(389 days)
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.
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.
The provided document describes a 510(k) summary for the Navigator Pro, AEP Software Modification - ENoG, which is an evoked response somatosensory stimulator. However, the document does not contain a study that proves the device meets specific acceptance criteria in terms of reported device performance metrics like accuracy, sensitivity, or specificity.
Instead, the submission focuses on substantial equivalence to predicate devices by comparing technological characteristics and ensuring safety and effectiveness through adherence to design control specifications and risk analysis. The "study" mentioned below refers to the safety and effectiveness summary provided in the document.
Here's an analysis based on the available information:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not provide a table with specific acceptance criteria (e.g., minimum sensitivity, specificity, or quantifiable performance metrics) for the ENoG Protocol, nor does it report numerical device performance against such criteria. The "acceptance" discussed is primarily in the context of substantial equivalence to predicate devices and adherence to quality systems and risk management.
2. Sample Size Used for the Test Set and Data Provenance
Not applicable. The document does not describe a clinical performance study using a test set of patient data with a specified sample size.
3. Number of Experts Used to Establish Ground Truth and Qualifications
Not applicable. There's no mention of a test set requiring expert-established ground truth.
4. Adjudication Method for the Test Set
Not applicable. There is no test set for which an adjudication method would be required.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No. The document does not describe an MRMC comparative effectiveness study, nor does it quantify any improvement in human reader performance with or without AI assistance. The device is not presented as an AI-assisted diagnostic tool in this context, but rather as a software modification to an existing evoked response system.
6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study
No. The document explicitly states: "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 review by a physician or other qualified healthcare professional, and may be modified, overridden or deleted as determined by a qualified user." This indicates that the device is intended for use with a human-in-the-loop, and no standalone performance study without human intervention is mentioned.
7. Type of Ground Truth Used
Not applicable. Since no performance study comparing device output to a known truth is described, there's no mention of the type of ground truth used.
8. Sample Size for the Training Set
No. The document does not describe a machine learning algorithm that requires a training set. The ENoG Protocol is described as a "convenience feature" and a "Windows® based software application" that utilizes "existing technology of the evoked response somatosensory function of the software."
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no training set for a machine learning algorithm.
Summary of the "Study" (Safety and Effectiveness Summary):
The "study" or assessment demonstrating safety and effectiveness relied on:
- Internal Product Development Procedures: The device was developed in accordance with Bio-logic's internal product development procedures, which are stated to meet ISO-9001, ISO 13485:2003, and FDA QSR Design Control specifications.
- Hazard/Risk Analysis: A detailed Fault Tree Analysis (FTA) was performed for the Evoked Potential family of products.
- Risk Assessment: 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.
- Human-in-the-Loop: A key aspect of safety is that "All program 'results' require a review by a physician or other qualified healthcare professional, and may be modified, overridden or deleted as determined by a qualified user." The program also allows users to review raw data and perform other analyses.
- Substantial Equivalence: The primary argument for market clearance is that the ENoG Protocol is substantially equivalent to legally marketed predicate devices, with differences in technological characteristics not raising new issues of safety or effectiveness.
In conclusion, the given document describes a regulatory submission centered on substantial equivalence and a risk management approach to safety, rather than a clinical performance study with specific quantitative acceptance criteria and reported device performance.
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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 iscategorized as GWJ and is regulated as Class II. |
| Submitter Information: | Natus Medical IncorporatedOne Bio-logic PlazaMundelein, 60060Phone: 800-323-8326Fax: 847-949-8615 |
| Correspondent Information | Helen ChandlerVantage Consulting International1011 Bugle Ct.Chapel Hill, NC 27516Phone: 919-932-4791Fax: 919-932-4791 |
| Summary Prepared By: | Helen ChandlerSenior Consultant |
| Date Prepared: | June 5, 2009 |
| Predicate Devices: | K073626 Bio-logic Master II Evoked Response SystemK031009 Bio-logic Evoked Potential SystemK030907 Stacked ABR for Navigator ProK070608 SmartEPK844992 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.
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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 Comparison | Similarity or Difference |
|---|---|
| Intended Use | Protocol is set-up for stimulation of facialnerves |
| Population | No differences |
| Hardware | Digitimer (K051357) |
| Computer Control Software | No differences |
| Patient Information and Tracking | No differences |
| Patient Connections (transducers & electrodes) | Stimulus electrodes positioned near themastoid, a cathode behind the earlobe, and ananode in front of the earlobe with forehead asthe ground. Recording electrodes are placed atthe nasio-labial fold |
| Presentation Data/User Interface | No differences |
| Physical Characteristics | No differences |
| Safety Characteristics | No differences |
| Product Labeling | No 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
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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.
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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.
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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
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Indications for Use
510(k) Number (if known):
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
§ 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).