(181 days)
The eVox System is intended for the acquisition, display, and storage, of electrical activity of a patient's brain including electroencephalograph (EEG) and event-related potentials (ERP) obtained by placing two or more electrodes on the head to aid in diagnosis.
The eVox System is intended for the acquisition, display, and storage, of electrical activity of a patient's brain including electroencephalograph (EEG) and event-related potentials (ERP) obtained by placing two or more electrodes on the head to aid in diagnosis.
The medical system includes the "eVox System" amplifier device, accessories, and a computer (laptop computer or tablet device with internal battery and power cord).
The hardware and ancillary components used in conjunction with the eVox System include an EEG cap, the eVox Amplifier, a charging kit (that consists of a USB cable, clip kit, and wall adapter), a Subject Response Device and a Base Station laptop computer. The software on the Base Station laptop computer is intended for device functioning.
The eVox System consists of two software components:
. Base Station laptop computer software: pre-loaded Evoke software EVO-002-400-BIATS.
. Firmware running on the eVox Amplifier PN SW-MSP430.
The Base Station laptop is running on a Windows Operating System and is paired with the eVox Amplifier with Bluetooth wireless technology. The Evoke software runs on the Base Station computer and has a graphic user interface that allows the clinician to set up a patient and create a new patient record, conduct a study to collect EEG and ERP data, view live EEG and ERP data on the Base Station monitor, and export recorded data to a file.
Firmware for the eVox System resides on the eVox Amplifier. The purpose of the eVox amplifier firmware is to acquire electrophysiology data from the patient and transmit it to the Base Station.
The Amplifier operational mode is controlled wirelessly via the Evoke software. In addition to 19 channels of EEG recording the device includes a mode to measure the cap electrode impedances. This is useful for determining if the electrodes are making a good electrical connection with the scalp at each electrode location.
The primary software outputs are EEG and ERP data files. These data files are written as floating point numbers in binary format, which represent the electrical potential on each of the 19 EEG channels in microvolts.
The eVox System amplifier device does not come in direct contact with patients. Accessories that contact patients, such as the EEG electrode cap, are the same as used with legally marketed devices or are comprised of the same materials as legally marketed accessories.
The eVox System is intended for prescription use in any healthcare, medical, or athletic or sports clinics, or outside of medical facilities such as in the sports arena under the supervision of a physician. Also, investigations can be performed outside of healthcare facilities, as long as they are led by qualified medical personnel.
The device is not sterile. The device is intended for use by qualified medical personnel only and qualifies for exemption per 21 CFR 801 Subpart D «Prescription devices».
The eVox System is intended for the acquisition, display, and storage of electrical activity of a patient's brain, including electroencephalograph (EEG) and event-related potentials (ERP), obtained by placing two or more electrodes on the head to aid in diagnosis.
Here's an analysis of the acceptance criteria and study information provided:
1. Table of Acceptance Criteria and Reported Device Performance
| Test Name | Acceptance Criteria (IEC 60601-2-26 Performance Limits) | Reported Device Performance (eVox System) | Met Criteria? |
|---|---|---|---|
| Accuracy of Signal Reproduction | Error < 20% | Pass: Accurately reproduces EEG signals over the specified range | Yes |
| Input Dynamic Range and Differential Offset Voltage | Amplitude error < 10% (at 300mV offset) | At 300mV Offset: 100% error (Fail); At 187mV Offset: 1.5% error (Pass) | Partially |
| Input Noise | Max 6 µV peak-to-valley | Maximum noise: 3.4 µV | Yes |
| Frequency Response | Output amplitude > 71%, < 110% | 0.5 Hz: 100% (Pass); 5 Hz: 105% (Pass); 50 Hz: 76% (Pass) | Yes |
| Common Mode Rejection | Output amplitude < 10mm (= 100µVpp) | With 0 DC Offset: 67.3µVpp (Pass); With 187mV dc Offset: output is saturated (Fail) | Partially |
2. Sample Size Used for the Test Set and Data Provenance
The provided summary does not specify a sample size for a test set in terms of patient data or data provenance. The performance data section describes technical validation tests against established standards (IEC 60601-2-26), not clinical studies with patient data. These tests were conducted by accredited laboratories.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
This information is not applicable as the provided performance data focuses on technical verification against international standards and not on clinical performance evaluated against a ground truth established by experts.
4. Adjudication Method for the Test Set
This information is not applicable as the performance data details technical compliance tests against pre-defined limits in standards, not clinical evaluations requiring expert adjudication.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No, an MRMC comparative effectiveness study was not indicated in the provided document. The submission focuses on demonstrating substantial equivalence through technical performance data and comparison to predicate devices, not on comparing human reader performance with and without AI assistance.
6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study
The provided document describes the standalone performance of the eVox System in terms of its ability to acquire, display, and store EEG/ERP data and its compliance with relevant electrical and safety standards. The performance data presented (e.g., accuracy of signal reproduction, input noise) are measurements of the device's inherent technical capabilities, independent of human interpretation or intervention beyond basic operation. The device itself is an acquisition and display system, not an AI-driven diagnostic algorithm that would require a "human-in-the-loop" performance study in the same way an AI for image interpretation would.
7. Type of Ground Truth Used
The "ground truth" for the performance data presented is based on pre-defined technical specifications and limits set by international standards, specifically IEC 60601-2-26:2012 for electroencephalographs. For electrical safety and EMC, the ground truth is compliance with IEC 60601-1 and IEC 60601-1-2 standards.
8. Sample Size for the Training Set
The document does not mention a training set as this device is an EEG/ERP acquisition and display system. It does not appear to involve machine learning or AI algorithms that require a training set in the conventional sense for medical imaging or diagnostic interpretation.
9. How the Ground Truth for the Training Set Was Established
Since there is no mention of a training set for machine learning or AI, the establishment of ground truth for a training set is not applicable.
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Image /page/0/Picture/0 description: The image shows the logos of the Department of Health and Human Services and the Food and Drug Administration (FDA). The Department of Health and Human Services logo is on the left, and the FDA logo is on the right. The FDA logo is a blue square with the letters "FDA" in white, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue.
December 13, 2017
Evoke Neuroscience, Inc. % Marinela Gombosev Executive VP Operations and Marketing Evoke Neuroscience 200 Valencia Dr. Suite 109 Jacksonville, North Carolina 28546
Re: K171781
Trade/Device Name: eVox System Regulation Number: 21 CFR 882.1400 Regulation Name: Electroencephalograph Regulatory Class: Class II Product Code: GWO. GWJ Dated: November 10, 2017 Received: November 13, 2017
Dear Ms. Gombosev:
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 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);
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and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Michael J. Hoffmann -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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Indications for Use
510(k) Number (if known) K171781
Device Name eVox System
Indications for Use (Describe)
The eVox System is intended for the acquisition, display, and storage, of electrical activity of a patient's brain including electroencephalograph (EEG) and event-related potentials (ERP) obtained by placing two or more electrodes on the head to aid in diagnosis.
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) | □ |
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510(k) Summary
- l. SUBMITTER
Evoke Neuroscience 200 Valencia Drive, Suite 109 Jacksonville NC 28546 United States David Hagedorn, PhD, CEO, CSO Phone: (917) 261-6096 Fax: (855) 386-5397
CONTACT PERSON
Marinela Gombosev, EVP Operations and Marketing Evoke Neuroscience, Inc. 200 Valencia Drive, Suite 109 Jacksonville NC, 28546 United States Cell Phone: (949) 584-7331 Office Phone: (949) 330-7216 Fax: (855) 386-5397 Email: 510k@evokeneuroscience.com
DATE PREPARED
June 6, 2017
DEVICE II.
Trade/Proprietary Name: eVox System Common/Usual Name: EEG System, EEG Amplifier Classification Name: Electroencephalograph Classification Regulation: 882.1400 Product Code: GWQ, GWJ Device Class: Class 2
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Classification Panel: Neurology
III. PREDICATE DEVICES
| Legally Marketed Device(s) | 510(k) # | Clearance Date |
|---|---|---|
| Mitsar-EEG | K143233 | 8-13-2015 |
| COGNISION EEG | K141316 | 2-13-2015 |
| Nicolet EDX System | K112052 | 3-15-2012 |
IV. DEVICE DESCRIPTION
The eVox System is intended for the acquisition, display, and storage, of electrical activity of a patient's brain including electroencephalograph (EEG) and event-related potentials (ERP) obtained by placing two or more electrodes on the head to aid in diagnosis
The medical system includes the "eVox System" amplifier device, accessories, and a computer (laptop computer or tablet device with internal battery and power cord).
The hardware and ancillary components used in conjunction with the eVox System include an EEG cap, the eVox Amplifier, a charging kit (that consists of a USB cable, clip kit, and wall adapter), a Subject Response Device and a Base Station laptop computer. The software on the Base Station laptop computer is intended for device functioning.
The eVox System consists of two software components:
- . Base Station laptop computer software: pre-loaded Evoke software EVO-002-400-BIATS.
- . Firmware running on the eVox Amplifier PN SW-MSP430.
The Base Station laptop is running on a Windows Operating System and is paired with the eVox Amplifier with Bluetooth wireless technology. The Evoke software runs on the Base Station computer and has a graphic user interface that allows the clinician to set up a patient and create a new patient record, conduct a study to collect EEG and ERP data, view live EEG and ERP data on the Base Station monitor, and export recorded data to a file.
Firmware for the eVox System resides on the eVox Amplifier. The purpose of the eVox amplifier firmware is to acquire electrophysiology data from the patient and transmit it to the Base Station.
The Amplifier operational mode is controlled wirelessly via the Evoke software. In addition to 19 channels of EEG recording the device includes a mode to measure the cap electrode impedances. This is useful for determining if the electrodes are making a good electrical connection with the scalp at each electrode location.
The primary software outputs are EEG and ERP data files. These data files are written as floating point numbers in binary format, which represent the electrical potential on each of the 19 EEG channels in microvolts.
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The eVox System amplifier device does not come in direct contact with patients. Accessories that contact patients, such as the EEG electrode cap, are the same as used with legally marketed devices or are comprised of the same materials as legally marketed accessories.
The eVox System is intended for prescription use in any healthcare, medical, or athletic or sports clinics, or outside of medical facilities such as in the sports arena under the supervision of a physician. Also, investigations can be performed outside of healthcare facilities, as long as they are led by qualified medical personnel.
The device is not sterile. The device is intended for use by qualified medical personnel only and qualifies for exemption per 21 CFR 801 Subpart D «Prescription devices».
V. INDICATIONS FOR USE
The eVox System is intended for the acquisition, display, and storage, of electrical activity of a patient's brain including electroencephalograph (EEG) and event-related potentials (ERP) obtained by placing two or more electrodes on the head to aid in diagnosis.
VI. COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICES
The following table compares the technological characteristics of the eVox System to those of the predicate devices in order to demonstrate substantial equivalence.
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Technological Comparison
| Trade Name | eVox System | MITSAR-EEG | COGNISION™ | Nicolet EDX 2 Viking Software | Comments |
|---|---|---|---|---|---|
| 510 (k) Number | K171781 | K143233 | K141316 | K112052 | |
| Product codes | GWQ, GWJ, | GWQ | GWJAdditional: OMC, OLT, | GWJAdditional:OLT, GWF, GZP, IKN, JXE, GWE | Product contains multiple productcodes which are generally requiredfor a complete system.The eVox System and the Mitsar –EEG device share the product code:GWQ: Full Montage SystemThe eVox System, the COGNISIONsystem and Nicolet EDX systemshare the product code:GWJ: Evoked response auditorystimulator |
| Indications for Use | The eVox System isintended for theacquisition, display, andstorage, of electricalactivity of a patient's brainincludingelectroencephalograph(EEG) and Event-relatedPotentials (ERP) obtainedby placing two or moreelectrodes on the head toaid in diagnosis. | The device Mitsar-EEG isintended to acquire,display and store theelectrical activity of apatient's brain obtainedby placing two or moreelectrodes on the headto aid in diagnosis. | The COGNISION system is foruse by qualified clinicalprofessional in private practiceoffices or small clinical settingsfor the acquisition, display,analysis, storage, reporting andmanagement ofelectroencephalograph (EEG)and auditory evoked potentials(AEP) information. | The Nicolet EDX is intended for theacquisition, display, analysis,reporting and management ofelectrophysiological informationfrom the human nervous andmuscular system including NerveConduction (NCS).Electromyography (EMG), EvokedPotentials (VEP), Auditory (AEP)Somatosensory Evoked Potentials(SEP), Electroretinography (ERG)Electrooculography (EOG), P300,Motor Evoked Potential (MEP). The | |
| Trade Name | eVox System | MITSAR-EEG | COGNISION™ | Nicolet EDX 2 Viking Software | Comments |
| Nicolet EDX with Viking Softwaremay be used to determineautomatics responses to physiologicstimuli by measuring the change inelectrical resistance between twoelectrodes (Galvanic Skin Responseand Sympathetic Skin Response).Autonomic testing also includesassessments of RR intervalvariability. The Nicolet EDX withViking Software is used to detectthe physiologic function of thenervous system, for the location ofneural structures during surgeryand to support the diagnosis ofneuromuscular disease orcondition. | |||||
| The listed modalities do not includeoverlap in functionality. In general,Nerve Conduction Studies measurethe electrical responses of thenerve; Electromyography measuresthe electrical activity of the muscleand Evoked Potential measureelectrical activity from the CentralNervous System.The Nicolet EDX with VikingSoftware is intended to be used bya qualified healthcare provider. | |||||
| Principle ofOperation | The eVox System device isused for acquisition ofphysiological signals usingtwo or more channels ofelectroencephalography | The Mitsar EEG consistsof biosignal amplifier,USB cable, USB dongleand software. Themedical system includes | The COGNISION EEG/EP Systemis a combination device forreduced montage recordingand display ofelectroencephalographic (EEG) | The Nicolet EDX system with VikingSoftware (Viking EDX) is designedfor the acquisition, display, analysis,reporting and management ofelectrophysiological information | The eVox System has a principle ofoperation that closely matches thatof its predicates. All devices useskin coupling methods, eitherthrough electrodes or sensors |
| Trade Name | eVox System | MITSAR-EEG | COGNISION™ | Nicolet EDX 2 Viking Software | Comments |
| (EEG) from the scalp. Itconsists of an eVoxamplifier, a laptopcomputer (base station),a patient EEG cap, subjectresponse button, earbuds, and a charging cord.The eVox amplifier andsoftware provide a meansto:a) initiate a study, trackuser EEG and ERP dataand enter text orquestionnaireinformation,b) acquire and savesignals to the memoryof the device,c) transmit signal datafrom the device,d) Visually inspect theacquired signal.e)Manage Event-related Potentials | "Mitsar EEG" device andcomputer (stationary PCwith uninterruptiblepower supply (UPS) orlaptop with internalbattery). The Mitsar EEGdevice is an amplifierwhich receives patientEEG data from a patientEEG cap or EEGelectrodes. | and evoked potentials (EP) testdata.The system uses elastic bandsto accurately position 10electrode pods around thehead.EEG signal amplification,conditioning, and A/Dconversion is performed byelectronic circuits closelycoupled to the electrode podsthrough short flexible printedwires.The headset is connected by acable to a handheld control unitand data acquisition box (HCU).The HCU communicates via awireless data link to a WindowsPC to stream EEG data.Software on the PC is used tosetup the tests and view andevaluate the resultant test datausing standard EEG/EP displaymethods. | from the human nervous andmuscular systems.The system is designed to performnerve conduction studies (NCS),needle electromyography (EMG)testing, evoked potential (EP)testing, and intra-operativemonitoring (IOM). The system canalso perform multi-modalityrecording through Multi-modeprograms (MMP). Viking EDXprovides a variety of tests spanningthe various modalities. | which transmits patient EEG andERP from the surface of the scalp toan amplifier.The connection between theamplifier and electrodes is a wiredconnection for the devices.All devices convert the analog datainto digital data which is thentransmitted to a base station orcomputer.Once transmitted to the basestation, the devices display andstore the data on the base stationand allow the user to export thedata to a file. | |
| Patient population | All age groups | All age groups | Adults | Unknown | |
| Use environment | Intended for use in anyhealthcare, medical, orathletic or sports clinics,or outside of medicalfacilities such as in thesports arena under thesupervision of a physician.Also, investigations can be | Intended for use infunctional diagnosticswards and departmentsat out-patient clinics,hospitals, healthresearch institutes,health centers and othermedical institutions. | Physicians' Offices | Physicians' Offices | |
| Trade Name | eVox System | MITSAR-EEG | COGNISION™ | Nicolet EDX 2 Viking Software | Comments |
| performed outside ofhealthcare facilities, aslong as they are led byqualified medicalpersonnel. | Also, investigations canbe performed outside ofhealthcare facilities, aslong as they are led byqualified medicalpersonnel. | ||||
| Safety class | Class II | Class II | Class II | Class II | |
| Biocompatibility | Per ISO 10993-1 | Per ISO 10993-1 | Per ISO 10993-1 | Per ISO 10993-1 | |
| Intended Use | The eVox System isintended for theacquisition, display, andstorage, of electricalactivity of a patient's brainincludingelectroencephalograph(EEG) and Event-relatedPotentials (ERP) obtainedby placing two or moreelectrodes on the head toaid in diagnosis. | The Mitsar-EEG isintended to acquire,display and store theelectrical activity of apatient's brain by placingtwo or more electrodeson the head to aid indiagnosis. | The COGNISION system is acombination device for reducedmontage recording and displayof electroencephalograph (EEG)and evoked potentials (EP) testdata. | The Nicolet EDX with VikingSoftware (Viking EDX) is intendedfor the acquisition, display, analysis,reporting and management ofelectrophysiological informationfrom the human nervous andmuscular systems. The system isdesigned to perform nerveconduction studies (NCS), needleelectromyography (EMG) testing,evoked potential (EP) testing, andintra-operative monitoring (IOM).The system can also perform multi-modality recording through Multi-mode programs (MMP).Viking EDXprovides a variety of tests spanningthe various modalities. | |
| ERP StimulusModality | Auditory; Visual | None | Auditory | Auditory; Visual | |
| SystemComponents | eVox System consists of : | "Mitsar EEG" consists of | COGNISION™ consists of:• Head Set | CareFusion Nicolet EDX 2 VikingSoftware consists of: | |
| Trade Name | eVox System | MITSAR-EEG | COGNISION™ | Nicolet EDX 2 Viking Software | Comments |
| • an eVox amplifier,• a laptop computer(base station),• a patient EEG cap,• subject responsebutton, ear buds,• and a charging cord. | • biosignal amplifier,• computer(stationary PC withuninterruptiblepower supply (UPS)• or laptop withinternal battery)• USB cable,• USB dongle• and software. | • Auditory stimulator• Handheld Control Unit(HCU) including InterfaceSoftwareConnecting Headset cablebetween the headset andthe handheld control unit | • EDX Console• Electrical stimulators• Auditory Stimulator• Trigger input/output• LED google interface ControlPanel• Amplifier• Computer Monitor• Keyboard,Mouse• Printer | ||
| ERP Paradigm(Auditory andVisual Stimuli) | P300 Oddball- Single Stimulus- Single Deviant- 2 Deviant- Active and Passive | None | P300 Oddball- Single Stimulus- Single Deviant- 2 Deviant- Active and Passive | P300 Oddball- Single Stimulus- Single Deviant- 2 Deviant- Active and Passive | |
| ERP TaskResponse | User Buttons | User Buttons | User Buttons | User Buttons | |
| Skin Coupling | Custom Electrode Bandand Gel | Custom Electrode Bandand Gel | HydroDot Biosensor | Discrete Electrode Wires | The eVox system, Mitsar EEG, andNicolet EDX use the same methodof utilizing a conductive gelbetween electrode and the skinThe COGNISION system usesHydroDot Biosensor. |
| Trade Name | eVox System | MITSAR-EEG | COGNISION™ | Nicolet EDX 2 Viking Software | Comments |
| Sterile | No | No | No | No | |
| Single Use | No | No | No | No | |
| Shelf life | Durable good | Durable good | Durable good | Durable good | |
| TypicalBiopotentialSignals Recorded | Electroencephalography(EEG), EP/ERP | Electroencephalography(EEG) | Electroencephalography (EEG),EP/ERP | Electroencephalography (EEG),EP/ERP | The eVox System, the COGNISIONsystem and the Nicolet EDX recordEEG and EP/ERP.TheMitsar-EEG device does |
| Number of SignalRecordingChannels | Up to 21 | Up to 21 | Up to 10 | 7 | nothave EP/ERP modality. |
| RecordingChannels Locationand PositioningSystems | Fz,Cz,Pz,F3,P3,F4,P4Utilizing elastic bandsusing distance ratiosconsistent with the 10-20System | Fz,Cz,Pz,F3,P3,F4,P4Utilizing elastic bandsusing distance ratiosconsistent with the 10-20 System | Fz,Cz,Pz,F3,P3,F4,P4Utilizing elastic bands usingdistance ratios consistent withthe 10-20 System | Variable Discrete electrode wires | The eVox system, the Mitsar systemand the COGNISION system use thesame exact electrode placementconfiguration and a similar methodposition of electrodes.The Nicolet EDX system has avariable electrode configurationthat may be configured in similarmanner. |
| Impedance Test | Yes | Yes | Yes | Yes | |
| Amplifier InputImpedance | > 10 MΩ | > 200 MΩ | > 60 MΩ | > 1000 MΩ | Performance testing per IEC 60601-2-26:2012 confirmed 10 MΩ issufficient to eliminate distortion inthe measured signal. |
| Trade Name | eVox System | MITSAR-EEG | COGNISION™ | Nicolet EDX 2 Viking Software | Comments |
| Analog to DigitalConversion | 24 Bit | 16 Bit | 16 Bit | 24 Bit | |
| Sampling Rate | 250 Hz | 500 Hz | 125/250 Hz | 384 KHz | Clinically relevant humanelectrophysiology does not exceed100 Hz and therefore there is notechnical need to sample above250 Hz. |
| Common moderejection | >110 dB | >100 dB | >90dB | >110dB | |
| Analysis Software | Embedded, commerciallyavailable, and userdefined. | Embedded, commerciallyavailable and userdefined. | Embedded, commerciallyavailable, and user defined. | Embedded, commercially availableand user defined. | |
| Interface withAmplifier | Class 2 Bluetooth® version2.0 to PC | USB cable to PC | Bluetooth 2.0/4.0 | USB cable to PC | |
| Power Supply | Li-Ion Battery, with USBcable for charging thebattery. | USB cable | Li Ion Battery | Mains (100-240 VAC) | |
| EEG inputterminals | up to 19 channels | up to 21 channels | Up to 7 channels | 2-8 channels | |
| Resolution | 24 bits | 16 bits | 16 bits | 24 bits | |
| Trade Name | eVox System | MITSAR-EEG | COGNISION™ | Nicolet EDX 2 Viking Software | Comments |
| Band Pass | 0.1 to 50 Hz | 0.162-70 Hz | 0.4 to 40 Hz | Unknown | The Band pass is the subset of theCognition System.The eVox system meets thefrequency requirements of IEC60601-2-26 (0.5Hz-50 Hz) |
| Noise | 2-3 uVp-p | < 1.5μVp-p | ≤1µV RMS | <0.6µV RMS | The measured noise of 2-3uVp-pfor the eVox System is well withinthe IEC 60601-2-26:2012requirement of 6 uVp-p. |
| Type | Burst (White Noise) | None | Unknown | Click, Pip, Burst | The eVox system uses a burst typenoise stimulus to evoke an ERP. |
| Duration | 100ms | None | 50ms | 0.05 to 1 ms | 100ms is a typical length forevoking an ERP. |
| Side | Both | None | Unknown | Left, Right, Both | |
| Frequency Range | 440 Hz-16kHz | None | Unknown | 250Hz-8kHz | The eVox system generates a soundwith a frequency range of 440Hz-16kHz which is a sufficiently wideenough band for human hearing. |
| Intensity | 0 to 85dB | None | Unknown | 0 to 139dB pSBL | The sound emitted by the eVoxsystem is a flat white noise burst,therefore the peak and average isthe same.Maximum decibel level is 85dB,well below 125dB (no risk to user). |
| Noise Patterns | 12.5% occurrencerandomly distributed over | None | 10 % occurrence within 10-60minutes | Unknown | The balance of this pattern is bestto elicit the desired ERPs. |
| Trade Name | eVox System | MITSAR-EEG | COGNISION™ | Nicolet EDX 2 Viking Software | Comments |
| 10 minutes | Not Stated | Not Stated | |||
| Input VoltageRange | +/-150 mV | 5 mV | Not Stated | Not Stated | Due to the 24x gain that is appliedto the A/D channels by the eVoxfirmware the dynamic range is +/-150 mV for the eVox System whichis sufficient for its use environment |
| Safety StandardsCompliance | IEC 60601-1: 2005 +CORR. 1:2006 + CORR.2:2007 + AM1:2012 (orIEC 60601-1: 2012 reprint)EN 60601-1-2:2012IEC 60601-2-26:2012 | EN 60601-1:2005EN 60601-1-2:2005EN 60601-2-26 | UL 60601-1:2003EN60601-1-2/A1:2007EN60601-1-2/A1:2007EN 60601-2-26IEC 60601-2-40 | EN / IEC 60601-1:1998+A1:1991+A2:1995IEC 60601-1-1:2000EN/IEC 60601-1-2: Ed 2.0+A1:2004IEC 60601-2-40: 1998, Ed 1,UL60601-1:2003-04-25 Ed1, Rev2003/06/30 | |
| OperatingEnvironment | 0 to +45 °C, Relativehumidity, 5% to 95% non-condensing | Not Published | 60-90 °F | Not Published | |
| StorageEnvironment | -20° to 45° C , Relativehumidity, 5% to 95% non-condensing | Not Published | Not Published | Not Published |
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VII. PERFORMANCE DATA
a. Verification and Validation Testing
Verification and validation testing was performed for the eVox System and the required documentation was provided with the 510k application per the FDA's Guidance for Industry and FDA Staff, Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices and General Principles of Software Validation.
b. Performance Testing
Extensive functional device testing and user testing has been performed with satisfactory results.
Additionally, tests have been performed by the accredited laboratories and show full compliance with standards below with the exception of DC offset, which passed under a relaxed condition. This deviation is acceptable for the intended use of the device.
IEC 60601 - 2 - 26:2012 Medical electrical equipment - Part 2: Particular requirements for the safety of electroencephalographs.
| Test | Test Method Summary | Results / P or F(per IEC 60601-2-26performance limits) |
|---|---|---|
| Accuracy of signalreproductionPurpose: verify signal isaccurately reproduced overa range of amplitudes. | Test circuit and method per IEC 60601-2-26 clause 201.12.1.101.1. Amplitude of2Hz Triangle wave varied from 50uV to500uV.IEC 60601-2-26 Pass-Fail Limit: error < 20% | PassTest shows that Evokesystem accuratelyreproduces EEG signalsover the specified range |
| Input dynamic range anddifferential offset voltagePurpose: verify signalaccuracy in presence of dcoffset voltages. | Test circuit and method per IEC 60601-2-26 clause 201.12.1.101.2. 1mV 6HzTriangle wave with 300mV offset added.IEC 60601-2-26 Pass-Fail Limit: amplitudeerror < 10% | 300mV Offset: 100%error: Fail |
| 187mV Offset: 1.5% error:Pass |
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| Test | Test Method Summary | Results / P or F(per IEC 60601-2-26 performance limits) |
|---|---|---|
| Input NoisePurpose: verify that thesignal noise caused byamplifier does not exceedmax 6 μ V peak-to-valley | Test circuit and method per IEC 60601-2-26 clause 201.12.1.101.3. Inputs shortedtogether.IEC 60601-2-26 Pass-Fail Limit: max 6 μ Vpeak-to-valley | Maximum noise: 3.4 uV:Pass |
| Frequency ResponsePurpose: verify signal isaccurately reproduced overa range of frequencies | Test circuit and method per IEC 60601-2-26 clause 201.12.1.101.4. Triangle waveAmplitude established at 5Hz, is thenadjusted to 0.5 Hz and 50Hz.IEC 60601-2-26 Pass-Fail Limit: outputamplitude > 71%, < 110% | 0.5 Hz: 100%: Pass5 Hz: 105%: Pass50 Hz: 76%: Pass |
| Common mode rejectionPurpose: verify amplifierrejects common mode noise | Test circuit and method per IEC 60601-2-26 clause 201.12.1.101.5. Apply 1Vrms at60Hz to all inputs tied together.IEC 60601-2-26 Pass-Fail Limit: outputamplitude < 10mm (= 100uVpp) | With 0 DC Offset:67.3uVpp: PassWith 187mV dc Offset:output is saturated: Fail |
c. Safety Testing
The tests have been performed by the accredited laboratories and show full compliance with standards below:
IEC 60601-1: 2005 + CORR. 1:2006 + CORR. 2:2007 + AM1:2012 plus US Differences to: US National standard ANSI/AAMI ES60601-1: 2005 / A2:2010 (FDA recognition # 19-4).
d. Electrical Safety and Electromagnetic Compatibility (EMC)
The tests have been performed by the accredited laboratories and show full compliance with standards below. The device under consideration has passed the tests according to IEC 60601-1-2:2007.
IEC 60601-1-2 Edition 3: 2007-03, Medical Electrical Equipment - Part 1-2: General Requirements for Basic Safety and Essential Performance - Collateral Standard: Electromagnetic Compatibility
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(FDA recognition # 19-1)
VIII. CONCLUSIONS
The eVox System passed the testing according to the established specifications and the eVox System is consistent with that of the predicate devices in terms of EEG and ERP recording performance.
As part of showing substantial equivalence to the predicate devices that are subject to this 510(k) submission, Evoke Neuroscience completed a number of tests. The eVox System meets all the requirements for overall design, biocompatibility, and electrical safety confirms that the design output meets the design inputs and specifications.
The eVox System passed all testing stated above as shown by the acceptable results obtained.
The eVox System complies with the applicable voluntary standards for biocompatibility and electrical safety. The device passed all the testing in accordance with national and international standards.
§ 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).