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Guidance
Document on the Performance Standard for Electrode Leadwires and
Patient Cables.
The Performance Standard for Electrode Lead Wires and Patient
Cables, found in Title 21 Code of Federal Regulations (CFR), part
898, was published in the Federal Register on May 9, 1997 [62 FR
25497]. The performance standard becomes effective for certain
devices on May 11, 1998.
This guidance document represents the agency's initial thinking on
implementation of the performance standard for electrode lead wires
and patient cables. This guidance does not create or confer any
rights for or on any person and does not operate to bind FDA or the
public. An alternative approach may be used if such approach
satisfies the applicable statute, regulations, or both. Due to the
public health risks associated with the use of unprotected electrode
lead wires and patients cables, the agency is accepting public input
while the guidance is being implemented.
The performance standard was promulgated to address the
electrocution hazard posed by unprotected patient electrical
connectors. Copies of the final rule are also available through the
Division of Small Manufacturers Assistance via Facts-On-Demand at
(800) 899-0381 or (301) 827-0111, or from the CDRH Web Page at:
http://www.fda.gov/cdrh/comp/fr0509af.html
or http://www.fda.gov/cdrh/comp/fr0509ap.pdf
This is the first mandatory medical device performance standard, and
it is being implemented in two phases.
Beginning on May 11,
1998, all electrode lead wires or patient cables intended for use
with any of the following devices must comply with the standard.
Breathing Frequency Monitors
Ventilatory Effort Monitors (Apnea Detectors)
Electrocardiographs (ECGs)
Radio Frequency Physiological Signal Transmitters
and Receivers
Cardiac Monitors
Electrocardiograph Electrodes (including
Pre-wired ECG Electrodes)
Patient Transducer and Electrode Cables
(including Connectors)
Medical Magnetic Tape Recorders (e.g., Holter
Monitors)
Arrhythmia Detectors and Alarms
Telephone Electrocardiograph Transmitters and
Receivers
Replacement electrode lead wires and patient cables that are
intended for use with any of the above listed devices must also
comply with the performance standard beginning on May 11, 1998. The
ten devices included in this first phase of implementation are those
which pose the greatest potential hazard (e.g., those with reported
macroshock deaths or injuries, and certain cardiac monitoring
devices used outside healthcare facilities).
By reference, the performance
standard incorporates the specific requirements of the international
standard, IEC 60601-1, subclause 56.3(c), which requires leads to be
constructed in such a manner as to preclude patient contact with
hazardous voltages (or for certain devices, contact with electrical
ground). Specific tests for compliance include conductive contact
with a flat conductive surface, conductive contact with the inside
of a socket connector, and conductive contact when plugged into an
electrical (mains) socket or power cord. While it cannot be posted
to the CDRH Web Page, single copies of the referenced IEC subclause,
with test criteria and rationale, are available to affected
manufacturers on request, from the Office of Compliance at the
telephone or FAX numbers listed at the end of this guidance
document.
Compliance is determined by
the design of the electrode lead wire at the end remote from the
patient. Most (if not all) single pole, exposed pin lead wires
(regardless of size) and some exposed multi-pin connectors are
non-compliant with this standard. The Center is aware of various
lead wire designs that do not comply, including recessed sockets,
recessed or shielded pins, and shielded multi-pin connectors. To
meet the standard, a compliant patient cable must be compatible with
a compliant lead wire. Questions regarding the compliance status of
specific electrode lead wire and patient cable configurations should
be directed to the Office of Compliance , at the telephone or FAX
numbers listed at the end of this guidance document.
As stated in the preamble to the final rule, design changes and
labeling changes made to comply with this performance standard will
not require submission of a new premarket notification (510(k).
However, for devices cleared through a premarket approval,
information describing the design and labeling changes should be
included in the firm's next annual report. Supporting documentation
for design changes should also be maintained in the design history
file for the device, and will be subject to FDA inspection.
Manufacturers and users have an additional two years to prepare for
the implementation of the second phase of the standard. Beginning on
May 9,2000, any electrode lead wire or patient cable intended for
use with any medical device must comply with the performance
standard. During this two year transition period, applicability of
the performance standard will be determined by the stated intended
use of the electrode lead wire or patient cable, and by
circumstances surrounding it's promotion, advertising and marketing.
To assure compliance with the performance standard after the
effective date, manufacturers and their representatives are expected
to exercise due diligence in assessing their customers' intended use
of replacement electrode lead wires and patient cables marketed for
use with existing devices. While not required, manufacturers may
also wish to add a statement to their labeling noting compliance
with the FDA performance standard (21 CFR, part 898), in order to
assist users in selection and management of their electrode lead
wires and patient cables. During the transition period, it will also
be important to educate customers regarding proper selection of
electrode lead wires and patient cables, and to avoid labeling that
could be misconstrued regarding intended use. For example, prewired
"ECG" electrodes are currently used for many purposes.
However, beginning on May 11, 1998, and pre-wired electrodes labeled
for "ECG" use must comply with the performance standard.
Continued availability of
compatible electrode lead wires and patient cables for existing
devices is a concern for the user community. It is anticipated that
relatively inexpensive adapters will be available and can be used to
economically convert existing devices already in the marketplace to
accept compliant electrode lead wires and patient cables. However,
the performance standard also accounts for the possibility that
there may be circumstances where adapters are not feasible. In such
circumstances the manufacturer may request a variance or exemption
from compliance with the standard. Criteria and procedures for
submission of a variance/exemption may be found in 21 CFR, section
898.14, and 21 CFR, section 10.30.
For further information regarding compliance with the Performance
Standard for Electrode Lead Wires and Patient Cables, please contact
Stewart Crumpler in the Office of Compliance at (301) 594-4659, or
via FAX at (301) 594-4627.
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