. Bench testing only, including risk analysis, requirements specification reviews, code inspections, software and hardware testing, safety testing, environmental testing, and final validation.
Technological Characteristics
Off-the-shelf computer hardware platform. Software-based analysis of ECG and multiparameter data. HRV analysis via Time Domain (statistical) or Spectral (power spectrum) modes. Connectivity via monitoring network. No specific materials or sterilization methods described as the device is a workstation.
Indications for Use
Indicated for adult and pediatric patients requiring acquisition, analysis, and review of ambulatory and network ECG and multiparameter data. HRV option provides RR interval variability measurements for use by qualified personnel as an adjunct to clinical evaluation; not indicated for automated diagnosis.
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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## nav 1 8 12:20
## Section 2 Summary and Certification
## 2.1 510(k) Summary of Safety and Effectiveness
| Date: | May 24, 1999 | |
|-----------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Submitter: | GE Marquette Medical Systems<br>8200 West Tower Avenue<br>Milwaukee, WI 53223 USA | |
| Contact Person: | Laura L McComis<br>Corporate Regulatory Affairs<br>GE Marquette Medical Systems<br>Phone: (414) 362-2688<br>Fax: (414) 355-3790 | |
| Device: | Trade Name: | MARS Unity Workstation with Heart Rate Variability (HRV) Option |
| Common/Usual Name: | | Holter Analysis System |
| Classification Names: | | Classification Name: Computer, Diagnostic, Programmable<br>Classification Number: 74DQK |
| Predicate Devices: | | K922171 CENTRA II Analysis System<br>K950779 Spacelabs Heart Rate Variability Software Option |
| Device Description: | | The Multi-Parameter Analysis and Review System (MARS) unity<br>workstation is an off-the-shelf computer hardware platform that<br>supports a number of software applications including Holter<br>analysis and editing system software and full disclosure clinical<br>review software.<br><br>1) The Holter analysis software performs acquisition, analysis,<br>editing, review, reporting and storage of ambulatory ECG<br>and multiparameter data acquired from solid-state electronic<br>ECG recorders, tape recorders and the monitoring real-time<br>network.<br><br>2) The clinical review software (CRS) is a full disclosure system<br>that acquires ECG and mixed parameter waveform data<br>from Marquette's Unity monitoring network for display and<br>reporting.<br><br>Heart Rate Variability (HRV) Option is a software option for<br>Marquette Holter analysis systems which measures the variation<br>from one cardiac cycle to the next, utilizing specific morphology.<br>Heart rate variability can be analyzed using either the Time<br>Domain mode, which quantifies variations using simple statistics,<br>or the Spectral mode, which characterizes interval variations as<br>a power spectrum. |
| Intended Use: | The MARS Unity Workstation is intended to acquire, analyze, edit,<br>review, report and store ambulatory and monitoring network<br>ECG and multiparameter data. The MARS Unity Workstation is<br>intended to be used by trained operators under the direct<br>supervision of a licensed health care practitioner in a hospital or<br>clinic environment. Patient population includes both adult and<br>pediatric.<br><br>The Heart Rate Variability (HRV) Option is intended to be used for<br>the analysis of the variability in RR intervals (heart rate) and to<br>report measurements of the variability heart rate data.<br><br>Heart Rate Variability (HRV) Option is intended to provide only<br>HRV measurements and is not intended to produce any<br>interpretation of those measurements or any kind of diagnosis.<br><br>The HRV measurements produced by Heart Rate Variability (HRV)<br>Option are intended to be used by qualified personnel in<br>evaluating the patient in conjunction with patient's clinical<br>history, symptoms, other diagnostic tests, as well as the<br>professional's clinical judgement.<br><br>The HRV feature of this device has not been shown to be safe<br>and effective for a specific clinical diagnosis. | |
| Technology: | MARS Unity Workstation with Heart Rate Variability (HRV) Option<br>employs the same technology as the predicate devices. | |
| Test Summary: | The MARS Unity Workstation with Heart Rate Variability (HRV)<br>Option complies with voluntary standards as detailed in Section 9<br>Specific Standards and Guidances of this submission. The<br>following quality assurance measures were applied to the<br>development of MARS Unity Workstation with Heart Rate<br>Variability (HRV) Option:<br>Risk analysis Requirements specification reviews Code inspections Software and Hardware Testing Safety testing Environmental testing Final validation | |
| Conclusion: | The results of these measures demonstrate MARS Unity<br>Workstation with Heart Rate Variability (HRV) Option is as safe, as<br>effective, and performs as well as the predicate devices, CENTRA<br>IL Analysis System and Spacelabs Heart Rate Variability Software | |
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Option.
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Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is an abstract symbol resembling an eagle or a stylized human figure, composed of three curved lines.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Nov 1 8 1999
Ms. Laura L. McCornis Regulatory Affairs Specialist GE Marquette Medical Systems 8200 W. Tower Avenue Milwaukee, WI 53223
K991786 Re: MARS Unity Workstation with Heart Rate Variability II (two) Requlatory Class: Product Code: DPS Dated: September 17, 1999 Received: September 20, 1999
Dear Ms. McCornis:
We have reviewed your Section 510(k) notification of intent to market the device referenced above and we have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to leqally 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). 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.
If your device is classified (see above) into either class II (Special Controls) or class III (Premarket Approval), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Requlations, Title 21, Parts 800 A substantially equivalent determination assumes compliance to 895. with the Current Good Manufacturing Practice requirements, as set forth in the Quality System Requlation (QS) for Medical Devices: General requlation (21 CFR Part 820) and that, through periodic QS inspections, the Food and Drug Administration (FDA) will verify such assumptions. Failure to comply with the GMP requlation may result in regulatory action. In addition, FDA may publish further announcements concerning your device in the Federal Register. Please note: this response to your premarket notification submission does not affect any obligation you might have under sections 531 through 542 of the Act for devices under the Electronic Product Radiation Control provisions, or other Federal laws or regulations.
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Page 2 - Ms. Laura L. McCornis
This letter will allow you to begin marketing your device as described in your 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling requlation (21 CFR Part 801 and additionally 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4648. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its internet address "http://www.fda.gov/cdrh/dsma/dsmamain.html".
Sincerely yours,
Nancy C. Brogdon for
Celia M. Witten, Ph.D., M.I
Acting Director Division of Cardiovascular, Respiratory, and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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## Section 11 Indications for Use Statement
510(k) Number (if known):
Unknown - 510(k) filed: May 24, 1999
Device Name: Option
MARS Unity Workstation with Heart Rate Variability (HRV)
Indications For Use:
The MARS Unity Workstation is intended to acquire, analyze, edit, review, report and store ambulatory and monitoring network ECG and multiparameter data. The MARS Unity Workstation is intended to be used by trained operators under the direct supervision of a licensed health care practitioner in a hospital or clinic environment. Patient population includes both adult and pediatric.
The Heart Rate Variability (HRV) Option is intended to be used for the analysis of the variability in RR intervals (heart rate) and to report measurements of the variability heart rate data.
Heart Rate Variability (HRV) Option is intended to provide only HRV measurements and is not intended to produce any interpretation of those measurements or any kind of diagnosis.
The HRV measurements produced by Heart Rate Variability (HRV) Option are intended to be used by qualified personnel in evaluating the patient in conjunction with patient's clinical history, symptoms, other diagnostic tests, as well as the professional's clinical judgement.
The HRV feature of this device has not been shown to be safe and effective for a specific clinical diagnosis.
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Image /page/4/Picture/13 description: The image shows the words "Prescription Use" followed by "(Per 21 CFR 801.109)". There is a check mark above the line under the word "Use". The text is in a simple, sans-serif font.
OR
Over-The-Counter Use_
(Optional Format 1-2-96)
Nancy C. Boydon
ascular, Resmiratory,
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.