K Number
K083371
Device Name
NAVIGATOR PRO WITH AEP SOFTWARE (BIOMARK, ENOG, CHAMP)
Date Cleared
2009-12-08

(389 days)

Product Code
Regulation Number
882.1870
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The ENoG Protocol is a feature of the Navigator Pro with AEP Software Evoked Response System and is intended to record evoked responses upon presentation of sensory stimuli to the facial nerve. The product is indicated for use as an assessment tool to supplement the case history information, physical examination, imaging studies, and/or other sensory evaluations conducted by or on the order of the physician.
Device Description
The ENoG Protocol is a feature of the Navigator Pro with AEP Software Evoked Response System; a Windows® based software application for use with the Navigator Pro hardware platform for the recording of evoked responses (i.e., electrical potentials) upon the presentation of sensory stimuli. The ENoG Protocol works on the basis of a repeating stimulus-response cycle. It is a convenience feature developed for the user to quickly set up testing for Electroneuronography evaluation of the facial nerves. The protocol utilizes the existing technology of the evoked response somatosensory function of the software. The evoked response from the patient is recorded through the use stimulus electrodes positioned near the mastoid, a cathode behind the earlobe, and an anode in front of the earlobe with the forehead as the ground.
More Information

No
The description focuses on standard evoked response recording technology and does not mention AI or ML.

No
The device is described as an "assessment tool" to "record evoked responses" for diagnostic purposes, not for treating a condition.

Yes

The device is intended to "record evoked responses upon presentation of sensory stimuli to the facial nerve" and is indicated for use "as an assessment tool to supplement the case history information, physical examination, imaging studies, and/or other sensory evaluations conducted by or on the order of the physician." This functionality clearly aligns with diagnostic purposes, supporting the physician in understanding a patient's condition.

No

The device description explicitly states that the ENoG Protocol is a feature of the Navigator Pro with AEP Software Evoked Response System, which is a Windows® based software application for use with the Navigator Pro hardware platform. It also describes the use of stimulus electrodes and other hardware components for recording the evoked response. This indicates it is not a software-only device.

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

Here's why:

  • IVD Definition: In vitro diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections.
  • Device Function: The description clearly states that the device records "evoked responses (i.e., electrical potentials) upon the presentation of sensory stimuli to the facial nerve." This involves applying stimuli to the patient's body and measuring the resulting electrical activity.
  • No Sample Analysis: There is no mention of analyzing samples taken from the patient's body. The measurements are taken directly from the patient's electrical responses.

Therefore, this device falls under the category of an in vivo diagnostic device, as it performs measurements directly on a living organism.

N/A

Intended Use / Indications for Use

The ENoG Protocol is a feature of the Navigator Pro with AEP Software Evoked Response System and is intended to record evoked responses upon presentation of sensory stimuli to the facial nerve. The product is indicated for use as an assessment tool to supplement the case history information, physical examination, imaging studies, and/or other sensory evaluations conducted by or on the order of the physician.

Product codes

GWJ, GWF

Device Description

The ENoG Protocol is a feature of the Navigator Pro with AEP Software Evoked Response System; a Windows® based software application for use with the Navigator Pro hardware platform for the recording of evoked responses (i.e., electrical potentials) upon the presentation of sensory stimuli.

The ENoG Protocol works on the basis of a repeating stimulus-response cycle. It is a convenience feature developed for the user to quickly set up testing for Electroneuronography evaluation of the facial nerves. The protocol utilizes the existing technology of the evoked response somatosensory function of the software. The evoked response from the patient is recorded through the use stimulus electrodes positioned near the mastoid, a cathode behind the earlobe, and an anode in front of the earlobe with the forehead as the ground.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

facial nerves

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Physician or other qualified healthcare professional

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

Safety and effectiveness of the ENoG protocol feature have been established throughout the design and incorporation into the Navigator Pro with AEP Evoked Response System in accordance with the Bio-logic internal product development procedures, which are intended to meet ISO-9001, ISO 13485:2003 and FDA QSR Design Control specifications. A detailed Hazard/Risk analysis for the Evoked Potential family of products was performed using the Fault Tree Analysis (FTA) approach, and a detailed Risk Assessment for the AEP Software was written in accordance with ISO 14971:2007, Medical Devices - Application of Risk Management to Medical Devices.

Key Metrics

Not Found

Predicate Device(s)

K073626 Bio-logic Master II Evoked Response System, K031009 Bio-logic Evoked Potential System, K030907 Stacked ABR for Navigator Pro, K070608 SmartEP, K844992 Bio-logic Portable Evoked Response System

Reference Device(s)

K051357

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 882.1870 Evoked response electrical stimulator.

(a)
Identification. An evoked response electrical stimulator is a device used to apply an electrical stimulus to a patient by means of skin electrodes for the purpose of measuring the evoked response.(b)
Classification. Class II (performance standards).

0

K08337/

K083371 Navigator Pro, AEP Software Modification - ENoG June 4, 2009 Page 1-1

DEC - 8 2009

Attachment 3

510(k) Summary

Trade Name:Navigator Pro, AEP Software Modification - ENOG
Common Name:Evoked Response Somatosensory Stimulator
Classification Name:Stimulator, auditory, evoked response -21 CFR 882.1900. This device is
categorized as GWJ and is regulated as Class II.
Submitter Information:Natus Medical Incorporated
One Bio-logic Plaza
Mundelein, 60060
Phone: 800-323-8326
Fax: 847-949-8615
Correspondent InformationHelen Chandler
Vantage Consulting International
1011 Bugle Ct.
Chapel Hill, NC 27516
Phone: 919-932-4791
Fax: 919-932-4791
Summary Prepared By:Helen Chandler
Senior Consultant
Date Prepared:June 5, 2009
Predicate Devices:K073626 Bio-logic Master II Evoked Response System
K031009 Bio-logic Evoked Potential System
K030907 Stacked ABR for Navigator Pro
K070608 SmartEP
K844992 Bio-logic Portable Evoked Response System

Device Description

The ENoG Protocol is a feature of the Navigator Pro with AEP Software Evoked Response System; a Windows® based software application for use with the Navigator Pro hardware platform for the recording of evoked responses (i.e., electrical potentials) upon the presentation of sensory stimuli.

The ENoG Protocol works on the basis of a repeating stimulus-response cycle. It is a convenience feature developed for the user to quickly set up testing for Electroneuronography evaluation of the facial nerves. The protocol utilizes the existing technology of the evoked response somatosensory function of the software. The evoked response from the patient is recorded through the use stimulus electrodes positioned near the mastoid, a cathode behind the earlobe, and an anode in front of the earlobe with the forehead as the ground.

1

Indications for Use

The ENoG Protocol is a feature of the Navigator Pro with AEP Software Evoked Response System and is intended to record evoked responses upon presentation of sensory stimuli to facial nerves. The product is indicated for use as an assessment tool to supplement the case history information, physical examination, imaging studies, and/or other sensory evaluations conducted by or on the order of the physician.

Technological Characteristics

The ENoG Protocol is a feature of the Navigator Pro with AEP Software Evoked Response System; a Windows® based software application using Evoked Response test which works on the basis of repeating a stimulus-response cycle. The evoked response is recorded through the use of two or more electrodes placed in the appropriate locations.

The technological characteristics of the ENoG Protocol feature are compared to the Bio-logic predicate devices and are summarized in the table below.

Parameter for ComparisonSimilarity or Difference
Intended UseProtocol is set-up for stimulation of facial
nerves
PopulationNo differences
HardwareDigitimer (K051357)
Computer Control SoftwareNo differences
Patient Information and TrackingNo differences
Patient Connections (transducers & electrodes)Stimulus electrodes positioned near the
mastoid, a cathode behind the earlobe, and an
anode in front of the earlobe with forehead as
the ground. Recording electrodes are placed at
the nasio-labial fold
Presentation Data/User InterfaceNo differences
Physical CharacteristicsNo differences
Safety CharacteristicsNo differences
Product LabelingNo differences

Safety and Effectiveness Summary

Safety and effectiveness of the ENoG protocol feature have been established throughout the design and incorporation into the Navigator Pro with AEP Evoked Response System in accordance with the Bio-logic internal product development procedures, which are intended to meet ISO-9001, ISO 13485:2003 and FDA QSR Design Control specifications. A detailed Hazard/Risk analysis for the Evoked Potential family of products was performed using the Fault Tree Analysis (FTA) approach, and a detailed Risk Assessment for the AEP Software was written in accordance with ISO 14971:2007, Medical Devices - Application of Risk Management to Medical Devices. The ENoG protocol feature does not make any final decisions that result in any automatic forms of diagnosis or treatment. All program "results" require a

2

review by a physician or other qualified healthcare professional, and may be modified, overridden or deleted as determined by a qualified user. The program provides additional functionality to allow the qualified user to review all raw data collected and perform other data analyses to suit specific requirements.

Conclusions

The indications for use are consistent with the previously indicated predicate devices and in the applicable FDA classification regulation. Differences in technological characteristics from those of the cited predicate devices do not raise new issues of safety or effectiveness and are addressed in the submission.

3

Image /page/3/Picture/1 description: The image is a black and white logo for the U.S. Department of Health & Human Services. The logo features a stylized eagle with outstretched wings, symbolizing protection and care. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular pattern around the eagle, indicating the department's name and national affiliation.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Room W-O66-0609 Silver Spring, MD 20993-0002

Natus Medical, Incorporated Bio-logic, a Division of Natus % Ms. Nicohl Wilding One Bio-logic Plaza Mundelein, IL 60060

DEC - 8 2009

Re: K083371

Trade/Device Name: Navigator Pro, AEP Software Modification - ENoG Regulation Number: 21 CFR 882.1870 Regulation Name: Evoked Response Electrical Stimulator. Regulatory Class: Class II Product Code: GWF Dated: June 4, 2009 Received: June 9, 2009

Dear Ms. Wilding:

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 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); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); 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.

4

Page 2- Ms. Nicohl Wilding

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to

http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

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 (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm

Sincerely yours,

Mark N. Melkerson Director Division of Surgical, Orthopedic, and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

5

Indications for Use

510(k) Number (if known):

K083371

Device Name:

Navigator Pro, AEP Software Modification - ENoG

Indications For Use:

The ENoG Protocol is a feature of the Navigator Pro with AEP Software Evoked Response System and is intended to record evoked responses upon presentation of sensory stimuli to the facial nerve. The product is indicated for use as an assessment tool to supplement the case history information, physical examination, imaging studies, and/or other sensory evaluations conducted by or on the order of the physician.

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

Over-The-Counter Use (21 CFR 801 Subpart C)

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

signature FOR M. MELKERSON

(Division Sign-Off) Division of Surgical, Orthopedic, and Restorative Devices

510(k) Number K083371