(103 days)
The Nemus 2 System is intended to acquire the bioelectric signals produced by the patient's central and peripheral nervous system and muscles. The acquired signals are transmitted to a PC during recording of neurophysiology examinations. The Nemus 2 System consists of a physiological signal amplifier, an evoked response auditory stimulator, an evoked response electrical stimulator, and an evoked response photic stimulator. The user needs to assure compatibility of the Nemus 2 System to the other components of the user's own system.
The Nemus 2 System is made up of the Nemus 2 Amplifier/Stimulator, an AC/DC converter to power the amplifier, a "junction box" to connect the system to the Host PC, and (optionally) by a dedicate keyboard and a Flash LED stimulator.
The Nemus 2 System is intended to acquire bioelectric signals produced by the patient's central and peripheral nervous system and muscles. The acquired signals are transmitted to a PC during recording of neurophysiology examinations. The device may use electrical stimulus, sound stimulus, or visual stimulus for use in evoked response analysis.
The Nemus 2 System is an amplifier/stimulator device especially developed to amplify biological signals. The amplifier captures the biological signal from the human body through specialized sensors or electrodes, amplifies the very low electrical signal, and filters it to accomplish an antialiasing in order to make an optimal ANALOG to DIGITAL conversion. The data, once converted in numerical form, are "passed" to a host computer, which at this point is free to elaborate the data following the logic of the application software running on the host. The Nemus 2 System is not involved in the data management performed by the host.
Here's an analysis of the provided text regarding the Nemus 2 System's acceptance criteria and studies:
1. Table of Acceptance Criteria and Reported Device Performance
The provided document (K133517) is a 510(k) summary for a medical device. In these summaries, acceptance criteria are typically presented as technical specifications that the new device must meet to demonstrate substantial equivalence to predicate devices. The study proving these criteria are met is usually a series of non-clinical bench tests.
| Acceptance Criteria (Technical Specification) | Reported Device Performance (Nemus 2) |
|---|---|
| Safety Standards Conformity | Conforms to: IEC 60601-1, IEC 60601-1-1, IEC 60601-1-2, IEC 60601-1-4, IEC 60601-2-26, IEC 60601-2-40 |
| Saturation | Verified to meet technical specifications |
| Polarization | Verified to meet technical specifications |
| Offset & Gain | Verified to meet technical specifications |
| Noise (EMG Channels) | < 0.3 µVrms (0.1 – 100 Hz) |
| Noise (EEG/EP Channels) | < 20 nV/√Hz (10-10KHz) |
| CMRR (Common Mode Rejection Ratio) | >100 dB |
| IMRR (Input Mode Rejection Ratio) | >100 dB |
| Input Impedance (EMG) | Same as Nemus 1 (>100 MΩ) |
| Input Impedance (EEG/EP) | Same as BE Plus LTM (Comm. Mode: 3.3 MΩ, Differential: 6.6 MΩ) |
| Number of Channels (EMG) | 2 EMG |
| Number of Channels (EEG/EP) | 20 EEG/EP |
| A/D Conversion (EMG) | 24 bit |
| A/D Conversion (EEG/EP) | 16 bit |
| Sampling Rate (EEG/EP) | 16384 Hz |
| Sampling Rate (EMG) | 32768 Hz |
| Antialiasing Low Pass Filter (EMG) | 20 KHz |
| Antialiasing Low Pass Filter (EEG/EP) | 2 KHz |
| High-pass Filter (EMG) | 1.6s (0.1 Hz) or 16ms (10Hz) |
| High-pass Filter (EEG/EP) | 1.6/160 ms (0.1/1 Hz) |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: Not applicable in the context of this 510(k) summary for engineering verification. The "test set" here refers to the device itself and its components undergoing bench testing, not a dataset of patient cases.
- Data Provenance: Not applicable. The "study" described is verification testing against technical specifications, not a study involving patient data.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Their Qualifications
- Number of Experts: Not applicable. Ground truth as typically defined for medical AI (e.g., expert labels on images) is not relevant for this type of device and study. The "ground truth" for the verification testing is adherence to established engineering specifications and medical device safety standards.
- Qualifications of Experts: Not applicable.
4. Adjudication Method for the Test Set
- Adjudication Method: Not applicable. The testing involves objective measurements against predefined technical specifications and safety standards, not a subjective interpretation requiring adjudication among experts.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and the Effect Size of Human Readers Improving with AI vs. Without AI Assistance
- MRMC Study: No. This device is a physiological signal amplifier and stimulator, not an AI-powered diagnostic tool that would typically undergo MRMC studies to evaluate reader performance.
- Effect Size of Human Readers: Not applicable.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
- Standalone Performance: Not applicable. This is a hardware device for acquiring and stimulating bioelectric signals, not an algorithm. Its performance is evaluated based on its ability to accurately amplify, filter, and stimulate according to its specifications.
7. The Type of Ground Truth Used
The "ground truth" for this device's acceptance is based on:
- Conformity to international electrical and medical device safety standards (e.g., IEC 60601 series).
- Demonstration through verification testing that the device meets its own established technical specifications for parameters such as noise, CMRR, IMRR, input impedance, and channel characteristics.
- Substantial equivalence to predicate devices (Nemus 1 and BE Plus LTM) based on technological characteristics and intended use.
8. The Sample Size for the Training Set
- Sample Size: Not applicable. This is not an AI/machine learning device. There is no "training set."
9. How the Ground Truth for the Training Set Was Established
- Ground Truth Establishment: Not applicable. There is no training set or associated ground truth in this context.
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FEB 26 2014
Traditional 510(k) Summary
The following 510(k) summary has been prepared pursuant to requirements specified in 21CFR 807.92.
807.92(a)(1)
| Submitter Information | |
|---|---|
| EB Neuro, S.p.A.Via Pietro Fanfani 97/aFlorence, Italy 50127 | |
| Contact Person: | Allison Scott317.228.8719Allison.Scott@Navigant.com |
| Date: | January 17, 2014 |
| 807.92(a)(2) | |
| Devices | |
| Common Name: | Physiological Signal Amplifier |
| Trade Name: | Nemus 2 |
| Classification Name(s): | Physiological Signal Amplifier |
| Classification Number: | 21 CFR 882.1835 Physiological signal amplifier, Product Code GWL21 CFR 882.1870 Evoked response electrical stimulator, Product CodeGWF21 CFR 882.1890 Evoked response photic stimulator, Product Code GWE21 CFR 882.1900 Evoked response auditory stimulator, Product CodeGWJ |
| Regulatory Class: | Class II |
| 807.92(a)(2) |
| Predicate Device(s) | ||
|---|---|---|
| Device | Owner | 510(k) |
| Nemus 1 | EB Neuro | K073415 |
| BE Plus LTM | EB Neuro | K121996 |
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807.92(a)(4)
Device Description
The Nemus 2 System is made up of the Nemus 2 Amplifier/Stimulator, an AC/DC converter to power the amplifier, a "junction box" to connect the system to the Host PC, and (optionally) by a dedicate keyboard and a Flash LED stimulator.
The Nemus 2 System is intended to acquire bioelectric signals produced by the patient's central and peripheral nervous system and muscles. The acquired signals are transmitted to a PC during recording of neurophysiology examinations. The device may use electrical stimulus, sound stimulus, or visual stimulus for use in evoked response analysis.
The Nemus 2 System is an amplifier/stimulator device especially developed to amplify biological signals. The amplifier captures the biological signal from the human body through specialized sensors or electrodes, amplifies the very low electrical signal, and filters it to accomplish an antialiasing in order to make an optimal ANALOG to DIGITAL conversion. The data, once converted in numerical form, are "passed" to a host computer, which at this point is free to elaborate the data following the logic of the application software running on the host. The Nemus 2 System is not involved in the data management performed by the host.
807.92(a)(5)
Intended Use
The Nemus 2 System is intended to acquire the bioelectric signals produced by the patient's central and peripheral nervous system and muscles. The acquired signals are transmitted to a PC during recording of neurophysiology examinations. The Nemus 2 System consists of a physiological signal amplifier, an evoked response auditory stimulator, an evoked response electrical stimulator, and an evoked response photic stimulator. The user needs to assure compatibility of the Nemus 2 System to the other components of the user's own system.
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807.92(a)(6)
Technological Characteristics
The Nemus 2 is very similar to the Nemus 1 both from the hardware and the software point of view. Nemus 2 may be considered an "enhanced" version of Nemus 1. Practically the Nemus 1 with an added internal board deputed to the Acquisition of the 20 EEG/EP channels. The case is practically identical with the obvious exception of the upper panel in which, in the Nemus 2 have been allocated the input sockets for the added channels.
In particular in relation to the internal stimulators:
- -The audio stimulator is absolutely identical
- । The electric stimulator of the Nemus 2 is the same of the Nemus 1, but with the difference that in the Nemus 2 the electric pulse may be delivered to 5 different output sockets. Under control of the firmware the stimulus may be delivered on one of this 5 output, but only one may be active at the same time, so also the Nemus 2 simulator has "only" one output. Apart from this aspect the two stimulators are identical.
The two devices use the same AC/DC mains adapter.
Parts of the system external the "Base unit" (the amplifier), i.e. the connection box, the link cable, the stimulation probe, the optional dedicated myographic keyboard, are the same for both devices.
The firmware is substantially the same with the only obvious exception of the added 20 EEG/EP channels. Apart from this, the host communication protocol is the same for both devices.
Differently from the Nemus 2 can handle, as an option, the EBNeuro Flash LED stimulator, useful during EEG or Visual Evoked Potential exams.
The Nemus 2 20 EEG/EP channels use the same technology of the 64 channels of the BE Plus LTM.
The part of Nemus 2 host communication protocol related to the transmission of the EEG data is substantially the same to the BE Plus LTM due to the fact that the processing architecture is very similar.
The Nemus 2 and BE Plus LTM devices can handle the same (optional) EBNeuro Flash LED stimulator.
The Nemus 2 and BE Plus LTM devices use the same AC/DC mains adapter. However the BE Plus LTM may be powered also from internal batteries.
An obvious difference is that the BE Plus LTM is not capable to hannels due to absence of internal stimulator and due to the technical characteristic of its acquisition channels (band, sampling rate, etc)
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Substantial Equivalence Comparison Table
| ProductCharacteristic | Nemus2 OEM System(submission device) | Nemus1 System(Predicate Device) | BE Plus LTM(Predicate Device) |
|---|---|---|---|
| Regulatory | |||
| Manufacturer | EBNeuro S.p.A. | EBNeuro S.p.A. | EBNeuro S.p.A. |
| 510(k) number | TBA | K073415 | K121996 |
| Device class | Class II | Class II | Class II |
| Product code | GWL, GWF,GWJ, GWE | IKN, GWF,GWJ,JXE | GWL |
| Device type | Physiological signalAmplifier, Electricalstimulator, Audio, photicstimulator | Electromyograph | Physiological signalAmplifier, |
| Regulation Number | 882.1835 | 890.1375 | 882.1835 |
| Product | Nemus2 Amplifier(submission device) | Nemus1 System(Predicate Device) | BE Plus LTM(Predicate Device) |
| Characteristic | |||
| Labeling | |||
| Intended use | The Nemus 2 System isintended to acquire thebioelectric signalsproduced by the patient'scentral and peripheralnervous system andmuscles. The acquiredsignals are transmitted to aPC during recording ofneurophysiologyexaminations.The Nemus 2 Systemconsists of a physiologicalsignal amplifier, anevoked response auditorystimulator, an evokedresponse electricalstimulator, and an evokedresponse photic stimulator.The user needs to assurecompatibility of theNemus 2 System to theother components of theuser's own system. | The Nemus1 system isintended to monitor,record and display thebioelectric signalsproduced by muscles, tostimulate peripheralnerves and to monitorrecord and display theelectrical activityproduced by nerves to aidthe clinician in thediagnosis and prognosis ofneuromuscular disease(EMG).The device may useelectrical stimulus orsound stimulus for use inevoked responsemeasurements (EP). | Acquisition of EEG,polygraphy andpolysomnographysignals andtransmission of these toa PC during recordingof neurophysiologyexaminations |
| Warnings | Items related to off-label use | same | same |
| Contraindication | Items related to designand indicated uselimitations, such as notfor use in the presenceof flammableanesthetics or inconjunction withdefibrillation equipment | same | same |
| Target population | Pediatric through adult | same | same |
| Environment of use | Hospitals, laboratory,institutions, or other testenvironmentsThe device may be placedin Intensive Care Unit or | Hospitals, institutions,or other testenvironments. | Hospitals,institutions, or othertest environments |
| Product Characteristic | Nemus2 Amplifier(submission device) | Nemus1 System(Predicate Device) | BE Plus LTM(Predicate Device) |
| Prescription status | Operating Room for continuous recording.Available only on the order of a physician | same | same |
| User Service | No user service allowed | same | same |
| Design - General | |||
| The device acquirebioelectric signalsproduced bymuscles and nerves(EMG) | YES | YES | NO |
| Device acquire theelectrical activity ofthe brain (EEG/EP) | YES | NO | YES |
| Patient inputs | 2 EMG channels20 EEG/EP channels | 2 EMG channels | 64 EEG channels |
| Signal acquisition | Analog-to-digitalconversion at variablesampling rate | same | same |
| Safety Standards | IEC 60601-1IEC 60601-1-1IEC 60601-1-2IEC 60601-1-4IEC 60601-2-26IEC 60601-2-40 | IEC 60601-1IEC 60601-1-1IEC 60601-1-2IEC 60601-1-4IEC 60601-2-40 | IEC 60601-1IEC 60601-1-1IEC 60601-1-2IEC 60601-1-4IEC 60601-1-6IEC 60601-2-26 |
| Patient circuitryisolation | OpticEMG channels inputs,electrical stimulatoroutputs: BF TypeAcoustic stimulatorheadphones: BF TypeExternal serial ports andI/O: B TypeEP\EEG channels inputs:CF Type | OpticEMG channels inputs,electrical stimulatoroutputs: BF TypeAcoustic stimulatorheadphones: BF TypeExternal serial ports andI/O: B Type | OpticPatient isolation BFtypeAuxiliary I/Ocomponents ports:B type |
| ProductCharacteristic | Nemus2 Amplifier(submission device) | Nemus1 System(Predicate Device) | BE Plus LTM(Predicate Device) |
| System Components | Nemus 2 Base Unit(Amplifier)AC/DC AdapterDedicated Keyboard(optional)LED Flash Stimulator(optional) | Nemus 1 Base Unit(Amplifier)AC/DC AdapterDedicated Keyboard(optional) | Amplifier UnitAC/DC AdapterRemovable 64/32 ch.Patient BoxRechargeable batterypackBattery pack chargerMixed power/Ethernetlink cablingExpansion cableLED Flash Stimulator(optional) |
| Amplifier-Computerinterface | LAN Ethernet IEEE 802.3 | same | "wired LAN "ETHERNET/IEEE802.3or"wireless LAN "WLAN/IEEE 802.11 |
| Amplifier PowerSupply | External IEC 60601-1mains adapter | same | External IEC 60601-1mains adapterorInternal battery pack |
| Size (H/W/D) mm | Nemus 2 Amplifier170 (L) x 125 (W) x 35(H) (mm) | Nemus 1 Amplifier170 (L) x 125 (W) x 35(H) (mm) | 188 (L) x 148 (W) x 40(H) (mm) |
| Weight | Nemus 2 Amplifier0.6 Kg | Nemus 1 Amplifier0.45 Kg | 0.5 Kg |
| Case material | Nemus 2 AmplifierPolicarbonateMacrolon 6557 UL VO | Nemus 1 AmplifierPolicarbonateMacrolon 6557 UL VO | ABS Resin -(AF312B). |
| Product | Nemus2 System | Nemus1 System | BE Plus LTM |
| Characteristic | (submission device) | (Predicate Device) | (Predicate Device) |
| Design - Acquisition | |||
| Number of channels | 2 EMG20 EEG/EP | 2 EMG | 64 EEG |
| CMRR | >100 dB | >100 dB | >98 dB |
| IMRR | >100 dB | >100 dB | >98 dB |
| Input impedance | EMG Channels: same asNemus 1 | EMG Channels :>100 MΩ | EEG Channels: |
| EEG/EP channels:same as BE Plus LTM | Comm. Mode : 3.3 MΩDifferential : 6.6 MΩ | ||
| Noise | EMG Channels : < 0.3µVrms (0.1 – 100 Hz)EEG/EP channels: <20nV/√Hz (10-10KHz) | EMG Channels : < 0.3µVrms (0.1 - 100 Hz) | EEG Channels:<0.3µVrms (@256 Hzsampling rate ) |
| A/D conversion | 24 bit (2 EMG bipolarchannels )16bit (20 EEG/EPunipolar channels) | 24 bit (2 EMG bipolarchannel) | 16 bit (64 EEG unipolarchannels) |
| Sampling rate | 16384 Hz (EEG/EP ch)32768 Hz (EMG ch)Oversampling = Fsx 128 | 32768 Hz (EMG ch)Oversampling = Fs x128 | 8192 Hz/Channel |
| Antialiasing Low passfilter | EMG ch. : 20 KHzEEG/EP ch, 2 KHz | EMG ch. : 20 KHz | 2KHz 3rd order filter |
| High-pass Filter | 1.6s (0.1 Hz) or16ms(10Hz)(EMGchannels)1.6/160 ms (0.1/1 Hz)(EEG/EP channels | 1.6s (0.1 Hz) or16ms(10Hz)(EMGchannels) | selectable 0.1/10 Hz1st order filter |
| Trigger mode | Free, Auto, Internal,External | same | na |
| Ohmmeter | 0-100 kOhm (auto fullscale) | same | same |
| ProductCharacteristic | Nemus System(submission device) | Nemus1 System(Predicate Device) | BE Plus LTM(Predicate Device) |
| Design - Stimulators | |||
| Electric Stimulator | Type: constant currentN. output : 1Max output : 100 mAPulse width: 0.05 - 1msMode: single, train | Type: constant currentN. output : 1Max output : 100 mAPulse width: 0.05 - 1msMode: single, train | None |
| Audio Stimulator | Output mode: click, toneSound pressure: 0-132dB SPLPhase: condens., raref.,alternateSignal frequency: 125-8000 HzPlateau time: 1-200 msRise/fall time: 1-100 msMask level: -40 - +10dB (relative)Click width: 1-100 $\mu$ sStimulus presen. Left,right, binauralOutput: Headset TDH39 | Same audio stimulator | None |
| Visual Stimulator | Led Flash Stimulator(optional - same deviceas BE Plus LTM) | None | Led Flash Stimulator(optional) |
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807.92(b)(1)
Summary of Non-Clinical Tests
The devices have been evaluated for electrical, electromagnetic, and mechanical safety, and have been found to conform to the following medical device safety standards.
- . IEC 60601-1
- . IEC 60601-1-1
- . IEC 60601-1-2
- . IEC 60601-1-4
- . IEC 60601-2-26
- IEC 60601-2-40 .
Verification testing was conducted to demonstrate that the Nemus 2 met technical specifications including saturation, polarization, offset & gain, noise, CMRR, IMRR, and input impedance. The testing successfully verified that the Nemus 2 meets the technical specifications.
807.92(b)(2)
Summary of Clinical Tests
No clinical tests were performed.
807.92(b)(3)
Conclusion
The Nemus 2 is substantially equivalent to the legally marketed devices and conforms to applicable medical device safety and performance standards.
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Image /page/10/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo features a stylized eagle or bird-like symbol with three curved lines representing its wings or body. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular fashion around the bird symbol. The logo is in black and white.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
February 26, 2014
EB Neuro, S.p.A. c/o Ms. Allison Scott, RAC Navigant Consulting, Inc. 9001 Wesleyan Road, Suite 200 Indianapolis, IN 46268
Re: K133517
Trade/Device Name: Nemus 2 System Regulation Number: 21 CFR 882.1835 Regulation Name: Physiological Signal Amplifier Regulatory Class: Class II Product Code: GWL Additional procodes: GWF, GWE, GWJ Dated: January 20, 2014 Received: January 22, 2014
Dear Ms. Scott:
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 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
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Page 2 - Ms. Allison Scott, RAC
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 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,
Joyce M. Whang -S
for 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
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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
Indications for Use
510(k) Number (if known) K133517
Device Name Nemus 2 System
Indications for Use (Describe)
The Nemus 2 System is intended to acquire the bioced by the patient's central and peripheral nervous system and nuscles. The acquired signals are transmitted to a PC during recording of neurophysiology examinations. The Nenus 2 System consists of a physiological signal amplifier, an evoked response auditory stimulator, an evoked response electrical stimulator, and an evoked response photic stimulator. The user needs to assure compaibility of the Nemus 2 System to the other components of the user's own system.
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)
Form Approved: OMB No. 0910-0120
Expiration Date: December 31, 2013
See PRA Statement on last page.
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)
Jovce N
§ 882.1835 Physiological signal amplifier.
(a)
Identification. A physiological signal amplifier is a general purpose device used to electrically amplify signals derived from various physiological sources (e.g., the electroencephalogram).(b)
Classification. Class II (performance standards).