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510(k) Data Aggregation

    K Number
    K202621
    Date Cleared
    2021-08-05

    (329 days)

    Product Code
    Regulation Number
    882.1400
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    NeuroWave Systems Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The NeuroSENSE Monitoring System, Model NS-901, is intended for monitoring the brain state of adult and pediatric patients (18 years of age and older) in the operating room and other clinical settings by acquiring electroencephalographic (EEG) signals.

    The WAVCNs index, a quantifier of EEG activity calculated and displayed by the NeuroSENSE NS-901 Monitor, may be used as an aid in monitoring the hypnotic effect of anesthetics. The anesthetics include inhaled anesthetics and propofol in combination with opioids. The NeuroSENSE Monitor is intended to be used under the direction and interpretation of a qualified medical professional.

    Device Description

    The NeuroSENSE Monitoring System, Model NS-901, is a 2-channel bilateral processed Electroencephalograph (EEG) monitor for brain function monitoring in the operating room and other clinical settings. The acquired EEG waveforms and processed EEG variables are continuously displayed by the system for interpretation by a qualified medical professional and for use as a supplement to the anesthesia standard of care. The user interacts with the system via a touch screen interface.

    The NS-901 System consists of the following main components:

    • Display Module (DM-901) processes acquired EEG signals, displays EEG waveforms . and processed EEG variables, and archives them for later review
    • EEG Module (EM-901)
      1. acquires analog EEG signals through the integrated Patient Cable connected to electrodes on a patient's forehead,
      1. converts acquired analog EEG signals into digital EEG signals, and
      1. sends the digital EEG signals to the Display Module through the integrated Data Cable
    • EasyPrep Sensor Kit (EK-901) Noninvasive, disposable, single-use patient electrodes ● for acquiring the EEG signal

    The NeuroSENSE Monitoring System displays EEG waveforms and the following EEG processed variables and plots for each EEG channel:

    • Wavelet-based Anesthetic Value for Central Nervous System (WAVCNS) ●
    • . Electromyogram (EMG)
    • Suppression Ratio (SR) ●
    • Spectral parameters: Density Spectral Array (DSA), Median Edge Frequency (MEF), ● Spectral Edge Frequency (SEF), and spectral powers in different EEG frequency bands

    For improved reliability, the NeuroSENSE employs circuitry and algorithms for automatic detection, removal and/or filtering of physiological and environmental artifacts that commonly contaminate EEG signals. The NS-901 System also performs self-tests, automatic calibration of the amplifiers and continuous check of the electrode-skin contacts to ensure proper operation and optimal signal quality. Signal quality indicators (electrode status, 50/60 Hz noise level, artifact status) as well as system alarms, notifications and other related messages are displayed by the system. The system also provides protection for the operator and patient during cardiac defibrillation.

    AI/ML Overview

    The provided text describes the NeuroSENSE Monitoring System, Model NS-901, and its substantial equivalence to a predicate device. While it details several performance characteristics and the clinical study conducted, it does not explicitly state acceptance criteria in a quantitative, pass/fail manner. Instead, the performance is described in terms of "correlation," "discrimination," and "agreement" with clinical observations and the predicate device.

    Given this, I will infer relevant performance measures from the text and present them as "reported device performance." I will also explicitly state when information requested is not present in the provided document.


    Acceptance Criteria and Device Performance

    The NeuroSENSE Monitoring System, Model NS-901, was evaluated to demonstrate its substantial equivalence to the predicate device in monitoring brain function during anesthesia. While explicit, numeric acceptance criteria are not presented in a traditional table format in the provided text, the document describes the purpose of the validation and the outcomes that supported the substantial equivalence claim.

    Based on the provided information, the implicit acceptance criteria are related to the device's ability to:

    • Discriminate clinical endpoints related to consciousness.
    • Correlate with changes in anesthetic dosing.
    • Demonstrate an appropriate range for general anesthesia for its proprietary index (WAVCNS).
    • Show excellent agreement with the predicate device for a specific parameter (SR).
    Acceptance Criteria (Inferred from study goals)Reported Device Performance
    WAVCNS Index: Discriminate effectively between clinical endpoints (LOS, ROC).The WAVCNS index was shown to discriminate effectively between clinical endpoints such as loss of consciousness during propofol induction and return of consciousness during emergence from inhalational anesthesia.
    WAVCNS and SR: Correlate with changes in inhalational anesthetic dosing.Both the WAVCNS and SR were shown to correlate with changes in inhalational anesthetic dosing.
    WAVCNS Index: Appropriate range for general anesthesia.The WAVCNS range of 40 to 60 was found to be appropriate for general anesthesia.
    SR: Excellent agreement with predicate device's SR calculation.The re-processed data from the clinical trial to compare the SR parameter calculated by the subject device with that calculated by the predicate showed an excellent agreement between the two SR measures in this patient population.
    Safety: No new questions of safety or effectiveness compared to predicate.Clinical data collected in the operating room showed no adverse effects or complications. The nonclinical and clinical performance data demonstrate the subject device is as safe and effective as the predicate device. Additionally, the device complies with electromagnetic compatibility (EMC), electrical safety, and other safety standards (IEC 60601-1, 60601-2-26, 60601-1-2, 60601-1-8, 62133, etc.).
    Overall: Substantial equivalence to predicate for intended use.The study concluded that the subject device is substantially equivalent to its predicate for use as an aid in monitoring the hypnotic effect of anesthetics, as its indications for use are a subset of (narrower than and encompassed by) the predicate device's indications, and no new questions of safety or effectiveness arise.

    Study Details:

    1. Sample Size used for the Test Set and Data Provenance:

      • Sample Size: 75 adult surgical patients.
      • Patient Age: 18-71 years.
      • Gender: 18 male / 57 female.
      • ASA Classification: I-III.
      • Data Provenance: The study was a "prospective clinical study." While the country of origin is not explicitly stated, the context of an FDA 510(k) submission generally implies the study adheres to U.S. regulatory standards, often conducted in the U.S. or under international standards acceptable to the FDA. The data was collected "in the operating room."
    2. Number of Experts Used to Establish Ground Truth for the Test Set and Their Qualifications:

      • This information is not provided in the text. The ground truth ("clinical observations" and "drug information") was seemingly captured during standard clinical practice by the operating medical professional(s), but the number and specific qualifications of the adjudicating or ground truth-establishing experts are not specified.
    3. Adjudication Method for the Test Set:

      • This information is not provided in the text. The "clinical observations" and "drug information" that served as ground truth appear to be direct clinical records, but details on how these observations were adjudicated (e.g., by multiple experts, consensus, etc.) are absent.
    4. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:

      • No, an MRMC comparative effectiveness study was not explicitly mentioned or described. The study focused on the device's performance in relation to clinical observations and comparison to a predicate device's calculated parameter, rather than evaluating human reader improvement with or without AI assistance.
      • Effect Size of Human Readers Improvement: Not applicable, as no MRMC study was described.
    5. Standalone Performance (Algorithm-only without human-in-the-loop performance):

      • Yes, in essence. The study evaluated the device's calculated indices (WAVCNS, SR) against clinical observations and anesthetic dosing, as well as the agreement of the device's SR calculation with that of the predicate. The device generates these values automatically. While the interpretation of the NeuroSENSE Monitor's output and its use as an aid is "under the direction and interpretation of a qualified medical professional," the performance evaluation described (e.g., discrimination of endpoints, correlation with dosing, agreement of SR) refers to the algorithmic output's accuracy and utility.
    6. Type of Ground Truth Used:

      • The ground truth relied on clinical observations (e.g., loss of consciousness (LOC) and return of consciousness (ROC)) and drug information (anesthetic dosing). Comparison for SR was against the SR calculated by a predicate device. This implies a form of clinical outcome/physiological measurement-based ground truth, observed by medical professionals during actual procedures.
    7. Sample Size for the Training Set:

      • This information is not provided in the text. The document describes the "validation" study as a "prospective clinical study in 75 adult surgical patients." It does not specify whether this dataset was used for training, testing, or exclusively for validation, nor does it mention the size of a separate training set if applicable. The focus of this 510(k) is on the validation data that supports substantial equivalence.
    8. How Ground Truth for the Training Set Was Established:

      • This information is not provided in the text, as details on a distinct training set are absent. If part of the 75-patient dataset was used for training (which is unlikely for a validation study unless it was a hold-out set for final performance evaluation), the ground truth would have been established via clinical observations and drug information as described for the evaluation.
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    K Number
    K142834
    Date Cleared
    2015-06-23

    (266 days)

    Product Code
    Regulation Number
    882.1400
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    NeuroWave Systems Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The DiscoverEEG System, Model DE-401 is intended to be used for measuring and recording the electrical activity of a subject's brain, obtained by placing non-invasive electrodes on the head. The DiscoverEEG, DE-401 is indicated for use in acquiring electroencephalographic (EEG) signals in the OR, ICU, ER, clinical settings and at home and for clinical research. The medical use of data acquired by the DiscoverEEG is to be performed under the direction and interpretation of a licensed medical professional. The DiscoverEEG, Model DE-401 does not provide any diagnostic conclusion about the subject's condition.

    Device Description

    The DiscoverEEG System, Model DE-401, is a wearable, medical-grade EEG device that acquires and stores up to four electroencephalograms (EEGs) obtained from noninvasive electrodes placed on a subject's head. The acquired EEG waveforms, as well as, processed EEG spectral variables are continuously stored by the system for later retrieval. The data can be transferred from the DiscoverEEG hardware to a computer for review. The DiscoverEEG System, Model DE-401 has four main components: Acquisition Module, Memory Module, Disposable Electrode Array, and Data Viewer Software.

    AI/ML Overview

    The provided text does not contain specific acceptance criteria for performance metrics (like sensitivity, specificity, accuracy) related to the interpretation of EEG signals by the DiscoverEEG System, Model DE-401 for diagnostic purposes. This is explicitly stated in the Indications for Use: "The DiscoverEEG, Model DE-401 does not provide any diagnostic conclusion about the subject's condition."

    Instead, the non-clinical testing sections focus on the device meeting its design and functional requirements, safety standards (UL, IEC60601-1, IEC60601-1-11, IEC60601-2-26), and electromagnetic compatibility (IEC60601-1-2). The substantial equivalence claim is based on similar intended use, technological characteristics, and principles of operation to predicate devices, with bench testing demonstrating functional performance without providing specific quantitative metrics for diagnostic accuracy.

    Therefore, for the aspects requested, here's what can be extracted from the document:

    1. A table of acceptance criteria and the reported device performance

    The document does not provide a table of performance-based acceptance criteria (e.g., sensitivity, specificity) for diagnostic accuracy. The "reported device performance" is primarily qualitative, stating that the device "meets its design and functional requirements" and "performed as expected."

    Acceptance Criteria CategoryReported Device Performance
    Design & Functional RequirementsMeets design and functional requirements; performed as expected; no unexpected behavior observed.
    Safety StandardsWill comply with IEC60601-1, IEC60601-1-11, IEC60601-2-26, and UL medical electrical equipment standards.
    Electromagnetic CompatibilityWill comply with IEC60601-1-2 and IEC60601-2-26.

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    Not applicable. The document states "Laboratory testing, performed on identical hardware to the DiscoverEEG subject of this submission, demonstrated that the DiscoverEEG, Model DE-401 meets its design and functional requirements." This indicates bench testing rather than a clinical human subject test set. There's no mention of sample size or data provenance in this context.

    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)

    Not applicable. The testing described is non-clinical bench testing, not involving human interpretation for ground truth.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Not applicable. There was no test set requiring expert adjudication for ground truth.

    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. The device "does not provide any diagnostic conclusion about the subject's condition" and the submission states "further clinical data is not required to demonstrate performance for the DiscoverEEG, Model DE-401 for the indication for use subject to this submission." Therefore, no MRMC study was performed to assess human reader improvement with or without AI assistance.

    6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done

    Not applicable in the context of diagnostic performance. The device's function is to "measure and record the electrical activity of a subject's brain" and provide "processed EEG spectral variables." The medical use and interpretation are explicitly "to be performed under the direction and interpretation of a licensed medical professional." While the device itself processes signals, the "standalone" performance for diagnostic purposes is not claimed or evaluated. The non-clinical testing focused on hardware functionality and adherence to standards.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    Not applicable. The testing described is non-clinical/bench testing against design specifications and functional requirements, not against clinical ground truth like expert consensus, pathology, or outcomes data.

    8. The sample size for the training set

    Not applicable. The document does not describe an AI/ML component that requires a training set for diagnostic or interpretative tasks. The device acquires and processes EEG signals, but its output is for interpretation by a medical professional, not a standalone diagnostic conclusion.

    9. How the ground truth for the training set was established

    Not applicable, as there is no described training set.

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    K Number
    K092477
    Date Cleared
    2010-10-29

    (443 days)

    Product Code
    Regulation Number
    882.1400
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    NEUROWAVE SYSTEMS, INC.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The NeuroFAST Monitoring System, Model NF-201 is intended to be used for measuring and recording the electrical activity of a patient's brain, obtained by placing electrodes on the head. The NeuroFAST NF-201 is indicated for use in acquiring electroencephalographic (EEG) signals in the OR, ICU, ER, clinical settings and for clinical research. The NeuroFAST Monitor is to be used under the direction and interpretation of a licensed medical professional. The NeuroFAST Monitoring System, Model NF-201 does not provide any diagnostic conclusion about the patient's condition.

    Device Description

    The NeuroFAST Monitoring System, Model NF-201, is an EEG monitor that records and displays electroencephalograms (EEGs) obtained from noninvasive electrodes placed on a patient's head. The acquired EEG waveforms and processed EEG variables are continuously displayed by the system for interpretation by the licensed medical professional. The NeuroFAST Monitoring System, Model NF-201 has three main components: Display Module (DM-201), Patient Module (PM-201), and EasyPrep Sensor Kit (EK-701).

    AI/ML Overview

    The NeuroFAST Monitoring System, Model NF-201, is an EEG monitor. The provided 510(k) summary focuses on demonstrating substantial equivalence to predicate devices rather than establishing novel safety and effectiveness through specific clinical performance criteria. Therefore, the information regarding acceptance criteria and a study proving device performance as typically understood for new medical devices with specific performance claims (e.g., diagnostic accuracy) is not present in the same way it would be for analytical or clinical performance studies.

    Here's an analysis based on the available information:

    1. Table of Acceptance Criteria and Reported Device Performance:

    Since this 510(k) is for an EEG monitor, the "acceptance criteria" are primarily related to its technical specifications and compliance with relevant standards, demonstrating that it functions equivalently to existing devices. There aren't specific diagnostic performance metrics (e.g., sensitivity, specificity) listed as acceptance criteria that a study would then "prove" the device meets.

    Instead, the acceptance criteria are implicitly met by showing the device's technical specifications and intended use are similar to predicate devices and that it complies with relevant safety and technical standards.

    Feature / StandardAcceptance Criteria (Implied)Reported Device Performance (NeuroFAST NF-201)
    Intended UseConsistent with 21 CFR 882.1400 (Electroencephalograph)Measuring and recording electrical activity of the brain, acquiring EEG signals in OR, ICU, ER, clinical settings, and for clinical research. No diagnostic conclusion provided.
    ModalitiesEEGEEG
    Environment of UseHospitals and ClinicsOperating room, intensive care unit, emergency room, and clinical settings where EEG monitoring is used.
    Sensing ElectrodesStandard EEG electrodesSilver-silver chloride disposable EEG electrodes (EasyPrep Sensor Kit)
    Screen DisplayRaw EEG waveforms and spectral parametersDisplays: Raw EEG Waveforms, Spectral Parameters (EEG power spectrum and frequency bands, 50% Median Edge Frequency (MEF), and 95% Spectral Edge Frequency (SEF))
    Stored EEG dataYesYes - through removable storage
    EEG ChannelsMultiple channels, typically 2 or more for EEG monitoring2 bilateral frontal channels viewed concurrently
    Real Time DisplayYesYes
    Processed BandwidthAppropriate for EEGUser Selectable: Low Filter: 0.125 or 0.5 Hz, High Filter: 30 or 70 Hz
    Automatic ArtifactingYesYes
    Amplifier CMRR≥ 100 dB≥100 dB
    Amplifier Input Impedance≥ 50 Meg Ohms (Predicate: ≥ 100 Meg Ohms)≥50 Meg Ohm
    Electrode Impedance TestYesYes - Continuous and on demand
    Derived/Processed EEG MeasuresPower spectrum parameters common to EEG monitorsPower spectrum parameters derived from FFT: Power spectrum (Density Spectral Array), 95% Spectral Edge Frequency (SEF), Median Edge Frequency (MEF), Spectral Powers in EEG frequency bands (α, β1, β2, δ, θ and γ)
    Patient IsolationElectrical isolation for patient safetyYes - Patient module (analog-to-digital converter) provides 6kV electrical isolation of the patient from the monitor.
    Safety StandardsCompliance with Medical Electrical Equipment and Electroencephalograph Standards (IEC/UL)Complies with IEC60601-1, IEC60601-1-4, IEC60601-2-26. Will meet UL medical electrical equipment standards for safety.
    EMC StandardsCompliance with Electromagnetic Compatibility Standards (IEC)Complies with IEC60601-1-2, IEC60601-2-26.
    Functional RequirementsMeets design and functional requirements; performs as expected.Laboratory testing on identical hardware demonstrated that the NeuroFAST Monitoring System, Model NF-201 meets its design and functional requirements, including IFCN Guidelines for electroencephalographs. Actual device functions and features were evaluated against the device specifications and in all instances the NeuroFAST NF-201 performed as expected and no unexpected behavior was observed.

    Study Proving Device Meets Acceptance Criteria:

    The key study mentioned is non-clinical bench testing.

    2. Sample Size Used for the Test Set and Data Provenance:

    • Sample Size for Test Set: Not applicable in the traditional sense for a clinical performance study. The "test set" in this context refers to the device itself and its components undergoing engineering and functional verification. The summary states "Laboratory testing, performed on identical hardware to the NeuroFAST subject of this submission..." This implies testing was done on units of the device, not a sample of patient data.
    • Data Provenance: Not applicable. The testing described is hardware and functional verification, not data from patients. There is no mention of country of origin or retrospective/prospective nature as clinical data was not used.

    3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:

    • Number of Experts: Not applicable. For hardware and functional testing, "ground truth" is typically established by engineering specifications, international standards, and comparison with predicate device functionalities, not through expert reading of data generated by the device.
    • Qualifications of Experts: Not applicable.

    4. Adjudication Method for the Test Set:

    • Adjudication Method: Not applicable. The testing described is objective measurement against specifications and visual verification of expected device behavior, not subjective interpretation requiring adjudication.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done:

    • No, an MRMC comparative effectiveness study was not done. The summary explicitly states: "We believe further clinical data is not required to demonstrate performance for the NeuroFAST NF-201 for the indication for use subject to this submission." This indicates that the regulatory pathway relied on demonstrating substantial equivalence through technical specifications and non-clinical testing rather than proving improved human reader performance with or without AI assistance.
    • Effect Size: Not applicable as no such study was performed.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done:

    • No, a standalone algorithm performance study was not done. The NeuroFAST Monitoring System, Model NF-201 is described as an EEG monitor that records and displays EEGs for interpretation by a licensed medical professional. It "does not provide any diagnostic conclusion about the patient's condition." This means it's a data acquisition and display device, not an AI-powered diagnostic algorithm. Its performance is intrinsically tied to its ability to accurately acquire and present physiological signals, not to generate a standalone interpretation.

    7. Type of Ground Truth Used:

    • Ground Truth: For the non-clinical testing, the "ground truth" was the device's own design and functional requirements, IFCN Guidelines for electroencephalographs, device specifications, and relevant international safety and EMC standards (IEC60601-1, IEC60601-1-4, IEC60601-2-26, IEC60601-1-2). The performance was evaluated against these predetermined engineering and regulatory benchmarks.

    8. Sample Size for the Training Set:

    • Sample Size for Training Set: Not applicable. This device is an EEG monitor, not an AI/ML algorithm that requires a training set in the conventional sense. Its function is to acquire and display biological signals, not to learn patterns from data.

    9. How the Ground Truth for the Training Set Was Established:

    • How Ground Truth for Training Set Was Established: Not applicable, as there is no training set for this type of device.
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