K Number
K081871
Device Name
UNIVERSAL ELECTRODES
Manufacturer
Date Cleared
2008-09-29

(90 days)

Product Code
Regulation Number
882.1320
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The NeuroMetrix UNIVERSAL Electrodes are intended for use with electrodiagnostic equipment for the recording of electrophysiological activity from peripheral nerves and muscles, and for peripheral nerve electrical stimulation. UNIVERSAL Electrodes are non-sterile and are for single patient use only.
Device Description
Surface electrodes are the interface medium between neurodiagnostic equipment and the patient. When used for recording, they transduce bioelectric signals into electronic signals for measurement of bioelectrical phenomena in the body, such as peripheral nerve or muscle responses. When used in conjunction with stimulation circuitry in neurodiagnostic devices, they provide the interface necessary to stimulate peripheral nerves. Surface electrodes are used in the performance of nerve conduction studies (NCS). They are provided non-sterile and are designed and intended to be for single patient use only and are disposable. - l UNIVERSAL Stimulator Bar Electrode (UE-001) - UNIVERSAL Tab Electrode Set (UE-002) 트 - 트 UNIVERSAL Ring Electrode Set (UE-003) These individually placed electrodes are not configured for specific nerves, limbs, or clinical applications. The Stimulator Bar Electrode (UE-001) is for stimulation of peripheral nerves and consists of two electrodes in a bar configuration. The Tab Electrode Set (UE-002) and the Ring Electrode Set (UE-003) each consist of three distinct electrodes that are individually placed by the user.
More Information

No
The device description focuses solely on the physical characteristics and function of surface electrodes for electrodiagnostic procedures. There is no mention of any software, algorithms, or data processing that would suggest the use of AI or ML.

No
The device is described as being used with electrodiagnostic equipment for recording and stimulating, which falls under diagnostic purposes rather than therapeutic treatment.

Yes

Explanation: The "Intended Use / Indications for Use" section explicitly states that the electrodes are "intended for use with electrodiagnostic equipment for the recording of electrophysiological activity from peripheral nerves and muscles." The "Device Description" further elaborates that they "transduce bioelectric signals into electronic signals for measurement of bioelectrical phenomena in the body, such as peripheral nerve or muscle responses" and are "used in the performance of nerve conduction studies (NCS)." These functions are inherent to diagnostic processes.

No

The device description explicitly details physical electrodes (Stimulator Bar Electrode, Tab Electrode Set, Ring Electrode Set) which are hardware components used for interfacing with the patient and electrodiagnostic equipment. The summary does not mention any software component as the primary or sole medical device.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In Vitro Diagnostics are devices intended for use in the collection, preparation, and examination of specimens taken from the human body (such as blood, urine, or tissue) to provide information for the diagnosis, treatment, or prevention of disease.
  • Device Function: The NeuroMetrix UNIVERSAL Electrodes are surface electrodes that interface with electrodiagnostic equipment to record electrophysiological activity from peripheral nerves and muscles, and for electrical stimulation of peripheral nerves. This involves direct interaction with the patient's body, not the analysis of specimens taken from the body.
  • Intended Use: The intended use clearly states recording and stimulation of peripheral nerves and muscles, which are in-vivo (within the living body) procedures.

Therefore, the function and intended use of these electrodes fall outside the scope of In Vitro Diagnostics. They are considered medical devices used for electrophysiological measurements and stimulation directly on the patient.

N/A

Intended Use / Indications for Use

The NeuroMetrix UNIVERSAL Electrodes are intended for use with electrodiagnostic equipment for the recording of electrophysiological activity from peripheral nerves and muscles, and for peripheral nerve electrical stimulation. UNIVERSAL Electrodes are non-sterile and are for single patient use only.

Product codes

GXY

Device Description

Surface electrodes are the interface medium between neurodiagnostic equipment and the When used for recording, they transduce bioelectric signals into electronic patient. signals for measurement of bioelectrical phenomena in the body, such as peripheral nerve or muscle responses. When used in conjunction with stimulation circuitry in neurodiagnostic devices, they provide the interface necessary to stimulate peripheral nerves. Surface electrodes are used in the performance of nerve conduction studies (NCS). They are provided non-sterile and are designed and intended to be for single patient use only and are disposable.

  • l UNIVERSAL Stimulator Bar Electrode (UE-001)
  • UNIVERSAL Tab Electrode Set (UE-002) 트
  • 트 UNIVERSAL Ring Electrode Set (UE-003)

These individually placed electrodes are not configured for specific nerves, limbs, or clinical applications. The Stimulator Bar Electrode (UE-001) is for stimulation of peripheral nerves and consists of two electrodes in a bar configuration. The Tab Electrode Set (UE-002) and the Ring Electrode Set (UE-003) each consist of three distinct electrodes that are individually placed by the user.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

peripheral nerves and muscles

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Not Found

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K062198, K060584

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 882.1320 Cutaneous electrode.

(a)
Identification. A cutaneous electrode is an electrode that is applied directly to a patient's skin either to record physiological signals (e.g., the electroencephalogram) or to apply electrical stimulation.(b)
Classification. Class II (performance standards).

0

510(k) Summary for NeuroMetrix UNIVERSAL Electrodes

1. SPONSOR

NeuroMetrix, Inc. 62 Fourth Avenue Waltham, MA 02451

Contact Person:Rainer Maas
Telephone:(781) 890-9989 ext. 2781

Date Prepared:

August 22, 2008

2. DEVICE NAME

Proprietary Name:UNIVERSAL Electrodes
Common/Usual Name:Pre-gelled surface electrodes with leads and connector
Classification Name:882.1320 GXY Electrode, Cutaneous

3. PRÉDICATE DEVICES

  • . Axon Systems Pre-gelled Surface Electrodes (K062198)
  • . NeuroMetrix Biosensors (K060584)

4. INTENDED USE

The NeuroMetrix UNIVERSAL Electrodes are intended for use with electrodiagnostic equipment for the recording of electrophysiological activity from peripheral nerves and muscles, and for peripheral nerve electrical stimulation. UNIVERSAL Electrodes are non-sterile and are for single patient use only.

August 22, 2008

1

5. DEVICE DESCRIPTION

Surface electrodes are the interface medium between neurodiagnostic equipment and the When used for recording, they transduce bioelectric signals into electronic patient. signals for measurement of bioelectrical phenomena in the body, such as peripheral nerve or muscle responses. When used in conjunction with stimulation circuitry in neurodiagnostic devices, they provide the interface necessary to stimulate peripheral nerves. Surface electrodes are used in the performance of nerve conduction studies (NCS). They are provided non-sterile and are designed and intended to be for single patient use only and are disposable.

  • l UNIVERSAL Stimulator Bar Electrode (UE-001)
  • UNIVERSAL Tab Electrode Set (UE-002) 트
  • 트 UNIVERSAL Ring Electrode Set (UE-003)

These individually placed electrodes are not configured for specific nerves, limbs, or clinical applications. The Stimulator Bar Electrode (UE-001) is for stimulation of peripheral nerves and consists of two electrodes in a bar configuration. The Tab Electrode Set (UE-002) and the Ring Electrode Set (UE-003) each consist of three distinct electrodes that are individually placed by the user.

6. BASIS FOR SUBSTANTIAL EQUIVALENCE

A comparison of the UNIVERSAL Electrodes to the predicate Axon Systems Pre-gelled Surface Electrodes (K062198), along with testing data presented, support a finding of substantial equivalence. The UNIVERSAL Electrodes and these predicate electrodes share similar intended use, clinical applications, and technological characteristics.

The UNIVERSAL Electrodes include a connector, an electronic serial number (UE-001 only), EEPROM memory (UE-001 only), and the measurement of patient skin-surface temperature (UE-001). These technological characteristics are substantially equivalent to the NeuroMetrix Biosensors (K060584).

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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 stylized eagle with its wings spread, and the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular pattern around the eagle. The logo is black and white.

Public Health Service

SEP 2 9 2008

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

NeuroMetrix, Inc. c/o Mr. Rainer Maas 64 Fourth Avenue Waltham, MA 02451

Re: K081871

Trade/Device Name: Universal Electrodes Regulation Number: 21 CFR 882.1320 Regulation Name: Cutaneous Electrode Regulatory Class: Class II Product Code: GXY Dated: August 22, 2008 Received: September 3, 2008

Dear Mr. Maas:

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); Iabeling (21 CFR Part 801); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

3

Page 2 - Rainer Maas

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), please contact the Center for Devices and Radiological Health's (CDRH's) Office of Compliance at (240) 276-0115. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding postmarket surveillance, please contact CDRH's Office of Surveillance and Biometric's (OSB's) Division of Postmarket Surveillance at (240) 276-3474. For questions regarding the reporting of device adverse events (Medical Device Reporting (MDR)), please contact the Division of Surveillance Systems at (240) 276-3464. You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely yours.

Mark N. Milliman

Mark N. Melkerson Director Division of General. Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

4

INDICATIONS FOR USE

510(k) Number (if known):

UNIVERSAL Electrodes Device Name:

Indications for Use:

The NeuroMetrix UNIVERSAL Electrodes are intended for use with electrodiagnostic equipment for the recording of electrophysiological activity from peripheral nerves and muscles, and for peripheral nerve electrical stimulation. UNIVERSAL Electrodes are non-sterile and are for single patient use only.

Prescription Use X (Part 21 CFR 801 Subpart D) AND/OR

Over-The-Counter Use (21 CFR 807 Subpart C)

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

Peblhora

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

510(k)Page 1 of 1 K041871

NeuroMetrix, Inc. Universal Electrodes 510(k) June 27, 2008

CONFIDENTIAL Page x