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Guidance for Industry and FDA

Guidance for Electrical Safety,
Electromagnetic Compatibility and
Mechanical Testing For Indwelling
Blood Gas Analyzer Premarket
Notification Submissions

(See Related Information)

Document issued on: June 28, 2000

 

 

 

CDRH Logo

U.S. Department Of Health and Human Services
Food and Drug Administration
Center for Devices and Radiological Health

Anesthesiology, Respiratory and Defibrillator Devices Branch
Division of Cardiovascular and Respiratory Devices
Office of Device Evaluation

 


Preface

Public Comment

Comments and suggestions may be submitted at any time for Agency consideration to Christy Foreman, Center for Devices and Radiological Health, 9200 Corporate Boulevard, HFZ-450, Rockville, MD 20850. Comments may not be acted upon by the Agency until the document is next revised or updated. For questions regarding the use or interpretation of this guidance contact Christy Foreman at (301) 443-8609 extension 177.

Additional Copies

World Wide Web/CDRH home page: http://www.fda.gov/cdrh/ode/guidance/1161.pdf or CDRH Facts on Demand at 1-800-899-0381 or 301-827-0111, specify number 1161 when prompted for the document shelf number.

TABLE OF CONTENTS

Guidance for Electrical Safety,
Electromagnetic Compatibility and
Mechanical Testing For Indwelling Blood
Gas Analyzer Premarket Notification
Submissions

This document is intended to provide guidance. It represents the Agency’s current thinking on the above. It 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 requirements of the applicable statute, regulations, or both.

Purpose

This guidance document describes a means by which indwelling blood gas analyzers may comply with the requirement of special controls for class II devices. Designation of this guidance document as a special control means that manufacturers attempting to establish that their device is substantially equivalent to a predicate indwelling blood gas analyzer device should demonstrate that the proposed device complies with either the specific recommendations of this guidance or some alternate control that provides equivalent assurances of safety and effectiveness.

This guidance document has been developed as a special control to support a change in classification from class III to class II. It identifies relevant material to include in a premarket notification. We intend it be used in conjunction with other identified special controls. All FDA requirements regarding premarket notification submissions are not repeated in this document. Please refer to the Federal Register notice published on March 15, 1999 for other applicable guidance documents and standards.

General Criteria and Testing

The premarket notification should include testing that demonstrates the performance characteristics of the device in the intended environment of use. The type of the device and its intended environment will determine the type of testing that is necessary. Recommended environmental, electrical, electromagnetic compatibility, and mechanical test procedures and protocols are discussed in the following sections.

Submit the following information in the premarket notification:

If device failure occurs during the testing, show how failure does not affect safety or effectiveness. However, if the device has been modified in response to such failure, describe these modifications (including the identification of and rationale for each modification), and include follow-up testing results demonstrating that the modification alleviates the problem.

General Test Methods

Establish and use general test methods for verifying that device performance is within specification when subjected to the environmental testing procedures described in this document. Provide:

Unless otherwise specified, the test conditions should be as follows:

Temperature: 15 to 35°C
Humidity: 30 to 90 percent
Barometric pressure: 68 to 106 kPa
Line voltage: 110 V rms to 125 V rms

For modular devices, test in more than one typical module configuration with the other modules operating.

Visual and Audible Status Indicators (Alarms)

Test methods for visual and audible indicators (alarms) should conform to either

Or

Electrical Safety

Electrical Power Indicators

Power visual status indicators should be provided to indicate that the device is energized. Such indicators should be located conspicuously on the device.

Electrical Power Indicators Test Methods

Determine by inspection that visual status indicators indicate when the device is energized.

Overcurrent Protection

Overcurrent protection should be provided for all line-powered devices.

An audible warning status indicator should be activated if the overcurrent protection mechanism is activated and operation of the device cannot be operated. This status indicator (alarm) should be capable of sounding for at least 15 minutes.

Medical devices should not be fitted with protective mechanisms which may cause disconnection of the device from the power line (supply mains) by producing a short-circuit which results in operation of an overcurrent protection mechanism.

Overcurrent Protection Test Methods

For ac line-powered devices:

Dielectric Strength

Power source conductors, patient contact circuits, and transducer circuits should be adequately insulated to assure protection of the patient and device from over voltages.

Dielectric Strength Test Methods

Test for dielectric strength in accordance with IEC 60601-1, Clause 20 (1988).

AC Power Grounding and Polarity

If the device power connector is not polarized, the device should operate within its specification in both polarities of power line connector insertion.

AC Power Grounding and Polarity Test Methods

For ac line-powered devices:

If the ac power connector is not polarized, reverse the polarity of the ac connection and repeat all tests.

Leakage Current

Provide the leakage current testing procedures and protocols, test results including leakage current measurements and identification of standards applied in testing in the premarket notification.

Leakage Current Test Methods

Test the device in accordance with IEC 60601-1 for Type BF equipment or in accordance with other applicable standards with leakage current specifications.

Auxiliary Output

Where an auxiliary output is provided:

Auxiliary Output Test Methods

If the device is provided with an auxiliary output:

Electromagnetic Compatibility

Electromagnetic compatibility is described in IEC 60601-1-2 (1993) with the replacement and additional requirements contained Subclauses 6.8.201(a) (except for the reference to 36.201.1.3), (b) and (c). Address electromagnetic compatibility in the premarket notification by describing and testing the performance characteristics under all applicable circumstances when operating from grounded and ungrounded ac power sources (i.e., with the third-wire ground connected and with it disconnected at the plug end of the power cord).

Devices should be tested for electromagnetic emissions and immunity to electromagnetic interference as described herein. Devices should be tested with the third wire ground connected at the plug end of the power cord. Devices intended for home use should be tested with the third wire ground connected and with it disconnected at the plug end of the power cord.

Electromagnetic Energy Emissions

The device should operate within its specification without emitting electromagnetic energy in excess of the levels specified below. The emission limit should be that specified by the referenced document, adjusted downward by the rms sum of all errors in the measurement of that quantity.

Electromagnetic Energy Emissions Test Methods

Emissions measurements should be made as specified in the referenced document. The required emission limit should be that specified by the referenced document, adjusted downward by the rms sum of all errors in the measurement of that quantity. Emission in excess of the adjusted limit should constitute failure of this test. These tests should be conducted using passive patient simulators, which in general are not capable of simulating normal patient signals.

Radiated and Conducted Electromagnetic Energy

Demonstrate the performance characteristics of the device relative to the requirements of CISPR 11 when tested as recommended in this guidance document. Provide this information in the premarket notification.

Radiated and Conducted Electromagnetic Energy Test Methods

The device should be tested according to CISPR 11.

Magnetic Fields

Demonstrate the performance characteristics of the device relative to RE101 (Army, 7-cm distance) of MIL-STD-461D from 30 Hz to 100 kHz when tested at the 7-cm distance according to RE101 of MIL-STD-462D.

Magnetic Fields Test Methods

The device should be tested for radiated magnetic field emissions between 30 Hz and 100 kHz as specified in RE101 of MIL-STD-462D, using the Army 7-cm limit. Measure at the 7-cm distance only.

Immunity and Electromagnetic Interference

The device should operate within its specification during and after exposure to electromagnetic interference at the levels specified below. The immunity level should be the level stated, adjusted upward by the rms sum of all errors in the measurement of that quantity, with the exception of the lower steady-state ac voltage limit and the line-voltage sag level, which should be adjusted downward by the rms sum of the measurement errors. The device should not, as a result of the specified test condition: indicate an equipment alarm, exhibit temporary degradation or loss of function or performance which requires operator intervention or system reset, or exhibit loss or corruption of stored data.

Immunity of the device to electromagnetic interference should be determined as specified in the referenced document, with the modifications listed below. The immunity level should be the level stated, adjusted upward by the rms sum of all errors in the measurement of that quantity, with the exception of the lower steady-state ac voltage limit and the line-voltage sag level, which should be adjusted downward by the rms sum of the measurement errors. Any of the following should constitute failure of this test: an equipment alarm, temporary degradation or loss of function or performance which requires operator intervention or system reset, or loss or corruption of stored data. Patient simulators should be used to provide simulated normal stimulus to sensors during electromagnetic immunity testing.

Electrostatic Discharge

The device should operate within its specification within 5 seconds of air discharges of 2, 4, and 8 kV, both positive and negative, applied to insulating surfaces and contact discharges of 2, 4, and 6 kV, both positive and negative, applied to conductive surfaces, both positive and negative, to include any point on the device accessible to the operator or patient, without the use of a tool, when tested according to IEC 61000-4-2, as specified in section 4.2. The device should operate within its specification within 5 seconds of contact discharges applied to horizontal and vertical conducting planes in the vicinity of the device.

Electrostatic Discharge Test Methods

The device should be tested with air discharges at 2, 4, and 8 kV, both positive and negative, applied to insulating surfaces and contact discharges at 2, 4, and 6 kV, both positive and negative, applied to conductive surfaces. Failure to resume normal operation (with no operator intervention) within 5 seconds of a discharge should constitute failure of this test. All test failure conditions listed above apply. The device should be tested according to IEC 61000-4-2, with the following conditions and modifications:

Monitors that are internally powered IEC CLASS II or circuitry isolated from earth ground may be tested in a way that ensures that there is no appreciable charge retention between individual test discharges. The electrical potential of the monitor may be equalized with that of the ground plane, between individual test discharges, by temporarily attaching a ground strap incorporating two 470 kilowatt resistors connected in series. This potential equalization connected should be disconnected and moved at least 1 meter away from the monitor during the application of individual test discharges.

Radiated Electromagnetic Fields

The device should operate within its specification during and after exposure to electromagnetic fields at frequencies between 80MHz and 2.5GHz at field (strengths up to 3 V/m (when unmodulated), amplitude modulated 80 percent with a 2 Hz sine wave or 100 percent with a square wave. A modulation frequency that is within each significant signal-processing passband of the device should used. For devices not having a defined passband, a modulation frequency of 0.5 Hz should be used. Specify the modulation frequency in the premarket notification.

Radiated Electromagnetic Fields Test Methods

All cables should be arranged so that they are horizontal over the majority of their length throughout the test. Device cables 1 meter or less in length should be arranged horizontally in the planar area of uniform field. For cables greater than 1 meter and less than or equal to 3 meters in length, the cable should be bundled in a serpentine configuration in the planar area of uniform field. For device cables grater than 3 meters in length, the first 3 meters should be bundled in a serpentine configuration in the planar area of uniform field and the remainder should be bundled low-inductively an placed on the non-conductive support.

Patient simulators used during the test should be either simple passive devices isolated from ground using fiber optic links, or battery operated and shielded. If the frequency step dwell method is used, the frequency step size should not exceed 1 percent of the fundamental and the dwell time should not be sufficient to allow the device to respond to the test. The dwell time should be based on the modality with the slowest response time and should be at least 3 seconds.

For modalities that average data over time, the minimum dwell should be either 1.2 times the averaging period or 3 seconds, which ever is greater. If the averaging period is adjustable the averaging period used to determine dwell time should be the monitor’s default averaging period, the period. If there is no default averaging period, the period used should be that which is expected to be used most often in clinical applications of the device.

If the continuous frequency sweep method is used, the rate of sweep should not exceed (4.5/X) x 10000 decades per second. Connections not normally used during the operation on the device that are made to the device to access performance during the test should be isolated using fiber optic links.

AC Voltage Fluctuations, Transients, and Surges

The following items apply to all devices that operate from the ac power line:

Steady-state voltage

The device should operate within its specification, without changing a voltage selection switch, when powered from line voltages between 95 and 132 volts rms.

For monitors that operate directly from an ac power lines, demonstrate the performance characteristics during and after power line dips to:

when tested according to IEC 61000-4-11.

For monitors that operate directly from an ac power line demonstrate the performance characteristics during and after power line dips to less than 1 % of nominal line voltage for 15 seconds according to IEC 61000-4-11. Test voltages should be step changes and start at a zero crossing.

Dropout

The device should operate within its specification during and after line voltage dropouts for durations of 10 milliseconds and less.

Slow sags and surges

The device should operate within its specification during and after line voltage surges to 150 V rms and sags to 90 V rms for durations of 500 ms and less.

Fast transient bursts

The device should operate within its specification during and after bursts of transients of 0.5, 1, and 2 kV, positive and negative, applied to ac power leads and transients of 0.25, 0.5, and 1 kV, both positive and negative coupled by way of a capacitive clamp to signal and interconnecting leads, that are specified to be 3 meters or more in length when tested according to IEC 61000-4-4, with the exception that the burst repetition frequency should not exceed 30 per minute.

The pulse repetition rate should be 5 kHz. Patient cables should not be tested directly, but should be attached to the monitor during the testing of all other cables power lines. Application of test to power lines should only be made simultaneously with respect to the ground reference plane.

Demonstrate the performance characteristics of the monitor during and after application of surges of 0.5, 1, and 2 kilovolts, both positive and negative, between ac power line(s) and ground, and application of 0.5 and 1 kilovolt, both positive and negative, between ac power line(s) (line-to-line), when tested according to IEC 61000-4-5. All other monitor cables should not be tested directly. Describe the response of the monitor to each individual surge.

While only power lines are tested, all monitor cables should be attached during the test. Five surges at each voltage level and polarity should be applied to each power line at each of the following: positive and negative zero crossing and positive and negative peak of the ac voltage waveform.

While only power lines are being tested, all device cables should be attached during the test.

Five surges at each voltage level and polarity should be applied to each power line at each of the following:

AC Voltage Fluctuations, Transients, and Surges Test Methods

The tests described below should be performed on all devices that operate from the ac power line.

Conducted Electromagnetic Energy

The device should operate within its specification during and after exposure of each interconnecting cable, including power cables, to conducted electromagnetic energy at frequencies between 10 kHz and 100 MHz at the levels specified in CS114, Curve #3, of MIL-STD-461D, when tested according to CS114 of MIL-STD-462D. A modulation frequency that is within each significant signal-processing passband of the device should be used. For devices not having a defined passband, a modulation frequency of 0.5 Hz should be used. The modulation frequency should be specified in the premarket notification.

Test the monitor should during and after exposure to conducted electromagnetic energy at 3 volts rms (measured before modulation is applied), modulated 80 percent with a 2 Hz sine wave over the frequency range beginning at the start frequency specified below and extending to 80 MHz when tested according to IEC 61000-4-6.

Conducted Electromagnetic Energy Test Methods

The device should be tested for immunity to conducted electromagnetic energy on each power and signal lead at frequencies between 10 kHz and 100 MHz at the levels specified in curve #3 of CS114 of MIL-STD-461D, using the test methods specified in CS114 of MIL-STD-462D, with the modifications and additions listed below.

Test conditions as described in subclause 36.202.5:

Magnetic Fields

A modulation frequency that is within each significant signal-processing passband of the device should be used. For devices not having a defined passband, a modulation frequency of 0.5 Hz should be used. The modulation frequency should be specified in the premarket notification.

Demonstrate the performance characteristics of the monitor during and after exposure to 60 Hz continuous wave magnetic fields at 3 amperes per meter when tested according to IEC 61000-4-8, with the exception that a maximum display jitter of 0.6 millimeters is allowed for cathode ray tube displays.

Monitors that recharge batteries or operate from an ac power line should be powered at a line frequency of 60 Hz during the test.

Magnetic Fields Test Methods

Demonstrate the performance characteristics of the monitor during and after exposure to 60 Hz continuous wave magnetic fields at 3 amperes per meter when tested according to IEC 61000-4-8, with the exception that a maximum display jitter of 0.6 millimeters is allowed for cathode ray tube displays.

Quasi-static Electric Fields

Demonstrate that the device operates within its specification during and after exposure to a sinusoidally varying electric field at 0.5 Hz with peak field strengths up to 2000 volts per meter. Note: This test simulates the movement of electrostatically charged fabrics and objects that could come into close proximity to the device.

Quasi-static Electric Fields Test Methods

Voltage Dips

Voltage dips are defined as short interruptions and voltage variations on power supply input lines.

Voltage Dips Test Methods

For devices that recharge batteries from the ac power line and devices that operate from the ac power line, demonstrate the performance characteristics during and after power line dips to less that 1 percent of nominal line voltage for 0.5 cycle, to 40 percent of nominal line voltage for 5 cycles, and to 70 percent of nominal line voltage for 25 cycles of the power frequency, when tested according to IEC 61000-4-11.

For monitors that recharge batteries from an ac power line and devices that operate directly from an ac power line, demonstrate the performance characteristics within 5 seconds after a power line dip to less than 1 percent of nominal line voltage for 15 seconds, when tested according to IEC 61000-4-1.

Test voltages changes should be step changes and start at a zero crossing.

For devices that recharge batteries from the ac power line and devices that operate from the ac power line demonstrate performance characteristics, without changing a voltage selection switch when powered from line voltage between 95 and 132 volts rms.

Environmental and Mechanical Safety

Controls Protection

The controls of medical devices should be protected from inadvertent or unauthorized changes or adjustment. The means of protection should be such as to preclude their defeat by patients, or other unauthorized persons.

All controls which increase or decrease a function should be marked with a legible indication to inform the operator which action(s) is (are) required to increase/decrease the controlled function. Controls and their associated markings should be visible or legible, or both, to an operator having a visual acuity of at least 1.0 when the operator is located at least 1 meter in front of the device and the ambient illuminance level is 215 lux, when viewing the information, marking, etc. perpendicular to, and including 15 degrees above, below, left and right. Controls should be identified with their associated markings.

For controls, movement upward, to the right, or in a clockwise direction should increase the control function. Movement downward, to the left, or a counterclockwise direction should decrease the control function. Rotary gas flow controls are exempt from this performance criterion.

Controls Protection Test Methods

Test by inspection.

Connector Protective Incompatibility

Device connectors, including those on wires and tubing, should be designed such that insertion into a receptacle other than the one into which they are intended to be inserted or into a receptacle using an improper orientation should not be possible.

Electrical connectors of a device (e.g., electrical lead wires) should include a mechanism to prevent connection of the patient to a power source that may cause a current flow in excess of that specified in paragraph (h)(6).

Electrode lead wires and patient cables for use with a medical device must comply with 21 CFR §898.12, Performance Standard for Electrode Lead Wires and Patient Cables.

Connector Protective Incompatibility Test Methods

Test by inspection and by attempting the prohibited connections.

Mechanical Safety

Each device should:

Mechanical Safety Test Methods

Test by inspection.

Mechanical Vibration and Shock Resistance

The device (i.e., the complete system suitable for its intended use) should withstand the mechanical shocks and vibrations expected in the environments of intended use as defined by the test methods contained herein, and should remain operational within its specification. Demonstrate the performance characteristics of the monitor following mechanical shock and vibration when tested according to IEC 60068-2-32 free fall procedure.

Mechanical Vibration and Shock Resistance Test Methods

Test the device (i.e., the complete system suitable for its intended use) to the following severity levels as specified in the following procedures. After each of these tests, visually inspect the device. Any evidence of damage or inability to perform within specification constitutes failure of the test.

IEC 68-2-27: Shock
  • Peak acceleration: 100 g (980 m/s2)
  • Duration: 6 msec
  • Pulse shape: half sine

IEC 60068-2-32 Shock Test (Free Fall)
  • Height: 0:5m
  • Duration at attitude: 2 falls on each face

IEC 60068-2-64 Broad Band Random Vibration Test
  • Frequency range 10 to 150 Hz,
  • Acceleration spectral density: 1(meter per second squared) squared per hertz (g2/Hz) from 10 to 12 Hz, decreasing at a rate of 3 decibels per octave from 12 to 150 Hz.
  • Duration: 30 minutes on each orthogonal axis

IEC 60068-2-6 Sinusoidal Vibration
  • Frequency range: 10 to 500 Hz
  • Acceleration amplitude: 1 g (9.8 m/s2)
  • Type and duration of endurance: 10 sweep cycles in each axis.

IEC 68-2-34 Random Vibration, Wide Band
  • Frequency range: 20 Hz - 500 Hz
  • Acceleration spectral density: 0.02 g2/Hz
  • Degree of reproducibility: low
  • Duration of conditioning: 9 minutes

Fluid Spill Resistance

The device should be so constructed that it continues to operate within its specification after fluids have been dripped on the device. Please refer to the requirements for drip-proof equipment as specified in Clause 44.6 of IEC 60601-1 and IEC 60529.

Fluid Spill Resistance Test Methods

Test the device as specified in Clause 44.6 of IEC 60601-1 according to the test method in IEC 60529 for drip-proof equipment. Following each of these tests, the device should be visually inspected. Any evidence of damage or inability to perform within specification constitutes failure of the test.

Temperature and Humidity

The device should operate within its specification when operating in the environmental temperature range of 5°C to 40°C, and in the environmental humidity range of 15 percent to 95 percent, noncondensing.

The device should not be damaged and should remain operational within its specification after storage in the environmental temperature range of minus 40°C to 70°C and at relative humidity up to 95 percent, non-condensing.

Temperature and Humidity Test Methods

Test the device as specified in Method Numbers 501.3, 502.3, and 507.3 of MIL-STD-810E. Failure of the device to perform within its specification constitutes failure of these tests.

Surface Temperature

Temperature of surfaces of a device an operator can contact during operation should not exceed 50°C in an ambient temperature of 35°C. The temperature of surfaces that may come in contact with the patient should not exceed 41°C in an ambient temperature of 35°C. Any surface that may come in contact with the patient exceeding 41°C, should be justified with a scientifically valid explanation and data should be provided demonstrating that patient safety is not compromised.

Surface Temperature Test Methods

Operate the device in an ambient temperature of 35°C. Measure the temperature of the device surfaces which are not intended to contact the patient. The presence of any temperature greater than 50°C should constitute failure of this test. Measure the temperature of device surfaces which are likely to contact the patient in normal use. Any temperature above 41°C should constitute failure of this test.

Toxic Materials

No toxic material from a device should come in contact with patient or operator during normal use.

Toxic Materials Test Methods

Determine by inspection that listed and any other known toxic materials used in the device are packaged in a manner that prevents patient and operator contact.

Strangulation

Provision should be made in routing, retention devices, or other means to minimize the risk of strangulation of the patient by wires or tubing. This may also be accomplished by providing instructions for routing of patient wires and tubing in the device labeling.

Strangulation Test Methods

Test by inspection.

 

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