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510(k) Data Aggregation
(22 days)
Natus Manufacturing Limited
The Grass MR Conditional/CT Cup Electrodes and Arrays are intended for use in the recording of the Electroencephalogram (EEG), the evoked potential (EP), or as a ground and reference in an EEG or EP recording.
This device is non-sterile for Single Patient Use Only and may remain on the patient in an MRI or CT environment under specific conditions.
Grass® MR Conditional/CT Cup Electrodes are for surface monitoring EEG, electromyogenic and physiologic data signals commonly recorded on the chest, extremities, head and faces of patients. Grass® MR Conditional/CT Array Cup Electrodes are also used in electrocardiography, evoked potentials, and polysomnography. The Grass® MR Conditional/CT Array Cup Electrodes are MR conditional/CT. The included extension cables are MR/CT Unsafe.
The Operating Principle and technological characteristics of the Grass MR Conditional Cup Electrodes are identical to the predicate device (K171102), with a few dimensional and material modifications that have been assessed to be equivalent to the predicate and therefore do not affect the fundamental scientific technology, safety, or effectiveness of the device (reference Substantial Equivalence of Technological Characteristics table, below). The test methods were identical to those used to assess the predicate device.
The provided text describes the 510(k) premarket notification for the Grass® MR Conditional/CT Cup Electrodes. This document focuses on demonstrating substantial equivalence to a predicate device rather than presenting a study proving a device meets specific acceptance criteria for AI/ML performance. As such, many of the requested details regarding AI/ML device performance studies (e.g., sample sizes for test/training sets, expert consensus for ground truth, MRMC studies, standalone performance) are not applicable or present in this specific regulatory submission.
The document primarily details the physical and functional characteristics of the electrodes and their compliance with safety standards and predicate device equivalency, particularly concerning MR conditional features.
However, I can extract the closest applicable information related to "acceptance criteria" and "device performance" based on the provided text, interpreting "performance" in the context of the device's electrical and physical properties as assessed for medical device regulatory submission.
Here's an attempt to fill in the table and answer the questions based on the provided non-AI/ML medical device submission:
Acceptance Criteria and Reported Device Performance (Non-AI/ML Device)
Acceptance Criteria (Target Performance) | Reported Device Performance |
---|---|
Electrical Resistance (Singles) | ** |
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(196 days)
Natus Manufacturing Limited
The Allergan Botox Needle Electrode are for SINGLE USE ONLY in electromyography (EMG) in situations wherein it is desired to insert an electrode, in the form of a probe, into a patient to locate a particular muscle and then inject a medication into that muscle. The hypodermic needle with an open lumen is designed for muscle stimulation, motor unit action potential recording and drug delivery. Once the physician is satisfied with the location, he/she injects a drug therein via the lumen of the needle.
The Allergan Botox Needle Electrode is used in EMG applications to record EMG activity while allowing injection of medication. The Allergan Botox Needle Electrode is a sterile, disposable, monopolar needle electrode with attached lead wire. The needle shaft is insulated so the needle records signals received only from the tip. The needle hub is designed to allow for precise manipulation of the electrode.
The provided text describes a 510(k) premarket notification for the "Allergan Botox Needle Electrode." This document focuses on demonstrating substantial equivalence to a predicate device (K973444 Teca Myoject Disposable Needle Electrode) through non-clinical performance data. Therefore, the "acceptance criteria" and "study that proves the device meets the acceptance criteria" refer to the non-clinical performance tests conducted to show the device's functional equivalence and safety/effectiveness compared to its predicate.
Here's a breakdown of the requested information based on the provided document:
1. A table of acceptance criteria and the reported device performance
Test | Acceptance Criteria | Reported Device Performance |
---|---|---|
Dimensional measurement of Needle Electrode – Needle Length | Needle length should be 37.0 ± 1.5mm. | Pass |
Dimensional measurement of Needle Electrode - Needle Diameter with and without coating | The diameter of the Needle (without PTFE coat) Electrode should be of 27 Gauge (0.40± 0.1mm). The diameter of the Needle with PTFE coating should be between 0.420 to 0.456 mm. | Pass |
Device Continuity measurement | The resistance between needle tip to the standard 1.5mm connector end should be less than 1.5Ω to allow the biopotential signals. | Pass |
Biocompatibility Evaluation | Biocompatibility testing per ISO 10993-1, classifying it as an Invasive Electrode, external communicating device in limited (≤ 24 hours) contact with tissue. Tests considered: cytotoxicity (ISO 10993-5), sensitization (ISO 10993-10), irritation (ISO 10993-10), and Blood Compatibility Hemolysis Test (ISO 10993-4). | Pass |
Tensile testing | Acceptance Criteria: $>/=22N$ (Needle to Wire Crimp Pull Test). | Pass |
Penetration testing | Comparative data (Verify that the needle consistently produces the comparative sharpness and frictional force). | Pass |
Leak Testing | The resistance of the needle should be greater than $10MΩ$ (measured across the needle with probe on the PTFE coating). | Pass |
Tip geometry measurements | The tip geometry of the Product should be compliant with BS EN ISO 7864:2016 standard (Verified by certificate). | Pass |
Luer Lock Design | The Luer lock and Luer slip fit syringes should be conform to ISO 594-1 & 594-2 standard (Compliance of certificates for Luer lock and Luer slip fit syringes). | Pass |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
The document does not specify the exact sample sizes (number of units tested) for each non-clinical performance test. It only states "Pass" for each test.
The data provenance is from Natus Manufacturing Limited, Ireland, the manufacturer submitting the 510(k). The tests are non-clinical performance tests, typically conducted in laboratory settings.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
This is a non-clinical performance study of a physical device (needle electrode). The "ground truth" for these tests is established by engineering and quality control standards (e.g., precise measurements, material specifications, mechanical strength tests, and biocompatibility standards like ISO 10993). Therefore, human expert review in the sense of clinical image interpretation or diagnosis is not applicable. The expertise involved would be in manufacturing, quality assurance, materials science, and biomedical engineering.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. This is not a clinical study involving human interpretation or subjective assessment that would require adjudication. The tests are objective measurements and compliance checks against established engineering and safety standards.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
Not applicable. This 510(k) submission is for a medical device (a needle electrode), not an AI-powered diagnostic or assistive tool that would involve human readers. The study performed is a non-clinical performance comparison to a predicate device, focusing on physical and functional characteristics.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This is for a physical medical device, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
The "ground truth" for this device's performance relies on established engineering standards, material specifications, and regulatory requirements (e.g., ISO standards) for medical devices. For instance, needle length must fall within a specified range, resistance must be below a certain threshold, and materials must demonstrate biocompatibility through standardized tests. It's objective performance against predefined technical criteria rather than subjective clinical "ground truth."
8. The sample size for the training set
Not applicable. This is a 510(k) submission for a physical device, not an AI model requiring a training set.
9. How the ground truth for the training set was established
Not applicable, as there is no training set for a physical medical device.
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(283 days)
Natus Manufacturing Limited
The disposable hypodermic monopolar needles are FOR SINGLE USE ONLY in electromyography (EMG) in situations wherein it is desired to insert an electrode, in the form of a probe, into a patient to locate a particular muscle and then inject a medication into that muscle. The hypodermic needle with an open lumen is designed for muscle stimulation, motor unit action potential recording and drug delivery. Once the physician is satisfied with the location, he/she injects a drug therein via the lumen of the needle.
The Myoject™ Luer Lock Needle Electrode is a Disposable Hypodermic Needle Electrode
Here's a breakdown of the acceptance criteria and the study information for the Natus Manufacturing Limited Myoject™ Luer Lock Needle Electrode, based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance:
The document primarily focuses on demonstrating substantial equivalence to a predicate device (Teca Myoject Disposable Needle Electrode K973444) through a comparison of characteristics and performance testing. There isn't a direct "acceptance criteria" table with specific pass/fail metrics explicitly stated alongside the new device's performance in a quantitative manner for most characteristics. Instead, the "Discussion of Differences" column in Table 5A (starting on page 5) serves as the primary mechanism for demonstrating equivalence and addressing performance.
However, for Biocompatibility and Bench Testing, the performance is reported against established ISO and ASTM standards.
Characteristic / Test | Acceptance Criteria (Implicit from Predicate/Standards) | Myoject™ Luer Lock Needle Electrode Performance (Reported) |
---|---|---|
Biocompatibility | ||
Cytotoxicity | Non-cytotoxic (ISO 10993-5:2009) | Non-cytotoxic to L929 cells |
Irritation (Intracutaneous) | Average reaction not greater than control (ISO 10993-10:2010) | Meets requirements; average reaction not greater than control for polar and non-polar extracts |
Sensitization (Local Lymph Node Assay) | Non-sensitizer (ISO 10993-10:2010) | Polar and non-polar extracts considered non-sensitizers. Positive controls gave SI > 3 (as expected for positive control function). |
Systemic Toxicity | PASS (ISO 10993-11:2006) | 0.9% sodium chloride solution extract: PASS; Cottonseed oil extract: PASS |
Bench Testing | ||
Tensile testing | Implied to meet design specifications | Conducted; meets performance and design specifications |
Coating thickness | Implied to meet design specifications | Conducted; meets performance and design specifications |
Leak Testing | Implied to meet design specifications | Conducted; meets performance and design specifications |
Tip geometry grind measurements | Implied to meet design specifications | Conducted; meets performance and design specifications |
Penetration testing | Reduced initial penetration force compared to predicate (discussed as an improvement) | Conducted; meets performance and design specifications. Implied improved penetration. |
Luer Lock Design Verification | Secure Luer Lock connection (reduced seepage/leakage) | Conducted; meets performance and design specifications. Luer lock is described as adding an additional safety mechanism. |
Other Comparisons (from Table 5A) | ||
Labelling | Equivalent, with minor changes not affecting safety/effectiveness | Minor changes (manufacturer name, address, branding, warnings, harmonized symbols); do not raise questions of safety/effectiveness. |
Intended Use | Same as predicate | Same as predicate; minor labeling nuance regarding drug supply does not affect safety/effectiveness. |
Physical Characteristics | Monopolar Needle | Same |
Connector | Single Contact Touch Proof DIN42 802 | Same |
Material of Needle | Stainless 304 | Same |
Needle Diameter (mm) | 0.30, 0.41, 0.46, 0.51, 0.71 | Same |
Needle Coating Material | PTFE (different formulation) | PTFE (Xylan 8820 G4075); improved to reduce initial penetration force, similar safety/effectiveness. |
Hub | Luer Slip (predicate) | Luer Lock/Slip; improved to reduce risk of medication leakage. Doesn't affect overall function/safety/effectiveness. |
Hub Material | Polycarbonate (predicate) | Polypropylene (Exxonmobil) Escorene PP9074 MED; equivalent material performance, no new safety/effectiveness concerns. |
Needle grind angle | 10-20 degrees conical (predicate) | 10-16 degrees conical; slight change in upper range, not significant, no new safety/effectiveness concerns, no altered diagnostic effects. |
Recording area (sqmm) | 0.25 (predicate) | 0.19 (fine) to 0.89 (depending on size); differences vary, no effect on safety/effectiveness or diagnostic effects. |
Length (mm) | 25, 37, 50, 75, 100 (predicate) | 25, 37, 50, 75; 100mm version obsolete. No new safety/effectiveness concerns. |
Connecting lead | 14 or 26 inches, 2mm or touchproof plug (predicate) | 770±10mm, 'ST' moulded 1.5mm touch proof. Cable length "30" (76cm) to 1.5mm female touchproof connector; increased length, minor changes, no new safety/effectiveness concerns. |
Sterilization | Supplied sterilized gamma irradiated | Same |
Protective Sheath | Polyethylene (predicate) | Polypropylene Escorene PP9074 MED (Exxon Mobil); equivalent material performance, no new safety/effectiveness concerns. |
Protective Pouch | Tyvek/Mylar | Same |
Sterility Assurance Level (SAL) | 10 minus 6 (predicate) | 10 minus 6; improved needle tip sharpness. No new safety/effectiveness concerns. |
Tip geometry | Lancet Point (predicate) | Trocar Point, 15 degree bevel; preferred for range of needles, improves tip sharpness, reduces patient discomfort. |
2. Sample Size Used for the Test Set and Data Provenance:
- Sample Size for Test Set: The document does not explicitly state specific sample sizes for each of the performance tests (tensile, coating thickness, leak, tip geometry, penetration, Luer Lock verification). It refers to "Performance Testing" and "Bench Testing" being performed. For biocompatibility tests, details are provided on the methods (e.g., L929 cells for cytotoxicity, rabbit for intracutaneous reactivity, mouse for local lymph node assay), but the exact number of test items or animals used is not specified in this summary.
- Data Provenance: The studies were conducted by Natus Manufacturing Limited, which is based in Ireland. The nature of these tests (biocompatibility, bench testing) usually implies controlled laboratory settings rather than patient data. Therefore, the data Provenance is the manufacturer's internal testing. Not retrospective or prospective patient data.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Their Qualifications:
- This is not applicable as the studies described are non-clinical performance tests (biocompatibility and bench testing) and technical comparisons to a predicate device. The "ground truth" is established by adherence to recognized international standards (ISO, ASTM) for materials, design, and manufacturing quality, not expert consensus on clinical cases.
4. Adjudication Method for the Test Set:
- Not applicable, as this refers to non-clinical performance and design verification tests, not clinical studies with human assessors.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done:
- No, an MRMC comparative effectiveness study was not done. This device is a diagnostic electromyograph needle electrode, not an image-based diagnostic AI device that would typically involve an MRMC study. The comparison is primarily against a predicate device's design specifications and performance standards through bench testing.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done:
- Not applicable. This device is a medical instrument (needle electrode), not an algorithm or AI system.
7. The Type of Ground Truth Used:
- The "ground truth" for demonstrating the device's acceptable performance and substantial equivalence is based on:
- Adherence to International Standards: ISO 10993 series (Biocompatibility), ISO 2859-1 (Sampling), ASTM F 1980 (Sterile Barrier).
- Predicate Device Specifications: The Teca Myoject Disposable Needle Electrode (K973444) serves as the primary benchmark for comparison of design and technological characteristics.
- Design and Performance Specifications: The device's own predetermined specifications for physical characteristics and functional performance (e.g., tensile strength, leak integrity, penetration force).
8. The Sample Size for the Training Set:
- Not applicable. There is no training set mentioned, as this is a physical medical device, not an AI or machine learning model.
9. How the Ground Truth for the Training Set Was Established:
- Not applicable, as there is no training set.
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(270 days)
Natus Manufacturing Limited
Dantec™ DCN Disposable Concentric Needle Electrodes are intended for use with recording, monitoring and stimulation/recording equipment for the stimulation/recording of biopotential signals including electromyograph (EMG) and nerve potential signals.
The Dantec™ DCN Disposable Concentric Needle Electrodes are designed as an electrical bipolar recording device for use in electromyography. The Dantec™ DCN Disposable Concentric Needle Electrode consists of an insulated core wire located inside a stainless steel cannula. The hub has a raised bevel indicator, allowing the user to always know the direction of the recording surface. A coaxial hub allows easy connection between needle and the electrode cable.
Acceptance Criteria and Device Performance Study for Dantec™ DCN Disposable Concentric Needle Electrodes
This document describes the acceptance criteria and the study proving that the Dantec™ DCN Disposable Concentric Needle Electrodes meet these criteria, based on the provided 510(k) submission.
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria for the Dantec™ DCN Disposable Concentric Needle Electrodes are primarily demonstrated through equivalence to the predicate device (K112034 Teca™ Elite Disposable Concentric Needle Electrodes) and successful completion of various performance tests.
Acceptance Criterion | Predicate Device Specification (K112034 Teca™ Elite) | Dantec™ DCN Performance | Discussion of Equivalence/Compliance |
---|---|---|---|
Material | |||
Core Material | Tungsten | Tungsten | Same |
Low Friction Lubricant | Silicone | Silicone | Same |
Cannula | Stainless Steel | Stainless Steel | Same |
Internal Insulating Polymer Coating (Core to Lumen) | Polyesterimide | Polyesterimide/Araldite | Dantec™ DCN uses Polyesterimide with Araldite, still considered equivalent. |
Physical Dimensions | |||
Length Diameter (mm) | 25mm 0.30 (30g), 25mm 0.46 (26g), 37mm 0.46 (26g), 50mm 0.46 (26g), 75mm 0.64 (23g) | 25mm 0.30 (30g), 25mm 0.46 (26g), 37mm 0.46 (26g), 50mm 0.46 (26g), 75mm 0.64 (23g) | Same |
Tip geometry | Trocar Point | Trocar Point | Same |
Recording Area | Fine gauge = 0.03 mm², Medium gauge = 0.07mm² | Fine gauge = 0.02 mm², Medium gauge = 0.07mm² | Fine gauge is slightly smaller but meets functional criteria, demonstrating no significant difference. |
Mechanical Properties | |||
Hub/Cover Tensile | Specification: >1.2 kgf, Mean: 3.9 kgf | Specification: >1.2 kgf, Mean: 3.9 kgf | Same |
Needle/Hub Tensile | Specification: >6 lbf, Mean: 19.7 lbf | Specification: >6 lbf, Mean: 22.7 lbf | Exceeds predicate results, demonstrating no significant difference. |
Penetration Testing | (Implicit: Demonstrates acceptable sliding force) | (Result not explicitly quantified in table, but stated as performed) | Stated that testing was performed, implying satisfactory results to deem equivalence. |
Electrical Properties | |||
Impedance | Specification: ) | for endotoxin, ISO 2859-1 for sampling, and ASTM F 1980 for accelerated aging. Compliance with these standards serves as a form of ground truth for safety and performance. |
- Predicate Device Characteristics: For many aspects (materials, dimensions, sterilization, intended use), the characteristics and established performance of the legally marketed predicate device (K112034 Teca™ Elite Disposable Concentric Needle Electrodes) serve as the "ground truth" for demonstrating substantial equivalence.
8. The Sample Size for the Training Set
The concept of a "training set" is usually applicable to machine learning algorithms. Since the Dantec™ DCN Disposable Concentric Needle Electrodes are a physical medical device and not an AI/ML algorithm, there is no training set in this context. The manufacturing process and device design are optimized through engineering principles, quality control, and adherence to established standards, rather than through iterative training with a dataset.
9. How the Ground Truth for the Training Set was Established
As there is no training set for this device, the question of how its ground truth was established is not applicable.
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