(159 days)
Not Found
Not Found
Unknown
The document does not explicitly mention AI or ML, but the functions described (Seizure Detection, Spike Detection, Sleep State feature, Artifact Reduction) are commonly implemented using AI/ML techniques in modern medical devices. Without further information, it's impossible to confirm.
No
The device is described as software for review, monitoring, and analysis of EEG recordings to aid in assessment. It specifically states "This device does not provide any diagnostic conclusion about the patient's condition to the user." and "Persyst Imaging Workflow is not intended to provide diagnostic information." and "The sleep state output is subject to user confirmation via EEG waveform review and is not intended for the diagnosis of sleep disorders". It functions as an aid to diagnosis, rather than providing therapy.
Yes
The "Intended Use / Indications for Use" section repeatedly states that the software is intended to "aid neurologists in the assessment of EEG," "assist qualified clinical practitioners in the assessment of EEG traces," and mark sections that "may correspond to electrographic seizures," all of which point to its role in diagnosis. However, it also explicitly states in point 13: "This device does not provide any diagnostic conclusion about the patient's condition to the user." This creates a contradiction. Given that the software is designed to assist in the "assessment" and "identification" of potential conditions (seizures, spikes etc.), it primarily functions as a diagnostic aid. The disclaimer that it "does not provide any diagnostic conclusion" means it doesn't make a final diagnosis, but rather provides information used in the diagnostic process.
Yes
The device is described as "Persyst 15 EEG Review and Analysis Software" and its intended uses are focused on the processing, analysis, and visualization of EEG data, including features like seizure detection, spike detection, sleep state analysis, quantitative measures, and artifact reduction. While it processes data from hardware devices (EEG, MRI, CT), the device itself is presented as software for review and analysis, not a hardware component.
Based on the provided information, this device is not an In Vitro Diagnostic (IVD).
Here's why:
- IVDs analyze samples taken from the human body. The intended use and device description clearly state that this software analyzes EEG recordings, which are electrical signals measured from the scalp, not a biological sample taken from the body (like blood, urine, or tissue).
- The device processes existing recordings. The software reviews, monitors, and analyzes previously acquired EEG recordings. IVDs typically involve the analysis of a sample in vitro (in a lab setting) to provide information about a patient's health.
- The device aids in the assessment of EEG. The primary function is to assist qualified medical practitioners in interpreting EEG data, marking potential events, and providing quantitative measures. This is distinct from performing a test on a biological sample to diagnose a condition.
While the device uses imaging modalities (MRI, CT) and processes physiological signals (ECG), its core function revolves around the analysis of electrical activity of the brain as captured by an EEG device, not the analysis of biological samples.
N/A
Intended Use / Indications for Use
-
Persyst 15 EEG Review and Analysis Software is intended for the review, monitoring and analysis of EEG recordings made by electroencephalogram (EEG) devices to aid neurologists in the assessment of EEG. This device is intended to be used by qualified medical practitioners who will exercise professional judgment in using the information.
-
The Seizure Detection and Seizure Probability component of Persyst 15 is intended to mark previously acquired sections of the adult (greater than or equal to 18 years) EEG recordings that may correspond to electrographic seizures, in order to assist qualified clinical practitioners in the assessment of EEG traces. EEG recordings should be obtained with a full scalp montage according to the standard 10/20 system. Alternatively, the Seizure Detection can operate using reduced set of electrodes including Fp1, F7, T3, O1, Fp2, F8, T3, T6, O2, but will have decreased sensitivity for seizures due to its limited spatial sampling.
-
The Neonatal Seizure Detection component of Persyst 15 is intended to mark previously acquired sections of neonatal patients' (defined as near-term or term neonates of conceptional age between 36 and 44 weeks and less than two weeks of chronologic age) EEG recordings that may correspond to electrographic seizures, in order to assist qualified clinical practitioners in the assessment of EEG traces. EEG recordings should be obtained with scalp-recorded EEG using the standard International 10-20 system electrode placement, modified for neonates (this includes electrode sites Fp1/2 or alternate F1/2, C3/4, T3/4, O1/2, and Cz, optionally including Fz). Alternatively, the Neonatal Seizure Detection component can operate using a more reduced set of electrodes including C3/4, Fp1/2 (F1/2), and O1/2 (recorded in such a manner to allow creation of montage C3-4, Fp1-O1, Fp2-O2), or an even more simplified electrode set including only C3/4 and Cz (arranged as C3-Cz and C4-Cz), but the three-electrode montage will have decreased sensitivity for seizures due to its limited spatial sampling.
-
The Spike Detection component of Persyst 15 is intended to mark previously acquired sections of the patient's EEG recordings that may correspond to spikes, in order to assist qualified clinical practitioners in the assessment of EEG traces. The Spike Detection component is intended to be used in patients at least one month old. Persyst 15 Spike Detection performance has not been assessed for intracranial recordings.
-
Persyst 15 EEG Review and Analysis Software includes the Persyst Imaging Workflow (PW), an imaging viewer. It is intended for use by qualified clinical practitioners on both adult and pediatric subjects at least 12 years of age to interpret EEG data in conjunction with any type of neuroimaging including magnetic resonance imaging (MRI) or computed tomography scans (CT). Persyst Imaging Workflow is not intended to provide diagnostic information.
-
The Persyst ESI component of Persyst 15 is intended for use by a trained/qualified EEG technologist or physician on both adult and pediatric subjects at least 3 years of age for the visualization of human brain function by fusing a variety of EEG information with rendered images of an individualized head model and an individualized MRI image.
-
The Persyst 15 sleep state feature provides the user with output concerning wake-sleep states (wake or sleep,) present in an EEG recording as an aid in assessing which states are present and when they are present. The EEG being assessed for sleep state should utilize standard 10-20 system electrode recording positions and contain the expected EEG patterns of typical wake and sleep, with no major persistent pathological alterations. The sleep state output is subject to user confirmation via EEG waveform review and is not intended for the diagnosis of sleep disorders (e.g.: sleep apnea, narcolepsy, restless leg syndrome). The sleep state feature is intended for adult and pediatric subjects at least 13 years and older.
-
Persyst 15 includes the calculation and display of a set of quantitative measures intended to monitor and analyze the EEG waveform. These include FFT, Rhythmicity, Peak Envelope, Artifact Intensity. Amplitude. Relative Symmetry, and Suppression Ratio. Automatic event marking is not applicable to quantitative measures. These quantitative EEG measures should always be interpreted in conjunction with review of the original EEG waveforms.
-
Persyst 15 displays physiological signals, including the calculation and display of a heart rate measurement based on the ECG channel in the EEG recording, which are intended to aid in the analysis of an EEG. Heart rate measurement of Persyst 15 is not applicable to patients with pacemaker and/or active implantable devices.
-
The aEEG functionality included in Persyst 15 is intended to monitor the state of the brain. The automated event marking function of Persyst 15 is not applicable to aEEG.
-
Persyst 15 provides notifications for seizure detection, quantitative EEG and aEEG that can be used when processing a record during acquisition. These include an on screen display and the optional sending of an email message. Delays of up to several minutes can occur between the beginning of a seizure and when the Persyst 15 notifications will be shown to a user. Persyst 15 notifications cannot be used as a substitute for real time monitoring of the underlying EEG by a trained expert.
-
Persyst 15 AR (Artifact Reduction) is intended to reduce EMG, eye movement, and electrode artifacts in a standard 10-20 EEG recording. AR does not remove the entire artifact signal, and is not effective for other types of artifacts. AR may modify portions of waveforms representing cerebral activity. Waveforms must still be read by a qualified medical practitioner trained in recognizing artifact, and any interpretation or diagnosis must be made with reference to the original waveforms.
-
This device does not provide any diagnostic conclusion about the patient's condition to the user.
Product codes (comma separated list FDA assigned to the subject device)
OMB, OLT, OMA, OLX
Device Description
Not Found
Mentions image processing
Yes
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Electroencephalogram (EEG), magnetic resonance imaging (MRI), computed tomography scans (CT)
Anatomical Site
Human brain
Indicated Patient Age Range
- Seizure Detection and Seizure Probability component: adult (greater than or equal to 18 years)
- Neonatal Seizure Detection component: near-term or term neonates of conceptional age between 36 and 44 weeks and less than two weeks of chronologic age
- Spike Detection component: at least one month old
- Persyst Imaging Workflow: adult and pediatric subjects at least 12 years of age
- Persyst ESI component: adult and pediatric subjects at least 3 years of age
- Sleep state feature: adult and pediatric subjects at least 13 years and older
Intended User / Care Setting
Qualified medical practitioners, trained/qualified EEG technologist or physician
Description of the training set, sample size, data source, and annotation protocol
Not Found
Description of the test set, sample size, data source, and annotation protocol
Not Found
Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)
Not Found
Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)
Not Found
Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.
Not Found
Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.
Not Found
Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).
Not Found
§ 882.1400 Electroencephalograph.
(a)
Identification. An electroencephalograph is a device used to measure and record the electrical activity of the patient's brain obtained by placing two or more electrodes on the head.(b)
Classification. Class II (performance standards).
0
January 22, 2025
Image /page/0/Picture/1 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo 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.
Persyst Development Corporation Dari Darabbeigi Vice President of Quality and Regulatory Affairs 420 Stevens Avenue, Suite 210 Solana Beach, California 92075
Re: K242446
Trade/Device Name: Persyst 15 EEG Review and Analysis Software (Persyst 15 (P15)) Regulation Number: 21 CFR 882.1400 Regulation Name: Electroencephalograph Regulatory Class: Class II Product Code: OMB, OLT, OMA, OLX Dated: December 20, 2024 Received: December 23, 2024
Dear Dari Darabbeigi:
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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2
(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.
All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rue"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-devices/device-advicecomprehensive-regulatory-assistance/unique-device-identification-system-udi-system.
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).
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Sincerely,
Image /page/2/Picture/3 description: The image contains the name "Patrick Antkowiak -S" in a simple, sans-serif font. To the left of the name is a faded, light blue FDA logo. The name is stacked vertically, with "Patrick" on top and "Antkowiak -S" below it. The overall impression is clean and professional.
for Jay Gupta Assistant Director DHT5A: Division of Neurosurgical, Neurointerventional, and Neurodiagnostic Devices OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
3
Indications for Use
Submission Number (if known)
Device Name
Persyst 15 EEG review and Analysis Software (Persyst 15 (P15))
Indications for Use (Describe)
-
Persyst 15 EEG Review and Analysis Software is intended for the review, monitoring and analysis of EEG recordings made by electroencephalogram (EEG) devices to aid neurologists in the assessment of EEG. This device is intended to be used by qualified medical practitioners who will exercise professional judgment in using the information.
-
The Seizure Detection and Seizure Probability component of Persyst 15 is intended to mark previously acquired sections of the adult (greater than or equal to 18 years) EEG recordings that may correspond to electrographic seizures, in order to assist qualified clinical practitioners in the assessment of EEG traces. EEG recordings should be obtained with a full scalp montage according to the standard 10/20 system. Alternatively, the Seizure Detection can operate using reduced set of electrodes including Fp1, F7, T3, O1, Fp2, F8, T3, T6, O2, but will have decreased sensitivity for seizures due to its limited spatial sampling.
-
The Neonatal Seizure Detection component of Persyst 15 is intended to mark previously acquired sections of neonatal patients' (defined as near-term or term neonates of conceptional age between 36 and 44 weeks and less than two weeks of chronologic age) EEG recordings that may correspond to electrographic seizures, in order to assist qualified clinical practitioners in the assessment of EEG traces. EEG recordings should be obtained with scalp-recorded EEG using the standard International 10-20 system electrode placement, modified for neonates (this includes electrode sites Fp1/2 or alternate F1/2, C3/4, T3/4, O1/2, and Cz, optionally including Fz). Alternatively, the Neonatal Seizure Detection component can operate using a more reduced set of electrodes including C3/4, Fp1/2 (F1/2), and O1/2 (recorded in such a manner to allow creation of montage C3-4, Fp1-O1, Fp2-O2), or an even more simplified electrode set including only C3/4 and Cz (arranged as C3-Cz and C4-Cz), but the three-electrode montage will have decreased sensitivity for seizures due to its limited spatial sampling.
-
The Spike Detection component of Persyst 15 is intended to mark previously acquired sections of the patient's EEG recordings that may correspond to spikes, in order to assist qualified clinical practitioners in the assessment of EEG traces. The Spike Detection component is intended to be used in patients at least one month old. Persyst 15 Spike Detection performance has not been assessed for intracranial recordings.
-
Persyst 15 EEG Review and Analysis Software includes the Persyst Imaging Workflow (PW), an imaging viewer. It is intended for use by qualified clinical practitioners on both adult and pediatric subjects at least 12 years of age to interpret EEG data in conjunction with any type of neuroimaging including magnetic resonance imaging (MRI) or computed tomography scans (CT). Persyst Imaging Workflow is not intended to provide diagnostic information.
-
The Persyst ESI component of Persyst 15 is intended for use by a trained/qualified EEG technologist or physician on both adult and pediatric subjects at least 3 years of age for the visualization of human brain function by fusing a variety of EEG information with rendered images of
4
an individualized head model and an individualized MRI image.
-
The Persyst 15 sleep state feature provides the user with output concerning wake-sleep states (wake or sleep,) present in an EEG recording as an aid in assessing which states are present and when they are present. The EEG being assessed for sleep state should utilize standard 10-20 system electrode recording positions and contain the expected EEG patterns of typical wake and sleep, with no major persistent pathological alterations. The sleep state output is subject to user confirmation via EEG waveform review and is not intended for the diagnosis of sleep disorders (e.g.: sleep apnea, narcolepsy, restless leg syndrome). The sleep state feature is intended for adult and pediatric subjects at least 13 years and older.
-
Persyst 15 includes the calculation and display of a set of quantitative measures intended to monitor and analyze the EEG waveform. These include FFT, Rhythmicity, Peak Envelope, Artifact Intensity. Amplitude. Relative Symmetry, and Suppression Ratio. Automatic event marking is not applicable to quantitative measures. These quantitative EEG measures should always be interpreted in conjunction with review of the original EEG waveforms.
-
Persyst 15 displays physiological signals, including the calculation and display of a heart rate measurement based on the ECG channel in the EEG recording, which are intended to aid in the analysis of an EEG. Heart rate measurement of Persyst 15 is not applicable to patients with pacemaker and/or active implantable devices.
-
The aEEG functionality included in Persyst 15 is intended to monitor the state of the brain. The automated event marking function of Persyst 15 is not applicable to aEEG.
-
Persyst 15 provides notifications for seizure detection, quantitative EEG and aEEG that can be used when processing a record during acquisition. These include an on screen display and the optional sending of an email message. Delays of up to several minutes can occur between the beginning of a seizure and when the Persyst 15 notifications will be shown to a user. Persyst 15 notifications cannot be used as a substitute for real time monitoring of the underlying EEG by a trained expert.
-
Persyst 15 AR (Artifact Reduction) is intended to reduce EMG, eye movement, and electrode artifacts in a standard 10-20 EEG recording. AR does not remove the entire artifact signal, and is not effective for other types of artifacts. AR may modify portions of waveforms representing cerebral activity. Waveforms must still be read by a qualified medical practitioner trained in recognizing artifact, and any interpretation or diagnosis must be made with reference to the original waveforms.
-
This device does not provide any diagnostic conclusion about the patient's condition to the user.
Type of Use (Select one or both, as applicable)
X Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
CONTINUE ON A SEPARATE PAGE IF NEEDED.
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