February 28, 2017: Department of Health & Human Services
February 28, 2017: Department of Health & Human Services
Medtronic, Inc.
Laura Danielson
Principal Regulatory Affairs Specialist
8200 Coral Sea Street Ne
Mounds View, Minnesota 55112
Re: K163008
    Trade/Device Name: Carelink SmartSync Device Manager Pacing System Analyzer
    Regulation Number: 21 CFR 870.3605
    Regulation Name: Pacing System Analyzer
    Regulatory Class: Class II
    Product Code: DTA, DTE
    Dated: January 25, 2017
    Received: January 26, 2017
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 device-
related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in
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.
Page 2 - Laura Danielson
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,
Enclosure
                   DEPARTMENT OF HEALTH AND HUMAN SERVICES                                  Form Approved: OMB No. 0910-0120
                           Food and Drug Administration                                     Expiration Date: January 31, 2017
                                 Indications for Use                                        See PRA Statement below.
Device Name
Carelink SmartSync Device Manager Pacing System Analyzer
                        This section applies only to requirements of the Paperwork Reduction Act of 1995.
                *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*
          The burden time for this collection of information is estimated to average 79 hours per response, including the
          time to review instructions, search existing data sources, gather and maintain the data needed and complete
          and review the collection of information. Send comments regarding this burden estimate or any other aspect
          of this information collection, including suggestions for reducing this burden, to:
                                                  Department of Health and Human Services
                                                  Food and Drug Administration
                                                  Office of Chief Information Officer
                                                  Paperwork Reduction Act (PRA) Staff
                                                  PRAStaff@fda.hhs.gov
                “An agency may not conduct or sponsor, and a person is not required to respond to, a collection of
                                information unless it displays a currently valid OMB number.”
FORM FDA 3881 (8/14)                                        Page 1 of 1                                   PSC Publishing Services (301) 443-6740   EF
                                                                                       Page 1 of 20
510(k) Summary
          Date Prepared:                     January 13, 2017
          510(k) Owner / Address:            Medtronic, Inc.
                                             Cardiac Rhythm and Heart Failure
                                             8200 Coral Sea Street
                                             Mounds View, MN 55112
          Contact:                           Laura L. Danielson
                                             Principal Regulatory Affairs Specialist
          Telephone:                         (763) 526-2385
          Fax:                               (651) 367-0603
          E-mail:                            laura.l.danielson@medtronic.com
          Trade / Proprietary Name:          CareLink SmartSync™ Device Manager
                                             Pacing System Analyzer
          Common Name:                       Pacing System Analyzer
          Classification /                   Class II
          Classification Name:               Pacing System Analyzer
                                             (21 CFR 870.3605)
          Product Code:                      DTA, DTE
Predicate Devices
The intended use, design, materials and performance of the CareLink SmartSync™ Device
Manager Pacing System Analyzer with associated Applications (Models: D00U001, D00U002,
M01G02, M01A02, M01G01, and M01A01), cables (previously approved) and accessories are
substantially equivalent to the following predicate device:
•   Medtronic Model 2290 Lead Analyzer approved on 13MAR2002 P890003/S065.
•   Medtronic Model 5311B A-V Pacing System Analyzer cleared on 07MAY1991 K910595.
Device Description
Device Identification:
The following is a list all key device components included in the submission:
    •   CareLink SmartSync Device Manager base (PSA hardware), Model 24970A
    •   CareLink SmartSync PSA App, Model D00U002
    •   CareLink SmartSync Host, Model D00U001
K163008
                                                                                    Page 2 of 20
K163008
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The following compatible ECG interface cables, ECG cables, and adaptors are available for the
base. These are the same Adaptors and Cables used with the current market approved and
released Model 2290 PSA predicate and are considered medical devices.
ECG cables and leads connect the base to surface electrodes on the patient for the display of live
waveforms. Adaptors allow ECG monitors with phono connectors to be connected to the base.
   •   5437 ECG Interface cable, 6.4 m (20 ft.) – Approved: P890003/S065, 13MAR2002
   •   5437A Adaptor – Approved: P890003/S065, 13MAR2002
   •   2090EC ECG cable, approximately 2.6 m (103 in.) – Approved: P890003/S065,
       13MAR2002
   •   2090ECL ECG cable, approximately 5.5 m (215 in.) – Approved: P890003/S065,
       13MAR2002
   •   9790LA ECG leads, approximately 1 m (40 in.) – Approved: P890003/S027,
       29NOV1994
   •  9790XLA ECG leads, approximately 1 m (40 in.) – Approved: P890003/S027,
      29NOV1994
Medtronic recommends the use of Medtronic-supplied components only. Use of unapproved
components may reduce device effectiveness or impact user or patient safety.
Device Characteristics:
The CareLink SmartSync PSA is comprised of Base, software applications, associated cables and
power cords. The software applications reside on a mobile platform or tablet and pair via
Bluetooth® with the base hardware. The mobile platform is considered non-medical. The
Operating System is also non-medical software that is delivered with and resides on the Mobile
Platform.
The CareLink SmartSync Device Manager base (Model 24970A) is not considered a single-use
device.
The CareLink SmartSync Device Manager base (Model 24970A) is not provided sterile.
Environment of Use:
The base is intended to be used by healthcare professionals only in operating environments under
direct medical supervision.
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                                                                                     Page 4 of 20
   •   ECG cable connections to collect live cardiac waveform data that can be viewed,
       measured, and recorded using the app running on your mobile device.
   •   Bluetooth® wireless technology to communicate with the app running on your mobile
       device.1
The Model 24970A Base contains a microprocessor that maintains the pacing engine logic
function for the PSA.
The PSA hardware within the Base consists of two main integrated circuits (ICs) which provide
a variety of functions as listed below:
   •   Micro Controller Unit: the microprocessor is used to provide timing support and also
       onboard memory for the device.
   •   Mixed Signal Integrated Circuit: the mixed signal IC chip takes the input signals from the
       cables (connected to a lead) and digitizes it for use by the device. This IC is also
       responsible for the electrogram (EGM) waveform and power management.
The App is the primary user interface for the device manager system. The App for the CareLink
SmartSync PSA is comprised of four main components:
   • A Host Application component that provides the system user interface necessary to
      initialize, and set-up the CareLink SmartSync Device Manager and launch the PSA
      Clinician Application
   • a Platform Application component for the transfer/exchange, storage/retrieval,
      electronic conversion, and electronic display of medical device data
   • a Common Application component that is a collection of software components that are
      utilized by the PSA or Device Applications
   • a PSA Application component that is a Mobile Platform Application that allows user to
      use the PSA device
The App includes these features:
   • Bluetooth® connectivity to pair with the base.
   • Integration with the base to start a lead analysis session.
   • Mobile device connectivity tools for sharing and printing Analyzer reports.
   • Updates to app software using an Internet connection.
The Analyzer tools in the App form the primary user interface to the Base). These tools display
and report on the cardiac lead and ECG data transmitted from the base. Clinicians use this data to
perform these tasks:
    • Analyze electrical performance of cardiac leads during implant.
    • Assess proper placement of cardiac leads during implant.
    • View, measure, and document live cardiac waveforms.
CareLink SmartSync Application Models installed on a clinician’s off-the-shelf non-medical
mobile device. The Operating System is also non-medical software that is delivered with and
resides on the non-medical Mobile Platform.
K163008
                                                                                        Page 5 of 20
The CareLink SmartSync Device Manager provides the essential capabilities for analysis of and
the electrical performance of cardiac leads during device implant in a hospital environment (See
Tables 1 through Table 4).
                         Table 1: PSA Base Physical Characteristics
       Parameter                                        Value
       Footprint                                        548 cm2
       Mass                                             0.91 kg (2.0 lbs.)
       Dimensions H x W x D                             1.8 in x 9.45 in x 8.2 in
       Device identification code                       Device serial number prefix
                                                        “SPM”
       Power Source                                     5V Direct Current provided by
                                                        Medical Grade External Power
                                                        Supply. PSA Battery info in the
                                                        following table.
K163008
                                                                                    Page 6 of 20
Materials of Use
The following is a list of exposed materials included in the manufacture of the Model 24970A:
 Component                  Material
                            Plastic:
                            SABIC LEXAN EXL-9330 Polycarbonate
                            White Resin per Medtronic color chip M954239A001
 Top Enclosure Base         Elastomer Edge:
                            Eraprene A6060N-SP
                            Thermoplastic Elastomer
                            Blue per Pantone 301
                            Plastic:
                            SABIC LEXAN EXL-9330 Polycarbonate
                            White Resin per Medtronic color chip M954239A001
                            Graphics:
 Lid Base                   Pantone 301 Blue
                            Elastomer Edge:
                            Eraprene A6060N-SP
                            Thermoplastic Elastomer
                            Blue per Pantone 301
                            Plastic:
                            SABIC LEXAN EXL-9330 Polycarbonate
 Bottom Enclosure Base      White Resin per Medtronic color chip M954239A001
                            Graphics:
                            Pantone 301 Blue
                            Graphics:
                            Autotex-2(V200)
                            Polyester
                            Button:
 Membrane Keypad Base       Silicone Rubber
                            60 Shore A
                            Clear
                            Top Coat:
                            Polyurethane
                            Per color chip Pantone Cool Grey 8
K163008
                                                                                                           Page 7 of 20
 Component                   Material
 Battery Cover Base          SABIC LEXAN EXL-9330 Polycarbonate
                             White Resin per Medtronic color chip M954239A001
                             Silicone Rubber 70 Shore A
 Foot Rear Base
                             Color: Pantone Cool Grey 8
                             Lexan PC 8B35
 Device Label Base           Polycarbonate
                             Clear
                             Lexan PC 8B35
 QR Code Label
                             Polycarbonate
 Base
                             Clear
                             Hypertronics D02 Housing
 PSA Connector
                             Polyethermide
 Base
                             Black
The device does not include biologics, drugs, or coating additives. The pacing system analyzer is not
intended for patient contact.
                                            AC power requirement
Voltage                                               100–240 VAC nominal
Frequency                                             50/60 Hz nominal
                                                    Battery
Type                                                  AA Alkaline (LR6) or Lithium-ion, non-rechargeable (quantity of 2)
Voltage                                               1.5 V each
Power Supply
USB Cable
K163008
                                                                                                                  Page 8 of 20
Charge cradle
Model                                                           24970A
Voltage                                                         5 V 0.8 A
Power                                                           4W
                                 IEC 60529 Degrees of Protection Provided by Enclosures (IP Code)
Temperature Limits
Operating                                                       8%-80%
Storage                                                         15%-93% at 35°C (95°F
Transport                                                       15%-93% at 35°C (95°F)
                                                              Altitude
Maximum                                                         3000 m
                                                           Connectivity
                                                    Conexus wireless telemetry
Frequency range                                                 402-405 MHz
Modulation frequency                                            Frequency shift key
Output power                                                    25 µW EIRP max
Disposal of the base: Return the base to Medtronic for proper disposal. Contact Medtronic at the address or telephone number on
the back cover for information on returning the base.
                                           Electromagnetic compatibility declaration
The following list of accessories is compliant with the requirements of IEC 60601-1-2.
                          Accessory                                                    Maximum length
K163008
                                                                                                                Page 9 of 20
K163008
                                                                                                               Page 10 of 20
K163008
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Note 1: At 80 MHz and 800 MHz, the higher frequency range applies.
Note 2: These guidelines may not apply in all situations. Electromagnetic propagation is affected by absorption and reflection
from structures, objects, and people.
a
  Field strengths from fixed transmitters, such as base stations for radio (cellular/cordless) telephones and land mobile radios,
amateur radio, AM and FM radio broadcast, and TV broadcast cannot be predicted theoretically with accuracy. To assess the
electromagnetic environment due to fixed RF transmitters, consider an electromagnetic site survey. If the measured field strength
in the location in which the 24970A base is used exceeds the applicable RF compliance level above, observe the 24970A base to
verify normal operation. If abnormal performance is observed, additional measures may be necessary, such as re-orienting or
relocating the 24970A base.
b
  Over the frequency range of 150 kHz to 80 MHz, field strengths should be less than 10 V/m.
    Recommended separation distances between portable and mobile RF communications equipment and the 24970A base
The 24970A base is intended for use in an electromagnetic environment in which radiated RF disturbances are controlled. The
customer or the user of the 24970A base can help prevent electromagnetic interference by maintaining a minimum distance
between portable and mobile RF communications equipment (transmitters) and the 24970A base as recommended below,
according to the maximum output power of the communications equipment.
    Rated maximum output                            Separation distance according to frequency of transmitter
     power of transmitter
                                    150 kHz to 80 MHz                80 MHz to 800 MHz                  800 MHz to 2.5 GHz
                                        d = 0.35√P                       d = 0.35√P                         d = 0.70√P
           0.01 W                         0.035 m                          0.035 m                             0.070 m
           0.1 W                           0.11 m                           0.11 m                             0.22 m
            1W                             0.35 m                           0.35 m                             0.70 m
            10 W                           1.1 m                             1.1 m                              2.0 m
           100 W                           3.5 m                             3.5 m                              7.0 m
For transmitters rated at a maximum output power not listed above, the recommended separation distance d in meters (m) can be
estimated using the equation applicable to the frequency of the transmitter, where P is the maximum output power rating of the
transmitter in watts (W) according to the transmitter manufacturer.
Note 1: At 80 MHz and 800 MHz, the separation distance for the higher frequency range applies.
Note 2: These guidelines may not apply in all situations. Electromagnetic propagation is affected by absorption and reflection
from structures, objects, and people.
K163008
                                                                                                             Page 12 of 20
                                                                                                                                   Difference
                      24970A) and Applications        P890003/S065                    (Model 5311B)
Parameter
                      (D00U002, D00U001,
                                                                                      K910595 07MAY1991
Device
                                                                                                                  Pacing System
                                                                                                                  Analyzer Model
                                                                                                                  2290
                                                                                                                                   Same
                                                      Class III                       Class III
                      Class II
K163008
                                                                                                                               Page 13 of 20
                                                                                                                                                  Difference
                      24970A) and Applications                P890003/S065                         (Model 5311B)
Parameter
                      (D00U002, D00U001,
                                                                                                   K910595 07MAY1991
Device
                                                                                                                                                  Same
General Description
                      Manager is a microprocessor-based       based accessory that installs into   A-V Pacing System Analyzer
                      Device. The device is designed to       the programmer. The Analyzer is      (PSA) is a hand-held
                      analyze the electrical                  designed to analyze the              microprocessor based device
                      performance of a cardiac lead           electrical performance of a          designed to test the
                      system, using the mobile device         cardiac lead system, and uses        electrical performance of the
                      platform and associated                 the programmer as a control          pulse generator and the
                      applications as a control and display   and display platform. The            pacing lead system at the
                      platform.                               Analyzer can be operated             time of pacemaker
                                                              "concurrently" with the              implantation and during
                                                              Programmer desktop. That is, you     invasive pacemaker
                                                              can switch to an analyzer session    troubleshooting or
                                                              from the Select Model screen on      evaluation procedures. The
                                                              the Programmer desktop, and you      model 5311B A-V PSA
                                                              can toggle back and forth between    combines the functions for a
                                                              an analyzer session and the Select   multimode external pulse
                                                              Model screen using icons on the      generator, a digital measuring
                                                              task bar.                            device, and a data processor
                                                                                                   to provide the following
                                                                                                   capabilities:
                                                                                                   • External single and dual
                                                                                                     chamber pacing in one of 10
                                                                                                     selectable pacing modes to
                                                                                                     support he patient during
                                                                                                     pacemaker implantation and
                                                                                                     pacing system test
                                                                                                     procedures. The 5311B PSA
                                                                                                     provides unipolar or bipolar
                                                                                                     pacing for both single and
                                                                                                     dual chamber applications.
                                                                                                   • Measurement of cardiac
                                                                                                     stimulation thresholds for
                                                                                                     voltage and current or pulse
                                                                                                     width.
                                                                                                   • P-wave/R-wave analysis for
                                                                                                     evaluation of the cardiac
                                                                                                     signals detected by the
                                                                                                     pacing lead system.
                                                                                                     Information provided
                                                                                                     includes the filtered and
                                                                                                     unfiltered voltage amplitude
                                                                                                     and the slew rate of the
                                                                                                     detected depolarization
                                                                                                     signal and an intracardiac
                                                                                                     electrogram taken from the
                                                                                                     pacing lead.
                                                                                                   • A test for retrograde
                                                                                                     conduction during evaluation
                                                                                                     of a dual-chamber lead
                                                                                                     system. This test is a feature
                                                                                                     of the intracardiac
                                                                                                     electrogram function.
                                                                                                   • Automatic calculation of
                                                                                                     pulse energy and lead
                                                                                                     resistance from measured
                                                                                                     pulse parameters.
                                                                                                   • Implantable pulse generator
                                                                                                     (IPG) tests include
                                                                                                     determination of the pacing
                                                                                                     mode and measurement of
                                                                                                     the pacing mode and
                                                                                                     measurement of up to 11
                                                                                                     pacing parameters.
K163008
                                                                                                                 Page 14 of 20
                                                                                                                                     Difference
                               24970A) and Applications   P890003/S065              (Model 5311B)
Parameter
                               (D00U002, D00U001,
                                                                                    K910595 07MAY1991
Device
                                                                                                                                     Same
General Description (Con’t.)
K163008
                                                                                                                      Page 15 of 20
                                                                                                                                               Difference
                     24970A) and Applications              P890003/S065                       (Model 5311B)
Parameter
                     (D00U002, D00U001,
                                                                                              K910595 07MAY1991
Device
                                                                                                                                               Same
                     The base is intended to be used by                                       troubleshooting or
                     healthcare professionals only in                                         diagnostic procedures. The
                     operating environments under direct                                      Model 5311B A-V PSA is
                     medical supervision.                                                     designed to pace the patient
                                                                                              externally during pacing
                                                                                              system test and implantation
                                                                                              procedures. The pacing and
                                                                                              test functions of the Model
                                                                                              5311B A-V PSA are intended
                                                                                              for both single- and dual-
                                                                                              chamber pacemaker
                                                                                              applications.
                     DTA, DTC                              KRG and OSR                        DTC                            This medical
                     21 CFR 870.3720                                                          21 CFR 870.3630                device has been
Product
 Code
                                                                                                                                               Same
                     21 CFR 870.3630                                                                                         reclassified to
                     New                                                                                                     Class II
                     21 CFR 870.3605                                                                                         18APR2016
                                                                                                                             21CFR870
K163008
                                                                                                                   Page 16 of 20
                                                                                                                                            Difference
            24970A) and Applications                P890003/S065                         (Model 5311B)
Parameter
            (D00U002, D00U001,
                                                                                         K910595 07MAY1991
Device
                                                                                                                                            Same
Features
            these tasks:                            and R-wave amplitudes and             PSA operating mode. For          Pacing System
            •   Analyze electrical performance of   slew rates                            pacing and lead system tests,    Analyzer Model
                cardiac leads during implant.       ■ Automatic lead impedance            the Model 5410 Surgical Cable    2290
                                                    measurement                           is used to connect the PSA to
            •   Assess proper placement of          ■ Real-time display of atrial and     an indwelling lead system.
                cardiac leads during implant.       ventricular EGM                      • Pacing Mode and Parameter
            • View, measure, and document           ■ Rapid atrial stimulation to 800       Adjustment
              live cardiac waveforms.               min-1 (ppm)                          • Emergency VVI Pacing
            The PSA app includes these              ■ Advanced analysis features,
                                                    including antegrade and              • Stimulation Threshold
            features for the analysis of cardiac
                                                    retrograde conduction tests,            Measurement
            leads:
                                                    and a pulse width versus             • Lead System Resistance
            •   Dual and single chamber pacing      amplitude threshold analysis         • Filtered P-Wave / R-Wave
                modes.                              ■ Measurement reports                   Amplitude
            •   Automatic measurement of P-         Safety features
                                                                                         • Pulse Energy
                wave and R-wave amplitudes.         The Analyzer has the following
                                                    safety features:                     • Slew Rate and Unfiltered
            •   Lead impedance measurement.
                                                    ■ Backup battery in the event of a      Signal Amplitude
            •   Real-time display of atrial and     power loss                           • Intracardiac Electrogram
                ventricular EGM and ECG             ■ Electrical isolation from the      • Retrograde Conduction
                waveforms.                          programmer
                                                                                            Test Function
            •   Rapid atrial stimulation to 850     ■ Emergency VVI pacing
                                                                                         • Inhibit Function
                min−1 (ppm).
                                                                                         • Rapid Stimulation
            •   Advanced pulse width versus
                amplitude pacing threshold
                tests.
            •  Measurement reports.
            The base includes these features:
            •   Analyzer hardware and patient
                cable connections to support
                electrical assessment of cardiac
                leads during implant.
            •   ECG cable connections to collect
                live cardiac waveform data that
                can be viewed, measured, and
                recorded using the app running
                on your mobile device.
            •   Bluetooth® wireless technology
                to communicate with the app
                running on your mobile device.
            •   A cradle to charge the Medtronic
                24967 Patient Connector (The
                24967 patient connector is not
                the subject of this submission).
            • Optional USB connectivity to
              charge the patient connector.
              (The 24967 patient connector is
              not the subject of this
              submission).
            5 year warranty                         10 years                             1 year warranty                   NA
Longevity
NA
K163008
                                                                                                                 Page 17 of 20
                                                                                                                                       Difference
                24970A) and Applications              P890003/S065                          (Model 5311B)
Parameter
                (D00U002, D00U001,
                                                                                            K910595 07MAY1991
Device
Length: 8.203” +/- 5% Width: 9.450” When installed the Analyzer will
                                                                                                                                       Same
                +/- 5% Thickness: 1.810” +/- 5%.      not change the physical size of the
                                                      Model 2090 Programmer.
                The Base will have a maximum
                footprint of:
                548 cm2.
                The Base Station shall have a         16 ounces (1 lbs.).                   1.5 kg (3.3 lbs.)         All
                maximum weight of 0.91 kilograms
Mass
                                                                                                                                       Same
                (2.0 lbs.).
                No                                    No                                    No                        All
Compatibility
                                                                                                                                       Same
   MRI
                                                                                                                                       Within the
                                                                                                                      Pacing System
                                                                                                                                       range but
Basic
                                                                                                                                         Same
Rate
                                                                                                                      Analyzer Model
                                                                                                                      2290
Analyzer Model
                                                                                                                                       Similar
   Rate
2290
Analyzer Model
                                                                                                                                       Similar
                                                                                                                      2290
Same
                                                                                                                      Analyzer Model
                                                                                                                      2290
K163008
                                                                                                                 Page 18 of 20
                                                                                                                                       Difference
              24970A) and Applications            P890003/S065                      (Model 5311B)
Parameter
              (D00U002, D00U001,
                                                                                    K910595 07MAY1991
Device
Analyzer Model
                                                                                                                                       Similar
                                                                                                                      2290
                                                                                                                      Analyzer Model
   P i d
                                                                                                                                       Similar
                                                                                    Ventricular: 233 or 325 ms        2290
                                                                                    depending on mode
              No                                  Yes                               Yes                               NA
Slew
Rate
                                                                                                                                       NA
              VOO; VVI; AOO; AAI; DOO; DDD;       VOO, VVI,AOO, AAI, DOO, DDD,      VVI, VVT, VOO, AAI, AAT,          All
                                                                                                                                       (excluding VVV
              DDI; ODO; OOO                       VDD, ODO                          AOO, DDD, DVI, DOO, VDD
Pacing
Modes
                                                                                                                                           mode)
                                                                                                                                            Same
              Model 2292 Analyzer Surgical        Model 2292 Analyzer Surgical      The Model 5311B A-V PSA is        Medtronic
                                                                                                                                       Same
Accessories
Performance Data
The following performance data were provided in support of the substantial equivalence
determination.
K163008
                                                                                       Page 19 of 20
Biocompatibility testing
The biocompatibility evaluation for the CareLink SmartSync Device Manager, Pacing System
Analyzer Base, Model 24970A was conducted in accordance with the FDA Blue Book Memorandum
#G95-1 “Use of International Standard ISO-10993, ‘Biological Evaluation of Medical Devices Part
1: Evaluation and Testing,’” May 1, 1995, and International Standard ISO 10993-1 “Biological
Evaluation of Medical Devices − Part 1: Evaluation and Testing Within a Risk Management
Process,” as recognized by FDA. The device was justified by similarity to the Medtronic Model
24967 patient connector (K163460). The battery of testing for materials used in the Model 24970A
included the following tests:
   •   Cytotoxicity
   •   Sensitization
   •   Irritation
The Model 24970A is considered non-tissue or patient contacting.
Electrical safety and EMC testing were conducted on the CareLink SmartSync Device Manager,
Pacing System Analyzer Base, Model 24970A, associated applications and non-medical mobile
platform (i.e. Tablet) with associated cables as necessary for test. The system complies with the IEC
60601-1, standards for safety and the IEC 60601-1-2 third and fourth edition versions of the standard
for EMC.
Mechanical Testing
The following is a list of testing performed:
   •   Inspection of the required mechanical design features and function
   •   Workmanship inspection concerning all external surfaces that can cause injury such as
       sharp edges or pinch points
   •   Product labeling inspection
   •   Forces required to activate controls
   •   Chemical resistance testing for effects of repeat cleaning cycles
   •   Environmental and drop testing
   •   Reliability testing of buttons, electrical contacts, user connector insertions, and
       replaceable or moving mechanical components
   •   Performance and robustness testing of the Articulated Lid
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Animal Study
There were no formalized animal studies performed for this 510(k) submission.
Clinical Studies
There were no formalized clinical studies performed for this 510(k) submission.
Conclusions
The non-clinical data, the hardware and software verification and validation support and demonstrate
that the CareLink SmartSync Device Manager, Pacing System Analyzer Base, Model 24970A should
perform as intended in the specified use conditions and is substantially equivalent to the predicate
device.
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