K Number
K133355
Device Name
CADWELL FLEX EEG/PSG
Date Cleared
2014-01-29

(90 days)

Product Code
Regulation Number
882.1400
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Cadwell Flex system is indicated for prescription use to acquire, record, transmit and display physiological and environmental data for electroencephalographic (EEG) and polysomnographic (PSG) ambulatory and/or clinical studies of patients of all ages.
Device Description
The Cadwell Flex EEG/PSG system consists of: (1) acquisition hardware that can acquire, record, store, and transfer up to 32 channels of EEG data, 8 active-reference signal, and audio signals from a microphone, and has EzNet-module-compatibility, (2).software_that_allows_a_user to acquire, store, transmit, view and print data, and to create reports based on the data, (3) optional video recording, (4) an optional photic stimulator, and (5) a host electronic device (typically a PC) capable of running the software and interfacing with the acquisition, video recording, and photic stimulation devices. The Cadwell Flex EEG/PSG system is capable of two modes of operation: (1) Ambulatory, where the acquisition hardware acquires, records, and stores physiological and/or environmental data to onboard mass-storage non-volatile memory, and said data is later transferred to a host electronic device, and (2) Clinical, where the host electronic device is connected to the acquisition hardware during data acquisition and recording, with mass-storage occurring on the host. The Cadwell Flex EEG/PSG system software is capable of interfacing with additional software used to perform EEG/PSG waveform analysis.
More Information

Not Found

No
The summary describes a system for acquiring, recording, transmitting, and displaying physiological data (EEG/PSG) and mentions software for data acquisition, storage, viewing, printing, and reporting. It also mentions interfacing with additional software for waveform analysis, but there is no mention of AI, ML, or related concepts in the provided text.

No
The device is used to acquire, record, transmit, and display physiological and environmental data for diagnostic purposes (EEG and PSG studies), not to provide therapy.

Yes

The device is designed to acquire, record, transmit, and display physiological data (EEG and PSG) for clinical studies, which are used to assess a patient's health status and identify abnormalities, thus serving a diagnostic purpose.

No

The device description explicitly states that the system consists of acquisition hardware, software, optional video recording, and an optional photic stimulator, in addition to a host electronic device. This indicates the presence of significant hardware components beyond just the software.

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

Here's why:

  • Intended Use: The intended use clearly states that the system is used to "acquire, record, transmit and display physiological and environmental data for electroencephalographic (EEG) and polysomnographic (PSG) ambulatory and/or clinical studies." This involves measuring electrical activity in the brain (EEG) and various physiological parameters during sleep (PSG).
  • Device Description: The description details hardware and software for acquiring, storing, and displaying these physiological signals.
  • Lack of IVD Characteristics: IVD devices are used to examine specimens derived from the human body (like blood, urine, tissue) to provide information for diagnosis, monitoring, or screening. The Cadwell Flex system directly measures physiological signals from the patient's body, not from a specimen.

Therefore, the Cadwell Flex system falls under the category of a physiological monitoring device, not an IVD.

N/A

Intended Use / Indications for Use

The Cadwell Flex system is indicated for prescription use to acquire, record, transmit and display physiological and environmental data for electroencephalographic (EEG) and polysomnographic (PSG) ambulatory and/or clinical studies of patients of all ages.

Product codes

GWQ, OMC, OLV, GWL, OLT, GWE

Device Description

The Cadwell Flex EEG/PSG system consists of: (1) acquisition hardware that can acquire, record, store, and transfer up to 32 channels of EEG data, 8 active-reference signal, and audio signals from a microphone, and has EzNet-module-compatibility, (2).software_that_allows_a_user to acquire, store, transmit, view and print data, and to create reports based on the data, (3) optional video recording, (4) an optional photic stimulator, and (5) a host electronic device (typically a PC) capable of running the software and interfacing with the acquisition, video recording, and photic stimulation devices.

The Cadwell Flex EEG/PSG system is capable of two modes of operation: (1) Ambulatory, where the acquisition hardware acquires, records, and stores physiological and/or environmental data to onboard mass-storage non-volatile memory, and said data is later transferred to a host electronic device, and (2) Clinical, where the host electronic device is connected to the acquisition hardware during data acquisition and recording, with mass-storage occurring on the host.

The Cadwell Flex EEG/PSG system software is capable of interfacing with additional software used to perform EEG/PSG waveform analysis.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Patients of all ages

Intended User / Care Setting

Hospital or home

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)

Software and hardware verification and validation, and clectromagnetic compatibility and safety testing were performed.

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

Not Found

Predicate Device(s)

K093728, K971214

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 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).

0

K133356 JAN 2 9 2014

:

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| Submitter: | Cadwell
909 N. Kellogg Street
Kennewick, Washington 99336
509-735-6481 |
|----------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | John Cadwell Jr
Electrical Engineer
Cadwell Laboratories, Inc. |
| Date Prepared: | October 31, 2013 |
| Trade Name: | Cadwell Flex |
| Regulation Name: | Electroencephalograph, Evoked Response Photic
Stimulator, Physiological Signal Amplifier |
| Regulation Number: | 21 CFR 882.1400, 21 CFR 882.1890, 21 CFR 882.1835 |
| Regulatory Classification: | Class II |
| Product Code: | GWQ, OMC, OLV, GWL, OLT, GWE, GWL |
| Classification Panel: | Neurological |
| Predicate Devices: | EB Neuro BE micro Trea (K093728)
Cadwell Kilowin (K971214) |
| Device Description: | The Cadwell Flex EEG/PSG system consists of: (1)
acquisition hardware that can acquire, record, store, and
transfer up to 32 channels of EEG data, 8 active-reference
signal, and audio signals from a microphone, and has
EzNet-module-compatibility, (2).software_that_allows_a_user
to acquire, store, transmit, view and print data, and to create
reports based on the data, (3) optional video recording, (4)
an optional photic stimulator, and (5) a host electronic
device (typically a PC) capable of running the software and
interfacing with the acquisition, video recording, and photic
stimulation devices.

The Cadwell Flex EEG/PSG system is capable of two
modes of operation: (1) Ambulatory, where the acquisition
hardware acquires, records, and stores physiological and/or |

Section 05: 510K Summary

・・.

Page I of 3

1

510k Summary

environmental data to onboard mass-storage non-volatile memory, and said data is later transferred to a host electronic device, and (2) Clinical, where the host electronic device is connected to the acquisition hardware during data acquisition and recording, with mass-storage occurring on the host.

The Cadwell Flex EEG/PSG system software is capable of interfacing with additional software used to perform EEG/PSG waveform analysis.

Indications for Use: The Cadwell Flex system is indicated Indications for Use: for prescription use to acquire, record, transmit and display physiological and environmental data for electroencephalographic (EEG) and polysomnographic (PSG) ambulatory and/or clinical studies of patients of all ages.

Substantial Equivalence:

Using the characteristics shown in the following table, the Cadwell Flex is shown to be substantially equivalent to the referenced predicate devices.

| Product | EBNeuro
BEmicro | Kilowin | Cadwell Flex |
|---------------------------|--------------------------------------------------|----------------------------------------------|-----------------------------------|
| 510K | K093728 | K97214 | TBD |
| Device class | Class II | Class II | Class II |
| Product Codes | OLV, GWQ, GWL,
MNR, DQA | GWE, GWF, GWJ,
GWQ, IKN, JXE, OLT,
OLV | GWQ, OLV, GWL, OLT,
GWE |
| Target Population | Pediatric through
adult | Patients of all ages | Patients of all ages |
| Recording
Modality | Attended and
unattended | Attended | Attended or unattended |
| Use Environment | Hospital and home | Operating room or clinic | Hospital or home |
| Prescription
Status | Available only on
the order of a
physician | By prescription only | By prescription only |
| Power | Battery powered or
USB powered | AC power | Battery powered or USB
powered |
| Number of EEG
Channels | 21 | 24-64 | 32 |
| Other Inputs | 1 digital | 12 ECG and 1-16 EMG | 8 active/reference, 2
other |
| A/D Resolution | 16 bit | 16 bit | 16 bit |
| Sampling Rate | Up to 2048
samples/s | 3200 Hz | 3200 Hz |
| Impedance Check | Yes | Yes | Yes |

Section 05: 510K Summary

Page 2 of 3

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Image /page/2/Picture/0 description: The image shows the word "CADWELL" in a stylized font. The "C" is replaced with a circle containing a symbol resembling a heartbeat. The letters are bold and have a textured appearance, giving them a slightly rough or grainy look. The overall design is simple yet distinctive, likely representing a brand or company name.

510k Summary

Testing:

Conclusion:

Software and hardware verification and validation, and clectromagnetic compatibility and safety testing were performed.

The Cadwell Flex system is substantially equivalent to The Cativen Tres in design, use, technology, and function.

Section 05: 510K Summary

Page 3 of 3

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DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo consists of a stylized caduceus symbol, which is a staff with two snakes coiled around it, placed within a circle. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged around the circumference of the circle. The logo is presented in black and white.

Public Health Service

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

January 29, 2014

Cadwell Laboratories c/o Mr. John Cadwell Jr. 909 N. Kellogg Street Kennewick, WA 99336

Re: K133355

Trade/Device Name: Cadwell Flex Regulation Number: 21 CFR 882.1400 Regulation Name: Electroencephalogram Regulatory Class: Class II Product Code: GWQ, OMC, OLV, GWL, OLT, GWE Dated: October 13, 2013 Received: October 13, 2013

Dear Mr. Cadwell:

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. Iisting 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 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

4

Page 2 - Mr. John Cadwell Jr.

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/ReportalProblem/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/ResourcesforYou/Industry/default.htm.

Sincerely yours.

Carlos L. Pena -S

Carlos L. Peña, Ph.D., M.S. Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

5

DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement on last page.

510(k) Number (if known) K133355

Device Name Cadwell Flex

Indications for Use (Describe)

The Cadwell Flex system is indicated for prescription use to acquire, record, transmit and environmental data for electroencephalographic (EEG) and polysomnographic (PSG) ambulatory and/or clinical studies of all ages.

Type of Use (Select one or both, as applicable) .

X 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) (Signalure)

Carlos L. Pena -S

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