(287 days)
The iEEG device is intended to acquire and store electrical activity of the brain and patient data for review by a medical professional using a digital EEG system to monitor the brain. The device is intended for use in a healthcare facility, clinical research environment, or in the home under the supervision of a qualified healthcare professional. The device is intended for use on all patient populations including pediatric.
The Intelligent Electroencephalogram (iEEG) device acquires and stores electrical activity of the brain and patient data. The iEEG can be used with other FDA cleared devices such as the BraiNet Kit (K043009) and Ives EEG electrode (K062880). The BraiNet Kit consists of the BraiNet Template (electrode cap), and Sub-dermal EEG Needle Electrodes and Cutaneous EEG Electrodes.
The iEEG consists of an iEEG transmitter module, a medical grade AC charging adapter/charging cable and an iEEG viewer/recorder software.
The wireless iEEG transmitter module provides an EEG electrode connection, electrode impedance (connection) status indicator(s), a single-user multi-function push button switch that provides power on/off, electrode impedance check. The wireless module is powered by an internal rechargeable energy source.
The AC charger module provides a convenient means to recharge the wireless module's internal energy source when not in use. The device is not intended to be charged when attached to the patient.
The iEEG viewer/recorder software provides, with the aid of host computer hardware and operating system, the ability to collect EEG electrode data from the wireless iEEG transmitter module, view EEG data, and record data to digital file. The iEEG viewer/recorder provides eight signal graphic display of selectable EEG montages (lead/electrode combinations). It also enables subject data entry (Name, DOB, ID number etc.) and control of EEG data recording to digital file.
The Intelligent Electroencephalogram (iEEG) is designed to be capable of usage and storage in hospital, clinic, and emergency room environments. The iEEG transmitter modules communicate with the computer by using Bluetooth wireless technology.
The provided 510(k) summary for the iEEG (Intelligent Electroencephalograph) device does not contain a dedicated section detailing acceptance criteria or the specifics of a study conducted to prove the device meets such criteria. Instead, it focuses on demonstrating substantial equivalence to predicate devices. This type of submission relies on showing that the new device is as safe and effective as a legally marketed device, rather than proving performance against specific pre-defined acceptance criteria through a clinical study.
The submission primarily lists technological characteristics and benchmarks them against predicate devices. The "Performance Data" section briefly mentions:
"The device was tested to IEC 60601-1-1 for safety and IEC 60601-2 Electromagnetic Compatibility. The device was also evaluated to standard IEC 60601-2-26 for essential EEG performance specifications. The device with a suitable battery charger was evaluated to IEC 60601-1/A2:1995, IEC 60601-2-26 and applicable national requirements. All applicable tests according to the specified standards were completed and passed. Bench testing was performed and confirms that the device meets design requirements and specifications."
This indicates that various engineering and safety standards were met through bench testing, but these are not the "acceptance criteria" for a clinical performance study in the way implied by the request. There is no clinical study described with a test set, ground truth, or expert review for diagnostic performance.
Therefore, for the points requested by the user, most of the information is not available in the provided text.
Here's a breakdown of what can be inferred or explicitly stated based on the provided document:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria (Inferred from regulatory standards and predicate comparison) | Reported Device Performance and Justification |
|---|---|
| Safety and Essential Performance (General) | - "The device was tested to IEC 60601-1-1 for safety and IEC 60601-2 Electromagnetic Compatibility."- "The device was also evaluated to standard IEC 60601-2-26 for essential EEG performance specifications."- "The device with a suitable battery charger was evaluated to IEC 60601-1/A2:1995, IEC 60601-2-26 and applicable national requirements."- "All applicable tests according to the specified standards were completed and passed."- "Bench testing was performed and confirms that the device meets design requirements and specifications." |
| Technological Equivalence (Relative to Predicate Devices) | - Channels: 8 (Equivalent to Zoom-100, within range of Trackit)- ADC Resolution: 16 bit (Same as Zoom-100 and Trackit)- ADC CMRR: >115dB (Slightly better than predicates (>100dB), deemed "comparable performance")- Input Impedance: 10MOhm (Same as Zoom-100, better than Trackit)- Electrode Impedance Check: Yes (Same as predicates)- Wireless Output: Bluetooth 2.4 GHz (Same as predicates)- Data Format: edf (Equivalent to Trackit)- Electrode Material: Standard off-shelf electrodes (Same as predicates)- Battery: Rechargeable Lithium-Polymer (Equivalent to Lithium-Ion in predicates)- Charger: Yes (Same as predicates)- Hi Filter Settings: Ranges listed (Deemed "Same or clinically insignificant differences" to predicates)- Low Filter Settings: Ranges listed (Deemed "Same" to predicates)- 60 Hz Filter: Yes (Same as predicates)- Gain Settings: Ranges listed (Deemed "Same or clinically insignificant differences" to predicates)- Time Base Settings: Ranges listed (Deemed "Same or clinically insignificant differences" to predicates)- Display Montage: User selectable (Deemed "Same or clinically insignificant differences" to predicates) |
2. Sample size used for the test set and the data provenance
- Not Available. The document describes bench testing against engineering standards and comparison of technical specifications against predicate devices. It does not mention any clinical test set or patient data used to evaluate diagnostic performance.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Not Applicable / Not Available. No clinical test set or ground truth establishment based on expert consensus for diagnostic performance is described. The evaluation was based on conformance to engineering standards and comparison of technical specifications.
4. Adjudication method for the test set
- Not Applicable / Not Available. No clinical test set or adjudication method is described.
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
- No. An MRMC comparative effectiveness study was not conducted or reported. The iEEG device is described as an "electroencephalograph" intended to acquire and store electrical activity for review by a medical professional, implying it is a data acquisition and display tool, not an AI-assisted diagnostic tool designed to improve human reader performance or automate diagnosis.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done
- No. The device is not an algorithm for standalone diagnostic performance. It is a hardware/software system for acquiring and displaying EEG data for human review.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- Not Applicable / Not Available. For its "performance data," the device primarily refers to meeting engineering and safety standards (IEC 60601 series). For demonstrating substantial equivalence, its technical specifications were compared to those of already cleared predicate devices. There is no mention of a clinical ground truth (like expert consensus, pathology, or outcomes data) being established for evaluating diagnostic accuracy.
8. The sample size for the training set
- Not Applicable / Not Available. This device is an EEG acquisition and display system, not an AI/ML algorithm that requires a "training set" in the context of diagnostic performance. Any internal development or validation would be against technical specifications, not a clinical training set for an algorithm.
9. How the ground truth for the training set was established
- Not Applicable / Not Available. As noted above, there is no mention of a "training set" or corresponding ground truth.
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4. 510(k) Summary
દાદ્ગાવવાય APR 1 0 2014
Summary Date: November 4, 2013
Submitter Data: Jordan NeuroScience, Inc. 1660 Plum Lane Redlands, CA 92374 909-881-2694
Primary Contact: Anne Perry aperry@jordaneuro.com
Device Name: iEEG (Intelligent Electroencephalograph)
Common Name: electroencephalograph
Device Classification Name: Electroencephalograph
Regulation: 882.1400 - Electroencephalograph
Requlatory Class: Class II
Primary Product Code(s):
OMC - Reduced- Montage Standard Electroencephalograph
Predicate Information
BrainScope Zoom-100 (K082886 cleared on 8/10/2009) Lifelines Trackit Recorder (K010460 cleared on 05/14/2001).
Device Description
The Intelligent Electroencephalogram (iEEG) device acquires and stores electrical activity of the brain and patient data. The iEEG can be used with other FDA cleared devices such as the BraiNet Kit (K043009) and Ives EEG electrode (K062880). The BraiNet Kit consists of the BraiNet Template (electrode cap), and Sub-dermal EEG Needle Electrodes and Cutaneous EEG Electrodes.
The iEEG consists of an iEEG transmitter module, a medical grade AC charging adapter/charging cable and an iEEG viewer/recorder software.
The wireless iEEG transmitter module provides an EEG electrode connection, electrode impedance (connection) status indicator(s), a single-user multi-function push button switch that provides power on/off, electrode impedance check. The wireless module is powered by an internal rechargeable energy source.
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The AC charger module provides a convenient means to recharge the wireless module's internal energy source when not in use. The device is not intended to be charged when attached to the patient.
The iEEG viewer/recorder software provides, with the aid of host computer hardware and operating system, the ability to collect EEG electrode data from the wireless iEEG transmitter module, view EEG data, and record data to digital file. The iEEG viewer/recorder provides eight signal graphic display of selectable EEG montages (lead/electrode combinations). It also enables subject data entry (Name, DOB, ID number etc.) and control of EEG data recording to digital file.
The Intelligent Electroencephalogram (iEEG) is designed to be capable of usage and storage in hospital, clinic, and emergency room environments. The iEEG transmitter modules communicate with the computer by using Bluetooth wireless technology.
Intended Use
The iEEG device is intended to acquire and store electrical activity of the brain and patient data for review by a medical professional using a legally marketed digital EEG system to assist in the diagnosis of neurological disorders. The device is intended for use by medical personnel in any location within a medical facility. physician's office, laboratory, and clinic or outside of a medical facility under the supervision of a medical professional. The device is intended for use on all patient populations including pediatric.
Technological Characteristics
The proposed iEEG and both predicate devices are batterv operated reusable electro-medical devices used to acquire and store electrical activity of the brain within a medical facility. The proposed iEEG and the predicate devices are also used outside of a medical facility under the supervision of a medical professional. The proposed iEEG and the predicate devices have the added capability to export data via wireless Bluetooth technology. The different technological characteristics are included in the risk assessment and testing (see section 16, 17, and 18). No new questions of safety and effectiveness were introduced. Refer to the following Table of Technological Characteristics for a summary.
Performance Data
The device was tested to IEC 60601-1-1 for safety and IEC 60601-2 Electromagnetic Compatibility. The device was also evaluated to standard IEC 60601-2-26 for essential EEG performance specifications. The device with a suitable battery charger was evaluated to IEC 60601-1/A2:1995, IEC 60601-2-26 and applicable national requirements. All applicable tests according to the specified standards were completed and passed. Bench testing was performed and confirms that the device meets design requirements and specifications.
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Substantial Equivalence
The proposed iEEG device is substantially equivalent in both function and use to the predicate device, BrainScope Zoom-100 (K082886 cleared on 8/10/2009). The iEEG device is substantially equivalent in EEG function and use of the reference device, Lifelines Trackit Recorder (K010460 cleared on 05/14/2001). The iEEG device is not used for a polysomnographs (sleep studies). Therefore the product code OLV of the device (Lifelines Trackit Recorder) does not apply.
Trackit, Zoom-100 and Insight are Class II legally marketed devices.
BrainScope Zoom-100 (K082886 cleared on 8/10/2009) is the predicate. The proposed device has equivalent intended use and has equivalent technology to the BrainScope Zoom-100 as indicated in the table below. Lifelines Trackit Recorder (K010460 cleared on 05/14/2001) is included as a reference device for the added technology of the Bluetooth wireless transmission of recorded data and for the additional application environment of outside of a medical facility under the supervision of a medical professional.
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| Device | iEEG(Subject) | BrainScope Z-100(Predicate) | Trackit EEG(Predicate)The informationis based on useof the device withPersyst softwareK010460 | PersystInsight | Explanation ofVariation | ||
|---|---|---|---|---|---|---|---|
| 510(k)# | K882886 | K082886 | K010460 | K011397 | N/A | ||
| Class | Class II | Class II | Class II | Class II | Same | ||
| Productcode | OMC | OMC | GWQ | GWQ/OMB | The twoproduct codesOMC and GWQhave exactlythe samedefinitionexcept GWQhas 16channels andabove, OMChas less than16. The numberof channelsdoes not affectthefundamentalscientifictechnology ofthe device.The TrackitEEG deviceallows for bothfull andreducedchannelconfigurations. | ||
| Regulationnumber | 882.1400 | 882.1400 | 882.1400 | 882.1400 | Same | ||
| Regulatory Information | Indicationsfor Use | The iEEG device isintended to acquireand store electricalactivity of the brainand patient data forreview by a medicalprofessional using adigital EEG system tomonitor the state ofthe brain. | The ZOOM-100DCis used to measureand record theelectrical activity ofa patient's brain.The ZOOM-100DCis intended tomonitor the state ofthe brain byacquisition anddisplay of EEGsignals and by thecalculation ofstandardquantitative EEGparameters. | The LifelinesTrackit is a 10 to36 channelambulatoryelectroencephalo-graph that isdesigned for usein a variety ofmonitoringapplications torecordphysiologicaldata for EEG andSleep Studies. | Persyt Insight(Reveal)software isuniversalEEGsoftware fordisplay ofEEG data tobeinterpreted bya medicalprofessional. | Equivalent. TheZoom-100 andTrackit devices areused to acquire andstore electricalactivity of the brain.Persyst onlydisplays acquireddata. | |
| ClinicalApplicationenvironment | The device isintended for use in ahealthcare facility,clinical researchenvironment, or in thehome under thesupervision of aqualified healthcareprofessional | Hospitals andclinics | For use in anylocation within amedical facility oroutside of amedical facilityunder thesupervision of amedicalprofessional | The softwareis intendedfor use by atrained EEGtechnologistor physician | Equivalent. Alldevices are usablewithin a medicalfacility. The iEEGand Trackit havethe similarapplication inenvironmentoutside of amedical facilityunder thesupervision of amedicalprofessional. | ||
| Modalities | EEG | EEG | EEG/PSG | EEG | Equivalent for EEG.The iEEG does nothave the modalityoption of PSG. ThePGS is used formonitoring sleepstudies. | ||
| The product codeOLV does not applyas IEEG is not usedfor apolysomnographs(PSG). | |||||||
| EEGChannels | 8 | 8 | 10 to 32 | 4 to 64 | Equivalent.Reduced montageis the same foriEEG and Zoom-100. The TrackitEEG referencedevice allows forboth full andreduced montage.The number of | ||
| electrodes does notaffect thefundamentalscientifictechnology of thedevice. | |||||||
| Montage | 10/20 system | 10/20 system | 10/20 system | 10/20 system | Same | ||
| SampleRate | 250 Hz | 200 Hz | 256 Hz | NA | Equivalent,sampling ratedefines the numberof samples persecond taken tocreate a digitalrepresentation ofthe EEG | ||
| specifications | waveforms. Alldevices provide asampling rate wellabove the upperfrequency content |
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| of the EEGwaveforms toprovide comparableand high fidelityrepresentation ofthe EEGwaveforms. | ||||||
|---|---|---|---|---|---|---|
| ADCResolution | 16 bit | 16 bit | 16 bit | NA | Same | |
| ADC CMRR | > 115dB | >100dB | >100dB | NA | Equivalent,Common ModeRejection Ratio(CMRR) is themeasure of asystem's ability toignore or rejectcommonbackgroundelectrical noisefrom the EEGsignals to berecorded (60 Hzline power noise forexample) Thegreater the CMRRvalue the better therejection ofcommon noisesources. The iEEGdevice is slightlybetter than thepredicate orreference deviceand would providecomparableperformance | |
| InputImpedance | 10MOhm | 10MOhm | 1 MOhm | NA | Equivalent, Sameas The primarypredicate (Zoom100) (Trackit EEG)is lower inimpedance, subjectto a loss in EEGsignal level. | |
| ElectrodeImpedance | Yes | Yes | Yes | NA | Same | |
| WirelessOutput | Bluetooth 2.4 GHz | Bluetooth 2.4 GHz | Class 1 BluetoothConnection | NA | Same | |
| Data Format | edf | Unknown | edf | NA | Equivalent toTrackit device. | |
| ElectrodeMaterial | Standard off shelfelectrodes | Standard off shelfelectrodes | Standard off shelfelectrodes | NA | Same | |
| Battery | RechargeableLithium-Polymer | RechargeableLithium Ion | DisposableBatteries orRechargeableLithium Ion | NA | Equivalent, LithiumPolymer andLithium Ion use thesame chemistries. | |
| Charger | Yes | Yes | Yes | NA | utilizes a micropore polymermaterial as thebattery plateseparator.Same | |
| Data format | iEEGedf | Zoom-100unknown | Trackitedf | edf | edf is a universaldata format forEEG | |
| Data Review | Persyst Insight, orJNS Viewer or legallymarketed edf reader | unknown | Persyst Insight orlegally marketededf reader | edf andvariousproprietarydata formats | Same | |
| DisplayChannels | 8 to 24 | unknown | NA | 4 to 64 | ||
| Hi FilterSettings | off10 Hz13 Hz15 Hz20 Hz25 Hz35 Hz50 Hz70 Hz | NA | NA | off1 Hz5 Hz10 Hz15 Hz20 Hz25 Hz35 Hz40 Hz80 Hz | Same or clinicallyinsignificantdifferences | |
| Waveform Review | Low filtersettings | off0.3 Hz0.5 Hz1 Hz2 Hz3 Hz10 Hz15 Hz20 Hz | NA | NA | off0.3 Hz0.5 Hz1 Hz2 Hz3 Hz10 Hz15 Hz20 Hz | Same |
| 60 Hz filter | yes | NA | NA | yes | Same | |
| Gain | 1 uv/mm1.5 uv/mm3 uv/mm5 uv/mm7 uv/mm10 uv/mm15 uv/mm20 uv/mm25 uv/mm35 uv/mm50 uv/mm125 uv/mm250 uv/mm | NA | NA | 1 uv/mm1.5 uv/mm3 uv/mm5 uv/mm7 uv/mm10 uv/mm15 uv/mm20 uv/mm30 uv/mm35 uv/mm50 uv/mm125 uv/mm250 uv/mm500 uv/mm | Same or clinicallyinsignificantdifferences | |
| Time Base | 1 Sec2 Sec5 Sec10 Sec | NA | NA | 1 Sec2 Sec5 Sec10 Sec15 Sec | Same or clinicallyinsignificantdifferences | |
| 30 Sec60 Sec120 Sec | 20 Sec30 Sec60 Sec120 Sec240 Sec | |||||
| DisplayMontage | User selectableTransverse-APHatband PlusHatbandDouble diamondCommon Ave RefReferentialD-Banana | NA | NA | UserselectableUserdefinableTransverseTransverse-APCommon AveReferentialReferentialLaplacianDoubleBananaBiPolarDoubleDiamond | Same or clinicallyinsignificantdifferences |
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Image /page/8/Picture/0 description: The image is a black and white seal for the U.S. Department of Health and Human Services. The seal is circular, with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the top half of the circle. In the center of the seal is a stylized design featuring three overlapping shapes that resemble waves or ribbons. The overall design is simple and professional, reflecting the department's role in public health and welfare.
DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
April 10, 2014
Jordan Neuroscience Inc. Ms. Anne Perry VP Finance and Administration 1660 Plum Lane Redlands, CA 92374
Re: K131944
Trade/Device Name: iEEG Regulation Number: 21 CFR 882.1400 Regulation Name: Reduced- montage Standard Electroencephalograph Regulatory Class: Class II Product Code: OMC Dated: March 12, 2014 Received: March 13, 2014
Dear Ms. Perry:
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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you however, that device labeling must be truthful and not misleading.
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 that I Dr Haral 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
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Page 2 - Ms. Anne Perry
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.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. 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 Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours,
Felipe Aquel -S
Carlos L. Peña, PhD, MS for
Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
Indications for Use
510(k) Number (if known) K131944
Device Name IEEG
Indications for Use (Describe)
The iEEG device is intended to acquire and store electrical activity of the brain and patient data for review by a medical professional using a digital EEG system to monitor the brain. The device is intended for use in a healthcare facility, clinical research environment, or in the home under the supervision of a qualified healtheare professional. The device is intended for use on all patient populations including pediatric.
Type of Use (Select one or both, as applicable)
Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
Please do not write below this line – continue on a separate page if needed.
FOR FDA USE ONLY
Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)
ം Date: 2014.04.10
2017:46:16 -04'00'
Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement on last page.
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§ 882.1400 Electroencephalograph.
(a)
Identification. An electroencephalograph is a device used to measure and record the electrical activity of the patient's brain obtained by placing two or more electrodes on the head.(b)
Classification. Class II (performance standards).