K Number
K021144
Date Cleared
2002-06-24

(76 days)

Product Code
Regulation Number
882.1310
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Nicolet Subdural Strip Electrodes can be temporarily placed on the surface of the brain or subdural space in support of stimulating the brain or recording the brain's electrical activity.

Device Description

Subdural Strip Electrodes are used by licensed medical professionals to support stimulation and recording of biopotentials from the surface of the brain or the subdural space above the surface of the brain. The electrodes connect to medical equipment in support of stimulation and recording. The electrodes are provided to the user sterile. The electrodes are single patient use, disposable devices. The electrodes are made from the same materials as the predicate devices. The electrode lead wires terminate in a safety connector, complying with the FDA Performance Standard for Lead Wires and Patient Cables, 21 CFR Part 898. These electrodes do not contain active electronics or software. The electrodes connect to the user's medical equipment.

AI/ML Overview

This document describes a 510(k) premarket notification for a medical device, the Nicolet Subdural Strip Electrodes. Much of the typical information found in an AI/algorithm-based device study is not present because this is a hardware device, not a software algorithm. Therefore, many of the requested fields cannot be answered from the provided text.

Here is the information that can be extracted or deduced from the document:

1. Table of Acceptance Criteria and Reported Device Performance

Not applicable. This is a hardware device submission, not a performance study for an AI/algorithm. The submission focuses on substantial equivalence to predicate devices rather than specific performance metrics against acceptance criteria.

2. Sample size used for the test set and the data provenance

Not applicable. No "test set" in the context of an algorithm's performance is mentioned as this is a hardware device.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

Not applicable. No ground truth establishment for an algorithm's test set.

4. Adjudication method for the test set

Not applicable. No test set adjudication detailed for an algorithm.

5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

Not applicable. This is a hardware device. No AI component or human reader study is discussed.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

Not applicable. This is a hardware device. No algorithm is involved.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

Not applicable. For a hardware device being cleared via 510(k), the "ground truth" for clearance is typically demonstration of substantial equivalence to a legally marketed predicate device, often through material comparisons, manufacturing process reviews, and functional testing to ensure it meets its intended use safely and effectively, rather than a diagnostic ground truth like pathology for an AI.

8. The sample size for the training set

Not applicable. No training set for an algorithm is mentioned.

9. How the ground truth for the training set was established

Not applicable. No training set for an algorithm is mentioned.


Summary of Device and 510(k) Submission:

The Nicolet Subdural Strip Electrodes are a hardware medical device intended for temporary placement on the surface of the brain or subdural space to support stimulating the brain or recording its electrical activity.

The 510(k) submission, K021144, asserts substantial equivalence to predicate devices (K970587, K923803, K850342 manufactured by Ad-Tech Medical Instrument Corp.). The basis for this claim is:

  • Identical intended use: "The Nicolet Subdural Strip Electrodes can be temporally placed on the surface of the brain or subdural space in support of stimulating the brain or recording the brain's electrical activity."
  • Similar technology: "The Subdural Strip Electrodes are made from the same materials as the predicate devices."
  • Safety compliance: The electrode lead wires terminate in a safety connector, complying with the FDA Performance Standard for Lead Wires and Patient Cables, 21 CFR Part 898.
  • Absence of active electronics or software: The device is passive and connects to existing medical equipment.

The FDA reviewed the submission and determined that the device is substantially equivalent to legally marketed predicate devices, meaning it does not raise new questions of safety or effectiveness. This clearance allows Nicolet Biomedical to market the device.

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JUN 2 4 2002

Image /page/0/Picture/1 description: The image shows the logo for Nicolet Biomedical. The word "Nicolet" is in a large, bold, serif font. Below the word "Nicolet" is a thick, black line. Below the line, the word "BIOMEDICAL" is in a smaller, sans-serif font, with a large space between each letter.

Image /page/0/Picture/2 description: The image contains a handwritten string of characters. The string appears to be "Ko21144". The characters are written in a simple, slightly slanted style, with varying stroke thicknesses. The writing is clear and legible against the plain background.

Summary of Safety and Effectiveness

Company Name:Nicolet Biomedical5225 Verona RoadMadison, WI 53711
Contact:Phone:Fax:Glen Hermanson, Manager of Standards and Compliance608 441-2065608 441-2007
Summary Date:April 3, 2002
Trade Name:Subdural Strip Electrodes
Common Name:Cortical Electrode
Classification Name:21 CFR 882.1310; Product Code: GYC
Predicate Device:510(k) Number: K970587, K923803, K850342Manufacture: Ad-Tech Medical Instrument Corp.

Trade Name:

1.0 Description of Device

Subdural Strip Electrodes are used by licensed medical professionals to support stimulation and recording of biopotentials from the surface of the brain or the subdural space above the surface of the brain. The electrodes connect to medical equipment in support of stimulation and recording.

Subdural Electrode

The electrodes are provided to the user sterile. The electrodes are single patient use, disposable devices.

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2.0 Intended Use

The intended use of the Nicolet Subdural Strip Electrodes is the same as the predicate electrodes. The Nicolet Subdural Strip Electrodes can be temporally placed on the surface of the brain or subdural space in support of stimulating the brain or recording the brain's electrical activity.

3.0 Technological

The Subdural Strip Electrodes are made from the same materials as the predicate devices. The electrode lead wires terminate in a safety connector, complying with the FDA Performance Standard for Lead Wires and Patient Cables, 21 CFR Part 898.

These electrodes do not contain active electronics or software. The electrodes connect to the user's medical equipment.

4.0 Conclusions

The intended use and technology of the Nicolet Subdural Strip Electrodes is substantially equivalent to the predicate electrodes. No new questions of safety or effectiveness are raised.

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DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized symbol composed of three parallel, curved lines that resemble a stylized caduceus without the snake.

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

JUN 2 4 2002

Nicolet Biomedical, Inc. c/o Mr. Gary Syring Ouality & Regulatory Associates, LLC 800 Levanger Lane Stoughton, Wisconsin 53589

Re: K021144

Trade/Device Name: Nicolet Biomedical/Subdural Strip Electrode Regulation Number: 882.1310 Regulation Name: Cortical Electrode Regulatory Class: II Product Code: GYC Dated: April 5, 2002 Received: April 9, 2002

Dear Mr. Syring:

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.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such 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); 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.

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Page 2 - Mr. Gary Syring

This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device - >>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>> to proceed to the market.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 21 CFR Part 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4659. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html

Sincerely yours.

Sincerely yours,

Mark A. Mikkelson

Celia M. Witten, Ph.D., M.D. Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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< 02 | 1 4 510(k) Number (if known): Device Name: Nicolet Subdural Strip Electrodes Indications For Use:

The Nicolet Subdural Strip Electrodes can be temporarily placed on the surface of the brain or subdural space in support of stimulating the brain or recording the brain's electrical activity.

(PLEASE: DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

(Division Sign-Off)
Division of General, Restorative
and Neurological Devices

510(k) Number K021144
(Optional Format 3-10-98)

§ 882.1310 Cortical electrode.

(a)
Identification. A cortical electrode is an electrode which is temporarily placed on the surface of the brain for stimulating the brain or recording the brain's electrical activity.(b)
Classification. Class II (performance standards).