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  • 1.  ECG device applied parts

    This message was posted by a user wishing to remain anonymous
    Posted 22-Feb-2024 09:06
    This message was posted by a user wishing to remain anonymous

    Hi all,

    My question is: are all ECG devices automatically classified as CF applied part according to IEC 60601-1 and IEC 60601-2-25 or can they be BF, as well?
    What confuses me a bit is the definition of "direct cardiac application" - is it related only to invasive intracardiac electrodes or electrodes in general?

    Thanks in advance!



  • 2.  RE: ECG device applied parts

    This message was posted by a user wishing to remain anonymous
    Posted 26-Feb-2024 09:12
    This message was posted by a user wishing to remain anonymous

    The general standard only requires testing to the CF level for things in physical contact with the heart, which is very few devices. But I have seen quite a few non-heart-contacting devices labeled as conforming to type CF. Does the particular standard call for type CF testing?




  • 3.  RE: ECG device applied parts

    Posted 27-Feb-2024 09:18

    My interpretation of the requirement in 60601-2-25 is that all applied parts related to the ECG function are required to be classified as Type CF applied parts. 



    ------------------------------
    Wade Munsch
    Director of Regulatory Affairs
    Biotex, Inc.
    Houston TX
    United States
    Company Website: www.biotexmedical.com
    Test Lab Website: https://www.biotexmedical.com/criterion/
    ------------------------------



  • 4.  RE: ECG device applied parts

    Posted 28-Feb-2024 14:08

    According to IEC 60601-1, the international standard for medical electrical equipment, ECG devices can be classified as either CF (Cardiac Floating) or BF (Body Floating) applied parts. The classification depends on the level of protection required for patient safety.

    In general, CF applied parts are used for direct cardiac applications, which involve making electrical contact with the heart or invasive procedures within the cardiovascular system. This typically includes invasive intracardiac electrodes used during procedures such as cardiac catheterization. CF applied parts have more stringent requirements for insulation and leakage current limits to ensure patient safety.

    On the other hand, BF applied parts are used for non-invasive applications where there is no direct contact with the heart or invasive procedures involved. This includes most standard ECG devices that use external electrodes placed on the skin surface to measure and record electrical activity of the heart. BF applied parts have less stringent requirements compared to CF applied parts.

    Therefore, most ECG devices that use external electrodes placed on the skin would typically fall under the classification of BF applied part according to IEC 60601-1 and IEC 60601-2-25.



    ------------------------------
    Raje Devanathan
    Amerisource Bergen
    TPIreg, Innomar Strategies
    Senior Manager - Regulatory Affairs, Medical Devices
    rdevanathan@tpireg.com
    3470 Superior Court
    Oakville ON L6L0C4
    Canada
    ------------------------------



  • 5.  RE: ECG device applied parts

    Posted 28-Feb-2024 14:46

    I believe the submitters original questions comes from 201.6.2 of IEC 60601-2-25 which modifies section 6.2 of IEC 60601-1 as follows:

    Replacement of the last paragraph:
    APPLIED PARTS shall be classified as TYPE CF APPLIED PARTS (see 7.2.10 and 8.3 of the general
    standard). APPLIED PARTS shall be classified as DEFIBRILLATION-PROOF APPLIED PARTS (see
    8.5.5 of the general standard).

    To me this means that all applied parts related to the ECG function are required to be classified as Type CF applied parts since 60601-2-25 removes the classification of Type B and Type BF as options. 



    ------------------------------
    Wade Munsch
    Director of Regulatory Affairs
    Biotex, Inc.
    Houston TX
    United States
    Company Website: www.biotexmedical.com
    Test Lab Website: https://www.biotexmedical.com/criterion/
    ------------------------------



  • 6.  RE: ECG device applied parts

    This message was posted by a user wishing to remain anonymous
    Posted 29-Feb-2024 10:20
      |   view attached
    This message was posted by a user wishing to remain anonymous

    Hi Wade and Rajeswari,

    Thanks for the answers.

    Basically the dilemma is can standard ECG devices be classified as CF applied parts according to 60601-2-25 but at the same time be not suitable for direct cardiac application (as the electrodes are not invasive) although 60601-1 says that CF applied parts are suitable for direct cardiac application?

    Maybe the answer lies in the attached section of 60601-1 - am I interpreting it right or not?




  • 7.  RE: ECG device applied parts

    Posted 29-Feb-2024 12:31

    Yes, applied parts can be classified as Type CF but not be invasive. Rather than "not be suitable for direct cardiac application", I would say "not intended for direct cardiac application". The difference here being that if a product is compliant with 6060-1 and 60601-2-25 it would be "suitable" for direct cardiac application (from a leakage current perspective) even though the intended use would not be for direct cardiac application due to sterility, biocomp, etc. as you have highlighted in the subclause. 



    ------------------------------
    Wade Munsch
    Director of Regulatory Affairs
    Biotex, Inc.
    Houston TX
    United States
    Company Website: www.biotexmedical.com
    Test Lab Website: https://www.biotexmedical.com/criterion/
    ------------------------------