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Study Watch with Irregular Pulse Monitor

Verily Life Sciences LLC • Cardiovascular • 01/17/2020

510(k)IEC 62304 Class C
FDA Summary PDF

Device Purpose

The Study Watch with Irregular Pulse Monitor is a prescription wearable system designed for adults with or at risk of atrial fibrillation, enabling them to record heart rhythms and single-channel ECGs under HCP guidance. It utilizes photoplethysmography for continuous irregular pulse detection and electrode-based technology for on-demand ECG capture, with data securely transferred to a cloud platform for healthcare professional review.

Summary

The Study Watch with Irregular Pulse Monitor, from Verily Life Sciences, is a prescription wearable device for adult patients (22 years and older) diagnosed with or susceptible to atrial fibrillation. It enables users to monitor and record their heart rhythms, including single-channel electrocardiogram (ECG) data. Intended for use in professional healthcare facility environments while worn as a wristwatch, the device prompts users to take a 60-second ECG, particularly upon detecting an irregular pulse. An animated ECG is displayed on the watch, but the actual waveform is securely transferred for review by a healthcare professional (HCP), without direct patient access to the detailed data on the watch. The device employs photoplethysmography (PPG) for continuous irregular pulse detection and utilizes two dedicated sensing electrodes for on-demand single-channel ECG acquisition when the user creates skin contact. ECG measurements, along with other physiological data, are transferred from the watch via a charging cradle and Verily's Study Hub to a cloud server. HCPs can then view these time-stamped ECG waveforms through a web portal, which does not include analytical features. Clinical studies demonstrated the PPG-based Irregular Pulse Monitor algorithm achieved 85% sensitivity and 96% specificity in detecting irregular pulses when compared against Holter ECG data.

AI Regulatory Concerns

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Keywords

Study WatchIrregular Pulse MonitorAtrial FibrillationElectrocardiogram (ECG)Photoplethysmography (PPG)Wearable DeviceRemote Patient MonitoringHealthcare Professional (HCP)Data TransferClinical Performance

Device Metadata

Submission Number
K192415
Company
Verily Life Sciences LLC
Panel
Cardiovascular
Product Code
N/A
Data Type
Signals
Clinical Function
Assessment
AI Function
Analysis
AI Subclass
detection

Relevant Clinical Questions

  • Q1. What is the typical battery life of the Study Watch under conditions of continuous PPG monitoring and frequent ECG captures, and how does this impact user compliance?; How does the device's PPG-based irregular pulse detection algorithm differentiate atrial fibrillation from other common arrhythmias or motion artifacts, especially in ambulatory settings outside of "professional healthcare facility environments"?; What are the specific criteria or thresholds used by the Irregular Pulse Monitor to trigger a notification and recommend an ECG capture, and how were these validated across diverse patient populations?; Given that patients do not have direct access to their ECG waveforms, what mechanisms are in place to ensure timely review by HCPs and subsequent communication of clinically significant findings back to the patient?; What is the observed learning curve and user acceptance rate for both patients (using the watch) and HCPs (using the web portal), particularly concerning the data interpretation workflow without integrated analysis features on the portal?

Risk Classification

ESL Analysis
FDA Device ClassII

FDA Class II via 510(k) pathway; IEC 62304 Class C (software safety classification); Authorized before §524B enforcement

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Cybersecurity Evidence

Powered by SBOMator™

Based on AI-generated device summaries, not the full FDA submission. Items not detected here may still be present in the complete submission package.

Cyber Score35/100
SBOM Evidence⚠ Not mentioned in summary
Cyber Risk Assessment⚠ Not mentioned in summary
Postmarket Plan✓ Detected in Summary
§524B ApplicableNo

Supply Chain BOM Evidence

Based on the CycloneDX / OWASP ECMA-424 xBOM ecosystem. Detection is from the AI-generated summary.

SBOMSoftware Bill of Materials
- Not detected
ML-BOMMachine Learning Bill of Materials(algorithm)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials(cloud, server, remote, platform)
✓ Detected
HBOMHardware Bill of Materials(sensor)
✓ Detected
CBOMCryptography Bill of Materials
- Not detected
VDR/VEXVulnerability Disclosure Report / Vulnerability Exploitability eXchange
- Not detected
OBOMOperations Bill of Materials(environment)
✓ Detected

Analysis:

• Analysis is based on the AI-generated device summary, not the full FDA submission package. Click "Analyze Full FDA PDF" below to scan the actual submission document.

• Evidence of ML-BOM, SaaSBOM, HBOM, OBOM detected in AI-generated device summary.

• This device was authorized before §524B took effect. Cybersecurity evidence requirements were less prescriptive at the time.

• Not detected in AI-generated device summary: SBOM, CBOM, VDR/VEX. These may be present in the full FDA submission.

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Study Watch with Irregular Pulse Monitor - Verily Life Sciences LLC | ESL FDA AI Device Intelligence