K Number
K234095
Device Name
OtoNova/OtoNova Pro
Manufacturer
Date Cleared
2024-06-21

(178 days)

Product Code
Regulation Number
874.1050
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
This Otonova Pro device is indicated for use when there is a requirement to screen for hearing disorders by objective and non-invasive means. ABR, TEOAE and DPOAE screening test results are automatically interpreted and a clear "Pass' or 'Refer' result is presented to the user. Use of the device is indicated when the patient is unable to give reliable voluntary responses to sound, especially with infants. Use of the device facilitates the early detection of hearing loss and its characterization. Where the individual to be screened is healthy with no medical conditions related to the ear, as in the case of well-baby hearing screening, the user can be a trained screener. In all other cases the user should be an audiologist or medical professional. The TEOAE and DPOAE analytical functions of the device are indicated when objective non-invasive clinical investigations require the characterization and monitoring of the peripheral auditory function. For this purpose, the device is intended to be used by audiologists or other professionals skilled in audiology. These TEOAE and DPOAE tests are applicable to populations of any age to obtain objective evidence of peripheral auditory function.
Device Description
OtoNova is a compact, portable battery-powered electronic device which records physiological responses to sound for the purpose of hearing testing. It Is controlled wirelessly from a local controlling device. OtoNova has two hardware variants: OtoNova and OtoNova Pro. Both the OtoNova and OtoNova Pro devices have been directly engineered from Otodynamics' currently marketed Otoport OAE+ABR device, retaining all the testing algorithms of the Otoport OAE+ABR device. The primary aim of the development was to physically separate the control console from the testing device while maintaining the same performance and effectiveness. Like the predicate Otoport OAE+ABR device, both OtoNova devices can record two different physiological indicators of a functioning auditory system's peripheral response to sound namely a) Otoacoustic emission (OAEs), which are small sounds made by the inner ear in response to acoustic stimulation, and b) Auditory brainstem responses (ABRs) are tiny electrical signals emanating from the auditory brainstem in response to sound. Automatic recognition of an ABR response is referred to as AABR. During ABR or OAE testing, low-level sounds are delivered to the ear. The responses to multiple presentations of these sounds (either acoustic or electrical responses) are recorded digitally and added together to enhance repeated responses with respect to the random/ noise signals that are always present. The averaged signal is automatically analysed by the device to identify and quantify true physiological response component and to assess the degree of noise contamination. This allows the quality/ accuracy of the recording to be determined for evidence of response validity. The processed data is reported to and displayed on the controlling device.
More Information

No
The document describes "automatic analysis" and "automatic recognition" of physiological responses, but the description of the algorithms and the validation process points to traditional signal processing and template matching techniques, not AI/ML. The training and test sets are described in terms of validating a pre-existing "newborn ABR template" and the "complete ABR infant screening algorithm," which aligns with a deterministic approach rather than a learning-based one.

No.
The device is used to screen for hearing disorders and characterize and monitor peripheral auditory function, but it does not provide treatment or therapy.

Yes

Explanation: The "Intended Use / Indications for Use" section explicitly states that the device is "indicated for use when there is a requirement to screen for hearing disorders" and facilitates "the early detection of hearing loss and its characterization." It also mentions interpreting results as "Pass" or "Refer," which are indicative of a diagnostic screening process.

No

The device description explicitly states that OtoNova is a "compact, portable battery-powered electronic device" and has "two hardware variants." This indicates the presence of physical hardware components beyond just software.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In Vitro Diagnostic devices are used to examine specimens taken from the human body, such as blood, urine, or tissue, to provide information about a person's health.
  • Device Function: The Otonova Pro device records physiological responses to sound (OAEs and ABRs) directly from the patient's ear and scalp. It does not analyze samples taken from the body.
  • Intended Use: The intended use is to screen for hearing disorders by objective and non-invasive means, directly measuring the body's response to stimuli.

Therefore, based on the provided information, the Otonova Pro device falls under the category of a medical device used for physiological measurement and screening, not an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

This Otonova Pro device is indicated for use when there is a requirement to screen for hearing disorders by objective and non-invasive means. ABR, TEOAE and DPOAE screening test results are automatically interpreted and a clear "Pass' or 'Refer' result is presented to the user. Use of the device is indicated when the patient is unable to give reliable voluntary responses to sound, especially with infants.

Use of the device facilitates the early detection of hearing loss and its characterization. Where the individual to be screened is healthy with no medical conditions related to the ear, as in the case of well-baby hearing screening, the user can be a trained screener. In all other cases the user should be an audiologist or medical professional.

The TEOAE and DPOAE analytical functions of the device are indicated when objective non-invasive clinical investigations require the characterization and monitoring of the peripheral auditory function. For this purpose, the device is intended to be used by audiologists or other professionals skilled in audiology.

These TEOAE and DPOAE tests are applicable to populations of any age to obtain objective evidence of peripheral auditory function.

Product codes

EWO, GWJ

Device Description

OtoNova is a compact, portable battery-powered electronic device which records physiological responses to sound for the purpose of hearing testing. It Is controlled wirelessly from a local controlling device.

OtoNova has two hardware variants: OtoNova and OtoNova Pro.

  • OtoNova has 3 separate connectors for 3 ABR electrode connections and accepts one probe.
  • The OtoNova Pro has a combined electrode connector and accepts 2 probes (red and blue sockets).
    Both the OtoNova and OtoNova Pro devices have been directly engineered from Otodynamics' currently marketed Otoport OAE+ABR device, retaining all the testing algorithms of the Otoport OAE+ABR device. The primary aim of the development was to physically separate the control console from the testing device while maintaining the same performance and effectiveness.

Like the predicate Otoport OAE+ABR device, both OtoNova devices can record two different physiological indicators of a functioning auditory system's peripheral response to sound namely a) Otoacoustic emission (OAEs), which are small sounds made by the inner ear in response to acoustic stimulation, and b) Auditory brainstem responses (ABRs) are tiny electrical signals emanating from the auditory brainstem in response to sound. Automatic recognition of an ABR response is referred to as AABR.

During ABR or OAE testing, low-level sounds are delivered to the ear. The responses to multiple presentations of these sounds (either acoustic or electrical responses) are recorded digitally and added together to enhance repeated responses with respect to the random/ noise signals that are always present. The averaged signal is automatically analysed by the device to identify and quantify true physiological response component and to assess the degree of noise contamination. This allows the quality/ accuracy of the recording to be determined for evidence of response validity. The processed data is reported to and displayed on the controlling device.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Ear, Scalp, forehead, nape, shoulder

Indicated Patient Age Range

Infants, children and adults for OAEs. Infants for AABR.

Intended User / Care Setting

Where the individual to be screened is healthy with no medical conditions related to the ear, as in the case of well-baby hearing screening, the user can be a trained screener. In all other cases the user should be an audiologist or medical professional.
For TEOAE and DPOAE analytical functions, the device is intended to be used by audiologists or other professionals skilled in audiology.

Description of the training set, sample size, data source, and annotation protocol

The newborn ABR template used as in integral part of the OtoNova and Otoport devices was derived from a database 1000 infant's ABR screening response waveforms independently collected using the Otodynamics ILO88 instrument (K962995) as part of the a multicenter investigation into the Identification of Neonatal Hearing Impairment as reported in " Identification of Neonatal Hearing lmpairment: Summary and Recommendations Norton, Susan J.; Gorga, Michael P.; Widen, Judith E.; Folsom, Richard C.; Sininger, Yvonne; Cone-Wesson, Barbara; Vohr, Betty R.; Fletcher, Kristin A. Ear and Hearing 21(5):p 529-535, October 2000.

Description of the test set, sample size, data source, and annotation protocol

The complete ABR infant screening algorithm of the Otoport OAE+ABR device - now duplicated in the OtoNova- was validated on 70 infants performed at Otodynamics Ltd and was then independently trialled in collaborating hospitals in USA, Brazil, Israel and UK . The algorithm was validated from 1078 tests files and results provided by these trials. Separately and independently the performance of the Otoport OAE+ABR screening function was evaluated on 56 neonates at a UK hospital by direct comparison with a Natus ABR screening product.

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Summary of Non-Clinical testing
The OtoNova and OtoNova Pro use the same DSP firmware algorithms and amplifier circuitry as the predicate Otoport device and are designed to provide the same stimulations and register the same responses in the same conditions. This functional equivalence was verified by bench tests that compared the stimuli delivered and the response recorded by the 3 devices.

  • For each device the electrical driving signals delivered by the stimulator 'probe' transducers during testing were measured on subject and predicate devices using calibrated equipment for each testing mode (i.e. TEOAE DPOAE and ABR) and compared. They were found to be substantially the same (to within 1dB) across the functional frequency range.
  • The acoustic stimulation delivered by the probe into a standard calibrated acoustic ear simulator was recorded for subject and predicate devices for each test mode (TEOAE, DPOAE, ABR) and also for ABR test stimulation in the 'earcup' stimulus delivery device. They were found to be substantially the same (to within 1dB) across the functional frequency range.
  • The sensitivity of each device to simulated DPOAE, TEOAE and ABR responses was recorded by fitting the probe and electrodes to Otodynamics' factory-reference 'response simulator'. Each device received the same simulated response signals. The responses recorded by the OtoNova Pro were substantially the same levels (within 1dB) across the functional frequency for OAEs, and the ABR recorded had substantially the same size and waveform for ABR (within 1dB).

Summary of Clinical testing
The operational equivalence of OtoNova Pro and predicate Otoport OAE+ABR devices was verified from data collected from 20 volunteer adult subjects with informed consent , under identical test conditions. The purpose of the trial to the compare physiological response measurement capacity and algorithms of the OtoNova and Otoport devices. Each subject was tested on each device with DPOAE, TEOAE or AABR, in the same session, with the same probe fitting (and electrode fitting for AABR), under the same test conditions. For each test mode data was recorded from a minimum 15 subjects from each device in the same session.

  • OtoNova's Nova-Link gives same screening test result under the same screening criteria (i.e. clear response, no clear response, invalid result) as the predicate device. The physical characteristics of the recorded responses were similar on each device. In the case of marginal response levels, where variability is to be expected, the range of marginality was no wider than for the Otoport OAE+ABR.
  • In the recording of OAE response for clinical purposes the OtoNova and OtoNova Pro the reported response levels were the same across frequency as with the Otoport OAE +ABR device within the tolerance expected due to subject movement.
  • The reported noise levels reported by Novalink were similar to those reported by the Otoport C. within the expected intrinsic variability of noise.

Human Factors/ Usability Engineering Testing
A summative usability validation study was conducted with 16 participants external to Otodynamics. The study participants were asked to operate the device, run tests and provide user summative evaluation of the OtoNova medical device.
All the 16 users were able to sufficiently understand the OtoNova product/ IFU, to successfully record tests and use the medical device per its intended use, using only the instructions provided, the OtoNova product and items and the OtoNova User Manual. There were no substantial issues found during this OtoNova summative evaluation. The issues found were not substantial, and improvements were implemented.

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

Not Found

Predicate Device(s)

K143395

Reference Device(s)

K962995

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 874.1050 Audiometer.

(a)
Identification. An audiometer or automated audiometer is an electroacoustic device that produces controlled levels of test tones and signals intended for use in conducting diagnostic hearing evaluations and assisting in the diagnosis of possible otologic disorders.(b)
Classification. Class II. Except for the otoacoustic emission device, the device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter, if it is in compliance with American National Standard Institute S3.6-1996, “Specification for Audiometers,” and subject to the limitations in § 874.9.

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Image /page/0/Picture/0 description: The image contains 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 includes the letters "FDA" in a blue square, followed by the words "U.S. Food & Drug Administration" in blue text.

June 21, 2024

Otodynamics % Chandler Thames Quality/Regulatory Consultant Rook Quality Systems 1155 Mount Vernon Hwy Suite 800 Dunwoody, Georgia 30338

Re: K234095

Trade/Device Name: OtoNova/OtoNova Pro Regulation Number: 21 CFR 874.1050 Regulation Name: Audiometer Regulatory Class: Class II Product Code: EWO, GWJ Dated: Mav 21, 2024 Received: May 21, 2024

Dear Chandler Thames:

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 (the 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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database available at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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.

Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device"

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(https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).

Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30. Design controls; 21 CFR 820.90. Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review. the OS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).

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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely.

Shuchen Peng -S

Shu-Chen Peng, Ph.D. Assistant Director DHT1B: Division of Dental and ENT Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

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Indications for Use

510(k) Number (if known) K234095

Device Name OtoNova/OtoNova Pro

Indications for Use (Describe)

This Otonova Pro device is indicated for use when there is a requirement to screen for hearing disorders by objective and non-invasive means. ABR, TEOAE and DPOAE screening test results are automatically interpreted and a clear "Pass' or 'Refer' result is presented to the user. Use of the device is indicated when the patient is unable to give reliable voluntary responses to sound, especially with infants.

Use of the device facilitates the early detection of hearing loss and its characterization. Where the individual to be screened is healthy with no medical conditions related to the ear, as in the case of well-baby hearing screening, the user can be a trained screener. In all other cases the user should be an audiologist or medical professional.

The TEOAE and DPOAE analytical functions of the device are indicated when objective non-invasive clinical investigations require the characterization and monitoring of the peripheral auditory function. For this purpose, the device is intended to be used by audiologists or other professionals skilled in audiology.

These TEOAE and DPOAE tests are applicable to populations of any age to obtain objective evidence of peripheral auditory function.

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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SUBMITTER

Otodynamics Ltd 30-38 Beaconsfield Rd Hatfield, Hertfordshire AL10 8BB, United Kingdom

Phone: +44 1707 267540 Email: daniel.budd@otodynamics.com

Contact Person: Daniel Budd, QA Manager Date Prepared: 9 April.2024

DEVICE

Trade Name:OtoNova/OtoNova Pro
Common Name:OtoNova/OtoNova Pro
Classification Name:Audiometer / Evoked response auditory stimulator
(874.1050 & 882.1900)
Regulatory Class:II
Product Codes:EWO & GWJ

PREDICATE DEVICE

The legally marketed device to which equivalence is being claimed [807.92(a)(3)] is the Otoport/ Otocheck OAE+ABR ™, K143395.

This predicate has not been the subject of any design-related recalls.

DEVICE DESCRIPTION

OtoNova is a compact, portable battery-powered electronic device which records physiological responses to sound for the purpose of hearing testing. It Is controlled wirelessly from a local controlling device.

OtoNova has two hardware variants: OtoNova and OtoNova Pro, illustrated below in Figure 1.

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FIGURE 1

Image /page/4/Picture/1 description: The image shows two different versions of the OtoNova device. The OtoNova on the left has 3 single AABR electrode connectors and a single probe connector. The OtoNova Pro on the right has 1 combined AABR electrode connector and 2 probe connectors. Both devices have indicators for L/R ear, sensors, test and device status.

  • . OtoNova (left) has 3 separate connectors for 3 ABR electrode connections and accepts one probe. The OtoNova Pro (right) has a combined electrode connector and accepts 2 probes (red and blue sockets).
  • . The OtoNova and OtoNova Pro perform the same audiological tests. The devices are controlled wirelessly from a separate controlling device. This can be a PC, a laptop or Android tablet running the supplied 'Nova-Link' software.

Figure 2 illustrates the configuration of OtoNova Pro in use. The test operator commands the OtoNova Pro from the supplied Nova-Link application running on the controlling device. OtoNova operates in the same way.

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Figure 2. Operation of the OtoNova with Nova-Link

Image /page/5/Figure/1 description: The image shows the OtoNova Pro testing device and its various applications. The device can be used with an OAE probe or electrodes for infants. It can wirelessly transfer processed test data between the device and a controller via Bluetooth. The controlling device can print or export reports to a PC, and an operator can conduct tests via the controlling device running Nova-Link software.

Both the OtoNova and OtoNova Pro devices have been directly engineered from Otodynamics' currently marketed Otoport OAE+ABR device, retaining all the testing algorithms of the Otoport OAE+ABR device. The primary aim of the development was to physically separate the control console from the testing device while maintaining the same performance and effectiveness.

Separation of testing and controlling devices provides several advantages to the user. It gives greater freedom for the relative positioning of patient and tester within the test environment. This may be advantageous when testing infants, children, or when testing a patient from outside of a test booth. It also provides choice of controlling processor and display. For example, a tablet allows the operator to observe tests and records on a full size display screen, rather than on a diminutive handheld device screen. It also allows access other services on the controlling device.

Principles of operation

Like the predicate Otoport OAE+ABR device, both OtoNova devices can record two different physiological indicators of a functioning auditory system's peripheral response to sound namely a) Otoacoustic emission (OAEs), which are small sounds made by the inner ear in response to acoustic stimulation, and b) Auditory brainstem responses (ABRs) are tiny electrical signals emanating from the auditory brainstem in response to sound. Automatic recognition of an ABR response is referred to as AABR.

6

During ABR or OAE testing, low-level sounds are delivered to the ear. The responses to multiple presentations of these sounds (either acoustic or electrical responses) are recorded digitally and added together to enhance repeated responses with respect to the random/ noise signals that are always present. The averaged signal is automatically analysed by the device to identify and quantify true physiological response component and to assess the degree of noise contamination. This allows the quality/ accuracy of the recording to be determined for evidence of response validity. The processed data is reported to and displayed on the controlling device.

Impaired/ defective ears do not produce a response which meets the pass criteria of the pass criteria of the OtoNova are the same as those of the predicate Otoport device. In SCREENING applications all failures to record a clear response which are not attributable to technical issues (e.g., an excess of noise or insufficient test duration) are recommended to be referred for further audiological investigations to determine if there is a hearing problem. Both serious and trivial ear problems (e.g., a blocked ear canal) can prevent the criteria being met and so cause a test failure. Technically inadequate recordings are recommended to be repeated after addressing the technical issues.

In CLINICAL OAE applications the strength of the OAE response is measured at differing stimulus frequencies and stimulus levels. The analysis is intended to be used as one input to a diagnostic process in conjunction with other audiometric tests, or as a means of monitoring cochlea status over time.

Both OAE and ABR responses are acoustically stimulated. The stimulus is delivered to the ear by an inserted earphone device called a 'probe'. The probe contains a microphone which also records the OAE response, and the acoustic stimulus given.

Figure 3 shows compatible Otodynamics probes intended for stimulation and recording of DPOAE, TEOAEs, and for both TEOAEs and DPOAE. These are the UPD, UPS and XPD probes respectively.

Image /page/6/Figure/5 description: The image shows three different types of otodynamics probes labeled UPD, UPS, and XPD. Each probe has a different design and color scheme. The UPD probe is white with a gray tip, the UPS probe is brown and white, and the XPD probe is white with a blue tip. The probes are labeled as Figure 3 and are likely part of a study or presentation on otodynamics.

The ABR response can be acoustically stimulated by any one of these probes but it is recorded electrically via 3 disposable self-adhesive conducting pads called 'electrodes', which are placed on the scalp (Fig 4).

Image /page/6/Picture/7 description: The image shows a small, white, oval-shaped object with a circular base. The object appears to be made of a translucent material, possibly plastic, with a white border. At the center of the circular base, there is a small, silver-colored button or contact point. The object is casting a shadow on a white background.

Figure 4 Otodynamics Electrodes (AABR testing)

For ABR stimulation the probe may be inserted into the ear canal (as for OAEs) or into a plastic cushioned

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'ear cup' which is placed over the ear. ABRs recording with OtoNova are intended for infant screening only.

Both OtoNova and OtoNovaPro variants offer the same two modes of hearing function assessment, that is OAE and AABR, separately or in combination, with optional levels of utilities.

The hearing test functions available on a device are identified by 6 OtoNova model names as follows:

  • OtoNova OAE,
  • OtoNova AABR,
  • OtoNova OAE+AABR
  • OtoNova Pro OAE,
  • OtoNova Pro AABR,
  • OtoNova Pro OAE+ABR

The level of utilities available is further determined by the Nova-Link program and the installed application package. There are three variants of Nova-Link application levels:

SCREENER, CLINICAL and ADVANCED CLINICAL.

These are available on both standard OtoNova and OtoNova Pro.

SCREENER LEVEL functionality provides Basic OAE and or AABR screening with preset automated pass/refer test protocols.

CLINICAL LEVEL provides all of the SCREENING LEVEL functionality plus detailed OAE analysis over a selectable frequency range at configurable stimulus levels. If AABR is enabled, examination of the ABR screening waveform and test conditions are available. No ABR diagnostic information is provided.

ADVANCED CLINICAL LEVEL functionality provides the same screening and clinical tests with enhanced user protocol definitions.

INDICATIONS FOR USE

The OtoNova device is indicated for use when there is a requirement to screen for hearing disorders by objective and non-invasive means. ABR, TEOAE and DPOAE screening test results are automatically interpreted and a clear 'Pass' or 'Refer' result is presented to the user. Use of the device is indicated when the patient is unable to give reliable voluntary responses to sound, especially with infants. Use of the device for screening facilitates the early detection of hearing loss and its characterization.

Where the individual to be screened is healthy with no medical conditions related to the case of well-baby hearing screening, the user can be a trained screener. In all other cases the user should be an audiologist or medical professional.

The TEOAE and DPOAE analytical functions of the device are indicated when objective non-invasive clinical investigations require the characterization and monitoring of the functional status of the peripheral auditory function. For this purpose, the device is intended to be used by audiologists or other professionals skilled in audiology. These TEOAE and DPOAE tests are applicable to populations of any age to obtain objective evidence of peripheral auditory function.

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COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE

The same Otoacoustic Emissions (OAEs) & Auditory Brainstem Response (ABR) techniques, algorithms and principles of response analysis are utilized in both the subject and predicate devices.

The OtoNova reproduces the Otoport/Otocheck OAE+ABR predicate device with regard to its acoustic stimulation, response gathering, analysis, display, and report generation database capabilities. The OtoNova has the same intended uses and fulfills the same roles as the predicate device.

Basis of the screening functions of the OtoNova and OtoONova Pro

The OAE and ABR screening functions of the OtoNova and OtoNova Pro are identical to the Otoport OAE+ABR predicate device (K143395).

The OAE infant screening function of OtoNova (subject) and Otoport (predicate), via its stimulus levels and pass criteria is as developed and verified in the Rhode Island Hearing Screening Assessment Project and reported in "The Rhode Island Hearing Assessment Project:Implications for universal newborn hearing screening. Seminars in Hearing 1993, Volume 14 Number 1. ". That algorithm now in use on the OtoNova requires a response to a nonlinear transient stimulus at 84dBSPL peak equivalent level, of 6dB or more greater than the measured noise level ( ie signal to noise level) in at least two half octave frequency bands between 1 and 4kHz.

The ABR infant screening function of the OtoNova presents a short chirp stimuli at 35dBHL or 40dBHL, and an requires a response waveform with a standard Fsp statistic of at least 3.1 (elevated according to noise levels) in addition to a waveform match to a newborn ABR template.

The stimulus level of the short chirp provided by the Otonova is automatically adjusted to the recommended dBHL sound level according to our measurements of hearing threshold of this stimulus in 25 healthy young adults with no hearing problems, using the Otoport and Otodynamics probe.

The newborn ABR template used as in integral part of the OtoNova and Otoport devices was derived from a database 1000 infant's ABR screening response waveforms independently collected using the Otodynamics ILO88 instrument (K962995) as part of the a multicenter investigation into the Identification of Neonatal Hearing Impairment as reported in " Identification of Neonatal Hearing lmpairment: Summary and Recommendations Norton, Susan J.; Gorga, Michael P.; Widen, Judith E.; Folsom, Richard C.; Sininger, Yvonne; Cone-Wesson, Barbara; Vohr, Betty R.; Fletcher, Kristin A. Ear and Hearing 21(5):p 529-535, October 2000.

The complete ABR infant screening algorithm of the Otoport OAE+ABR device - now duplicated in the OtoNova- was validated on 70 infants performed at Otodynamics Ltd and was then independently trialled in collaborating hospitals in USA, Brazil, Israel and UK . The algorithm was validated from 1078 tests files and results provided by these trials. Separately and independently the performance of the Otoport OAE+ABR screening function was evaluated on 56 neonates at a UK hospital by direct comparison with a Natus ABR screening product.

9

Table 1 Equivalence Table.

Subject DevicePredicate DeviceDiscussion
OtoNova/OtoNova ProOtoport/Otocheck OAE+ABR (K143395)
Common NameAudiometer Evoked response auditory stimulator.Audiometer Evoked response auditory stimulatorsame
Regulaton
NumbersAudiometer 21 CFR 874.1050, Evoked response auditory stimulator 21 CFR
882.1900Audiometer 21 CFR 874.1050, Evoked response auditory stimulator 21 CFR
882.1900same
Classification
Product CodesIIIIsame
Product CodesEWO & GWJEWO & GWJsame
Intended UseFor use in the detection hearing disorders in infants with AABR or OAEs,
B8and to provide objective input from OAEs for use as part of a diagnostic
audiological test battery with infants children and adults.For use in the detection hearing disorders in infants with AABR or OAEs, and
to provide objective input from OAEs for use as part of a diagnostic
audiological test battery with infants children and adults.same
Indications for
UseThis Otonova Pro device is indicated for use when there is a requirement
to screen for hearing disorders by objective and non-invasive means. ABR,
TEOAE and DPOAE screening test results are automatically interpreted
and a clear 'Pass' or 'Refer' result is presented to the user.
Use of the device is indicated when the patient is unable to give reliable
voluntary responses to sound, especially with infants.
Use of the device facilitates the early detection of hearing loss and its
characterization.
Where the individual to be screened is healthy with no medical conditions
related to the ear, as in the case of well-baby hearing screening, the
user can be a trained screener. In all other cases the user should be an
audiologist or medical professional.
The TEOAE and DPOAE analytical functions of the device are
indicated when objective non-invasive clinical investigations require the
characterization and monitoring of the functional status of the peripheral
auditory function. For this purpose, the device is intended to be used by
audiologists or other professionals skilled in audiology. These TEOAE and
DPOAE tests are applicable to populations of any age to obtain objective
evidence of peripheral auditory function.The Otoport/Otocheck OAE+ABR device is indicated for use when there is a
requirement to screen for hearing disorders by objective and non-invasive
means. Test results are automatically interpreted and a clear 'Pass' or
'Refer' result is presented to the user.
Use of the device is indicated when the patient is unable to give reliable
voluntary responses to sound, especially with infants.
Use of the device facilitates the early detection of hearing loss and its
characterization.
Where the individual to be screened is healthy with no medical conditions
related to the ear, as in the case of well-baby hearing screening, the user can
be a trained. In all other cases the user should be an audiologist or medical
professional.
The device is also indicated when objective non-invasive clinical
investigations require the characterization and monitoring of the functional
status of the peripheral auditory function using otoacoustic emissions
(OAEs). It may also be used in populations of any age to obtain objective
evidence of normal peripheral auditory function.Similar. The OtoNova and OtoNova Pro manuals
explicitly name the OAE's used.
Overall Device
DesignPortable device (120mm x 79mm x 26mm; 170g)
Stimulates the ear with quiet sounds.
Non-invasive, records physiological responses to these sounds.
Automatically evaluates the evidence for a response
Transmitsprocessed results by bluetooth wireless connection to the
controlling device (tablet). Controlling device displays a concise results
about the presence or absence of responses
Saves a detailed record of the test on the controlling device
As a screener the device alerts to the possibility of hearing loss and in
clinical use documents the status of the ear by OAEsHandheld device (197mm x 70mm x 30mm; 250g)
Stimulates the ear with quiet sounds.
Non-invasive, records physiological responses to these sounds.
Automatically evaluates the evidence for a response
Displays a concise results about the presence or absence responses on
its integral display.
Saves a detailed record of the test
Device alerts to the possibility of hearing loss and documents the status
of the earSimilar. The only significant differences between
device designs is that in the OtoNova there is a
separation of testing device from controlling
device via a bluetooth wireless link. The subject
device is of lighter weight and smaller body. It is
to be marketed as portable for use a controlling
device which runs the supplied Nova-Link
software. The predicate is a self contained
handheld device with its own diplay screen and
keypad, making it heavier and larger.
User ControlsVia touch screen or keyboard of the controlling device running the supplied
Nova-Link software which wirelessly commands the OtoNova test deviceVia soft keypad on the handheld deviceEquivalent.The OtoNova's 'Nova-Link' software
provides the same control functions via touch
screen or keyboard of the controlling device, as
does the Otoport OAE+ABR device via its
keypad.D13
Test
SpecificationsABR Stimulus for infant screening Chirp 30-45dBnHL . 35 & 40dBnHL, recom-
mended. 60dBnHL available as a training aid only , not for screening
DPOAEs.Frequency ratio F2/F1 1.22. F2 frequency range 1-8kHz ,
Stimulus levels for screening L1/L2 preset 65/55, 60/55 or 65/50dBSPL
Stimulus levels ofr clinical use L1 & L2 configurable 40-75dBSPL
TEOAE Half octave analysis. Frequency range 1-6kHz
Stimulus levels for screening 84dBSPLpe
Stimulus levels for clinical use configurable 74- 84dBSPLpe,
Advanced clinical 60-90dBSPLpeABR Stimulus for infant screening Chirp 30-45dBnHL, 35&40dB recom-
mended. 60dBnHL available as a training aid only,not for screening
DPOAEs.Frequency ratio F2/F1 1.22. F2 frequency range 1-8kHz ,
Stimulus levels for DP screening L1/L2 65/55dBSPL (confgurable)
Stimulus levels ofr clinical use L1 & L2 configurable 40-75dBSPL
TEOAE Half octave analysis. Frequency range 1-6kHz
Stimulus levels for screening 84dBSPLpe recommended, configurable 60-
84dBSPLpe
Stimulus levels for clinical use configurable 60-84dBSPLpeSimilar. The OtoNova stimulus frequency range
are the same as the predicate device. Both
predicate and subject devices cover the most
commonly used and validate stimlus levels . The
OtoNova screening settings do not provide
stimulus levels no longer judged appropriate for
screening, but these are available on the clinical
mode.
Automatic
screening
decisionsIn screening mode OtoNova automatically provides an on screen 'Pass, Refer
or invalid test result', plus indications of the reason for test invalidity.In screening mode Otoport OAE+ABR automatically provides an on
screen 'Pass, Refer or invalid test' result, plus indications of the reason
for test invalidity.Same
Stimulus
calibrationwith inserted probe - In-the-ear self calibration
For AABR with ear-cup, stimulus is preset to dial level.with inserted probe - In-the-ear self calibration
For AABR with ear-cup, stimulus is preset to dial level.Same
Device
Components /
FeaturesStimulates the ear with either transient or tonal sounds via an inserted
earpieceStimulates the ear with either transient or tonal sounds via an inserted
earpieceSame
Registers interfering acoustic noise and advises users when this is too large
for testing to take place.Registers interfering acoustic noise and advises users when this is too large
for testing to take place.
Implements otoacoustic emission technology to record TEOAE and DPOAEs
responses to sound applied via an inserted earpiece (probe)Implements otoacoustic emission technology to record TEOAE and DPOAEs
responses to sound applied via an inserted earpiece (probe)
Provides an intensity and frequency analysis of the OAE response,
numerically and graphicallyProvides an intensity and frequency analysis of the OAE response,
numerically and graphically
Automatically determines and displays the presence or absence of a normal
TEOAE or DPOAE responseAutomatically determines and displays the presence or absence of a normal
TEOAE or DPOAE response
Implements auditory brainstem response (ABR) technology to record electro
physiological responses via surface electrodesImplements auditory brainstem response (ABR) technology to record electro
physiological responses via surface electrodes
Stimulates the ear for ABR screening at 30,35,40,or 45dBnHLStimulates the ear for ABR screening at 30,35,40,or 45dBnHL
Registers interfering electrical noise and advises users when this is too large
for testing to take place.Registers interfering electrical noise and advises users when this is too large
for testing to take place.
Registers the electrical impedance of electrode connections to the patient
and advises users when this is too large for testing to take placeRegisters the electrical impedance of electrode connections to the patient
and advises users when this is too large for testing to take place
Performs statistical analysis on the ABR response to decide if it is present
and normalPerforms statistical analysis on the ABR response to decide if it is present
and normal
Automatically determines and displays the presence or absence of a normal
ABR responseAutomatically determines and displays the presence or absence of a normal
ABR response
Serves as a hearing based on the presence or absence of a normal OAE or
ABR responseServes as a hearing based on the presence or absence of a normal OAE or
ABR response
PopulationOAEs Infant, child and adult, AABR, infantOAEs Infant and adult, AABR, infantSame
Intended userTrained screener and professionalsTrained screener and professionalsSame
Safety
characteristicsElectrically isolated. Acoustic stimulation levels physically constrained and
monitored with active protection against single faults.Electrically isolated. Acoustic stimulation levels physically constrained and
monitored with active protection against single faults.Same
Probe: plastic encapsulated insert earphone containing microphone and
receiver, fitted with disposable single use plastic tip both as used with the
predicate.Probe: plastic encapsulated insert earphone containing microphone and
receiver, fitted with disposable single use plastic tipSame
Surface, disposable self-adhesive skin electrodesSurface, disposable self-adhesive skin electrodesSame
Materials of
ConstructionElectronic circuitry providing stimulation drive to the probe, amplification
for the signals, received from the probe microphone and electrodes, signal
processing for response enhancement and noise rejection and
microprocessor for signal and statistical analysis, rechargeable battery,
m=power managment, LEDs to indicate states, bluetooth communication
modules for reception of commands form the conrolling computer and the
transmission of processed test data to the conrolling devce all encapsulate
in a plastic housing,Electronic circuitry providing stimulation drive to the probe, amplification
for the signals, received from the probe microphone and electrodes, signal
processing for response enhancement and noise rejection and
microprocessor for signal and statistical analysis, rechargeable battery,
power managment, graphic display unit and data input keypad, and
bluetooth module for tramission of test data to third party computer all
encapsulated in a plasticSimilar. All devices have similar circuits and
firmware providing the testing functions. The
differences are that in the subject device
bluetooth communication is two way and is
updated during testing, whereas it is one way in
the predicate device and it post test.
Also the subject device hardware does not
include a data input keypad or a graphic display
as this is provided by the controlling device.D37
SterileNoNosame
Duration of
placementLess than 5 minutes per earLess than 5 minutes per earsame
Usage of
Patient contact
itemsAcoustic probe tip and electrodes are single patient use only as used on the
predicate deviceAcoustic probe tip and electrodes are single patient use onlysame
Electrode,
number and
Anatomical
placementScalp, forehead, nape, shoulderScalp, forehead, nape, shouldersame
Number of
Electrodes33same
Electrode
Socket
ConnectorOtoNova: Three Single Pin electrode Socket Connectors, compatible with DIN
42-802 Type ST 'Touchproof' terminated electrode cables
OtoNova Pro: One 4 Pin Plug & Sock+B34et Connector and is compatiblel
with the supplied combined electrode cable.Otoport OAE+ABR has three Single Pin electrode Socket Connectors,
compatible with DIN 42-802 Type ST 'Touchproof' terminated electrode
cablesSimilar. The OtoNova and the predicate device
are similar in their use of three single electrode
pin plugs and socket connectors.The exact same
electrode cables and electrodes are used in
OtoNova and predicate Otoport ABR.
The OtoNova Pro uses a 4 pin plug and socket
connector- combining 3 electrode connections
and an electrical interference screen.
The 4 pin single electrode cable socket of the
OtoNova Pro provides a simpler method of
connection for the user and incorrect
connections are eliminated.
In the OtoNova basic version incorrect electrode
wires montage is mitigated by clear color coding
of the electrode cables and sockets. This
change in connector on OtoNova Pro affords less
parts/ with easier use while the functionality
remains the same and the residual user risks
remain low/ are acceptable.D42
BatteryLithium-ion BatteryLithium-ion BatterySame
Battery voltage
operating
range:3.2-4.2V3.2-4.2VSame
SourceSource: 1000mAh lithium polymer internal rechargeable cellsSource: 1000mAh lithium polymer internal rechargeable cellsSame
Electrode CableOtoNova: compatible with DIN 42-802 Type ST 'Touchproof' terminated
electrode cables - with snap electrode connectors.
OtoNova Pro: Supplied 3 electrode combination cable with snap connectorscompatible with DIN 42-802 Type ST 'Touchproof' terminated electrode
cables with snap elelctroc connectorsOtoNova:Same
OtoNova Pro:similar, with the added simplicity of
a single connection for the 3 electrodes
Probe
Connector(14 pin) 'Medi-Snap' connector push pull connector(8 pin) 'Triad' connector metal collar to screw lock in placeSimilar. The probe connector for the subject
device is a 14 pin "Medi-Snap" connector while
the predicate device uses an 8 pin "Triad"
connector. The addition 8 pins of the Medi-Snap
connector are note currently used.
The OtoNova / OtoNova Pro UPD and UPS
probes are equivalent with legacy probes of
predicate Otoport OAE+ABR which have been in
service for 20+years. The only difference is the
connectors.
The Medi-Snap probe connector of the OtoNova
serves the same purpose is the Triad connector
of the preducate but its insertion and removal
are mechanically different. Instead of a screwed
collar locking method, the Medi -Snap features a
Push-in- Pull-out mechanism with adequate
retention when in. This provides an easier user
experience and reduces risk of connector pin
damage by mishandling. Connector damage
ProbesOtoNova and OtoNova Pro accept UPS, UPD probes
OtoNova Pro is additionally compatible with Otodynamics XPD probes and
can accept two probes.
All compatable probes include a chip containing calibration data.Otoport OAE+ABR accepts UGS, UGD, and XGD probes
All compatable probes include a chip containing calibration data.Similar. The OtoNova Pro is compatible with all
Otodynamics probes which the predicate
Otoport devices are compatible if fitted with a
Medi-Snap connector or via a connector adaptor
OtoNova (not pro) does not recognise the XPD
probe because it has a differently structured
calibration chip
OtoNova and OtoNova Pro probes have a
different 'push pull' connector than predicate
Otoport probes but are acoustically and
mechanically identically. This connector
difference is indicated by the 'P' in their name eg
Number of
Probes
ConnectedOtoNova - 1 probe
OtoNova Pro 2 probesThe Otoport OAE+ABR can operate with one probe or two probes with the
binaural optionThe subject and predicate base models (OtoNova
and Otoport) are similar while the OtoNova Pro
and Otoport OAE+ABR can similarly accept two
probes
Device
Components /
FeaturesA handheld battery powered hearing screening device which is wirelessly
controlled (Bluetooth) by an Android or Windows PC device to display and
communicate processed real time data.A handheld battery powered hearing screening device with integral keypad
and display which shows processed real time dataSimilar. The OtoNova controlling processor
provides all the functionality of the Otoport
interface, but on a larger screen with the
convenience of touch screen function.
The wireless connection between the OtoNova
controller device running Nova-Link software
and the OtoNova test hardware gives greater
freedom to the operator, better positioning
themselves relative to the patient. The residual
users risks are found to be low/ are acceptable.
User InterfaceThe OtoNova's 'Novalink' software runs on the selected controlling device
and provides complete user control over the OtoNova testing hardware.
Nova-Link displays test progress, test results, and saves tests in the in-built
database.
Optionally, Novalink database contents can be securely transferred to
Otodynamics Otolink software for review, printing or archiving. Novalink is
installed from Google play for Android devices or from Microsoft Store for
PC devices"The Otoport preinstalled software provide complete user control over the
testing hardware inside the Otoport and displays test progress, test results,
and tests saved in the in-built database.
Optionally, Otoport database contents can be securely transferred to
Otodynamics Otolink software for review, printing or archiving.
Otoport firmware can be securely updated from Otolink"Similar. There are no significant functional
differences for the user between the OtoNova
control program Nova-Link and Otoport built in
control software.
Differences are cosmetic, and ergonomic -
resulting form the larger display screen, touch
screen controll and large storage capacity
because of access to the controlling device
processor and memory
Data TransferOtoNova and OtoNova Pro test devices transfer processed test data to the
third party controlling computer device wirelessly via bluetooth (4.2) as the
test progresses. The controlling devide also commands the test device via
bluetooth.Otoport OAE+ABR can transfer completed and saved test records to a third
party computer either wirelessly via bluetooth (2.0), or via a wired USB1.1
or 2.0 connectionSimilar. The subject and predicate both use
Bluetooth to tranfer processed test data
between test and computer devices. Whereas the
predication only transfered completed and files
test records, the subject device uses bluetooth to
command the testing device as well as to recieve
processed test results from the test device as
testing progresses. Bluetooth 4.2 is more robust
than bluetooth 2. The OtoNova devices do not
have a USB port. The controling device will have
USB which can be used to securely transfer filed
test records to a PC.
Chargingcompatible with wireless chargers (transmitters) meeting WPC Qi standard
v1.1 or v1.2Charging is via a charging/data connector on the device - which connects to
Otodynamics PSU (charging) or to PC USB port (USB 1.1or 2.0) via a Data
Cable.Equivalent. The wireless charging of the OtoNova
is advantageous because it requires no electrical
connection of the device. This enhances its
cleanability.
Power StatesIntelligent multi-level power control for
charging/testing/idle/sleepIntelligent multi-level power control for
charging/testing/idle/sleep/shutdownSimilar. The power states of OtoNova are
identical to the Otoport except for the renaming
of 'shutdown' (predicate) as Flight Mode
(subject).
When the subject sleeps detects physical
movement and then actively searches for its host
controller by bluetooth advertising information.
For air transported this function must be
disabled. The shutsdown state is named
'FlightMode' to make this clear. It is not
necessary for the OtoNova to be toally powered
down at any other time as the sleep mode can
sustain operational battery charge for more than
one month.
Charge Time3.5 Hrs to 100%4 Hrs to 100%Similar. The subject device has a slightly shorter
battery charging time at 3.5 hours versus the
predicate device's 4 hours. This is advantageous
for the user. The battery usage time of OtoNova
is many times that of the predicate device
because it does nothave to power a display
screen.
Max
consumption
when testing:0.5W1WSimilar. The subject device uses less power than
the predicate Otoport (0.5W vs 1W) because it is
not powering an LCD display, which the
predicate Otoport has.
Max
consumption
when charging:2.5W2.5WSame

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15

Summary of Non-Clinical testing

The OtoNova and OtoNova Pro use the same DSP firmware algorithms and amplifier circuitry as the predicate Otoport device and are designed to provide the same stimulations and register the same responses in the same conditions. This functional equivalence was verified by bench tests that compared the stimuli delivered and the response recorded by the 3 devices. OtoNova and OtoNova Pro are operated from a tablet controlling device running Nova-Link software. The Otoport is a self -contained test device with its own firmware.

For each device the electrical driving signals delivered by the stimulator 'probe' transducers during testing were measured on subject and predicate devices using calibrated equipment for each testing mode (i.e. TEOAE DPOAE and ABR) and compared. They were found to be substantially the same (to within 1dB) across the functional frequency range.

The acoustic stimulation delivered by the probe into a standard calibrated acoustic ear simulator was recorded for subject and predicate devices for each test mode (TEOAE, DPOAE, ABR) and also for ABR test stimulation in the 'earcup' stimulus delivery device. They were found to be substantially the same (to within 1dB) across the functional frequency range.

The sensitivity of each device to simulated DPOAE, TEOAE and ABR responses was recorded by fitting the probe and electrodes to Otodynamics' factory-reference 'response simulator'. Each device received the same simulated response signals. The responses recorded by the OtoNova Pro were substantially the same levels (within 1dB) across the functional frequency for OAEs, and the ABR recorded had substantially the same size and waveform for ABR (within 1dB).

Summary of Clinical testing

The operational equivalence of OtoNova Pro and predicate Otoport OAE+ABR devices was verified from data collected from 20 volunteer adult subjects with informed consent , under identical test conditions. The purpose of the trial to the compare physiological response measurement capacity and algorithms of the OtoNova and Otoport devices. Each subject was tested on each device with DPOAE, TEOAE or AABR, in the same session, with the same probe fitting (and electrode fitting for AABR), under the same test conditions. For each test mode data was recorded from a minimum 15 subjects from each device in the same session.

  • a. OtoNova's Nova-Link gives same screening test result under the same screening criteria (i.e. clear response, no clear response, invalid result) as the predicate device. The physical characteristics of the recorded responses were similar on each device. In the case of marginal response levels, where variability is to be expected, the range of marginality was no wider than for the Otoport OAE+ABR.
  • b. In the recording of OAE response for clinical purposes the OtoNova and OtoNova Pro the reported response levels were the same across frequency as with the Otoport OAE +ABR device within the tolerance expected due to subject movement.
  • The reported noise levels reported by Novalink were similar to those reported by the Otoport C. within the expected intrinsic variability of noise.

Based on the close agreement of the clinical test results obtained, and the equivalence of all the physical measurement characteristics of the devices as demonstrated in bench tests, on which the intended infant screening use solely depends, it is concluded that OtoNova Pro devices have the same efficacy

16

as the predicate device across all applications, including for infant screening.

Human Factors/ Usability Engineering Testing

The Human Factor (HF) engineering process applied to the OtoNova devices has been in accordance with ANSI/AAMI HE75:2009 Human factors Engineering – Design of medical devices and FDA Guidance Applying Human Factors and Usability Engineering to Medical Devices, Guidance for Industry and Food and Drug Administration Staff, issued February 3, 2016 and IEC 62366-1 Edition 1.0 2015-02.

A summative usability validation study was conducted with 16 participants external to Otodynamics. The study participants were asked to operate the device, run tests and provide user summative evaluation of the OtoNova medical device. The OtoNova simulated users, used only the OtoNova Quick Start guide- an essential OtoNova testing abbreviated IFU, the OtoNova IFU in case they needed further information, and the OtoNova device/ system items.

All the 16 users were able to sufficiently understand the OtoNova product/ IFU, to successfully record tests and use the medical device per its intended use, using only the instructions provided, the OtoNova product and items and the OtoNova User Manual. There were no substantial issues found during this OtoNova summative evaluation. The issues found were not substantial, and improvements were implemented.

User Manual

Improvements and changes to the OtoNova/Otonova Pro IFUs were made throughout the device's development and IFU change histories based on human factors testing data. Subsequently no substantial issues were found during further OtoNova Pro IFU summative evaluations or clinical applications.

Summative use evaluation for the user, patient and the environment concluded that the remaining residual risks are acceptable and that OtoNova as safe and effective as the predicate Otoport OAE+ABR device.

Biocompatibility Testing

The biocompatibility evaluation for the OtoNova Device was conducted in accordance with the FDA Guidance Use of International Standard ISO 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process" issued September 4, 2023, and International Standard ISO 10993-1 "Biological Evaluation of Medical Devices – Part 1: Evaluation and Testing Within a Risk Management Process," FDA recognition number 258.

When used as intended, the OtoNova device will be placed in transient contact with the user's skin during handling and Normal Use; the patient's total cumulative exposure of the device is expected to be