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510(k) Data Aggregation

    K Number
    K142159
    Date Cleared
    2015-06-03

    (301 days)

    Product Code
    Regulation Number
    882.1320
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    ROCHESTER ELECTRO MEDICAL, INC.

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

    The Disposable Pre-gelled Surface Electrodes are intended for recording/stimulation and monitoring of Electromyography (EMG), Electroencephalograph (EEG) and Evoked Potential (EP) signals.

    The Rochester Electro-Medical Disposable Pre-gelled Surface Electrodes are intended for use with recording, monitoring and stimulation equipment for the purpose of stimulating/recording of biopotential signals. Electrodes are applied in the study of biopotentials such as Electroencephalograph (EEG), surface Electromyography (EMG) and Evoked Potential signals (EP). Electrodes are non-invasive as they are applied to the patient's skin using a self-adhesive solid-gel surface. The electrodes are non-sterile and for single use only.

    Device Description

    A conductive solid gel electrode consisting of a conductive adhesive gel, a silver/silver chloride plated eyelet, an adhesive cloth substrate, label, lead wire with a 0.60" diameter touch-proof female socket per DIN 42802 and polystyrene release liner. These are available in various lead lengths, lead configurations, electrode styles/sizes, and wire colors.

    AI/ML Overview

    This document is a 510(k) Summary for the Rochester Electro-Medical Disposable Pre-gelled Surface Electrode, demonstrating its substantial equivalence to a predicate device.

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria are not explicitly enumerated with numerical targets in this summary. Instead, the document states that the physical and electrical characteristics of the subject device (Rochester Disposable Adhesive Surface Electrodes) were evaluated against those of the predicate device (Xian Friendship Medical K110289). The overarching acceptance criterion is "substantially equivalent" to the predicate device, meaning there are no new concerns regarding safety or effectiveness.

    Acceptance Criterion (Implicit)Reported Device Performance
    Physical and electrical characteristics comparable to predicate device."Physical and electrical characteristics evaluated during bench testing and in the comparison chart of this submission demonstrate that the design, materials, chemical composition, packaging, intended use, electrical performance and other characteristics of the subject device are comparable to those of the predicate device."
    Electrode Impedance measurements (comparable to predicate and method similar to K010431)."Bench testing included electrode impedance measurements of the subject device and the predicate using a 1kHz source and a Digital Multimeter, a method similar to that used in K010431. Details of this testing and performance criteria are included in section 18 of this submission, Performance Testing - Bench." (Specific numerical results are not provided in this summary, but are referenced as being in Section 18).
    Gel uniformity inspection."Additionally gel uniformity was inspected." (Details and specific results not provided in this summary).
    Biocompatibility (Cytotoxicity, Skin irritation, Skin sensitization)."The contact material is Tyco hydrogel RG-63 with slight proprietary variations and has been previously tested for material safety and biocompatibility to: Cytotoxicity study – ISO 10993-5, Skin irritation study - ISO 10993-10, Skin sensitization study - ISO 10993-10. There were no changes to the formulation for the new intended use." (Implied successful completion based on original testing of material).
    Shelf life"18 Months in unopened pouch." (This is a stated characteristic rather than a performance measure against a predicate in this summary document, but implies it meets expected criteria for stability).
    No new concerns regarding safety or effectiveness compared to predicate device."The Rochester Electro-Medical Disposable Pre-gelled Surface Electrodes are substantially equivalent to the predicate device... There are no new concerns regarding safety or effectiveness."

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

    The document refers to "bench testing" that included electrode impedance measurements and gel uniformity inspection. However, the specific sample size used for these tests is not provided in this 510(k) summary. The data provenance is implied to be from internal laboratory testing conducted by Rochester Electro-Medical, Inc. or an affiliated testing facility. It is prospective testing, performed specifically for this submission.

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

    This type of information is not applicable to this submission. The device is a physical electrode, and its performance is evaluated against engineering specifications and comparison to a predicate device, not through expert-labeled data for a diagnostic algorithm.

    4. Adjudication Method for the Test Set

    This information is not applicable as the evaluation is based on bench testing of physical and electrical properties, not on expert review of ambiguous cases.

    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

    This information is not applicable. The device is a physical electrode, not an AI-powered diagnostic tool, so an MRMC study is not relevant.

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

    This information is not applicable. The device is a physical electrode, not an algorithm.

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

    The "ground truth" for the device's performance is established by engineering measurements (e.g., electrode impedance, physical dimensions, material composition) and biocompatibility testing standards (ISO 10993 series). The ultimate "ground truth" for regulatory approval relies on demonstrating substantial equivalence to a predicate device that has already been deemed safe and effective based on similar scientific and engineering principles.

    8. The sample size for the training set

    This information is not applicable. As a physical medical device, there is no "training set" in the context of machine learning or AI algorithms.

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

    This information is not applicable for the same reason as in point 8.

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    K Number
    K080914
    Date Cleared
    2008-07-15

    (105 days)

    Product Code
    Regulation Number
    890.1385
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    ROCHESTER ELECTRO MEDICAL, INC.

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

    Recording muscle activity for Electromyography (EMG) applications. For single patient use only. Patient population: Adults.

    Device Description

    Bi-polar/multi-polar disposable concentric needles for recording muscle activity. The needles consist of a stainless steel hypodermic outer shell with a centered platinum/iridium inner recording core with a trocar sharpencd tip. An electrically insulated molded handle incorporates the contact points allowing electrical continuity through the connecting cable, which is sold separately.

    AI/ML Overview

    The Rochester Electro-Medical, Inc. Ultra Sharp Concentric Needles are diagnostic electromyograph needle electrodes. The acceptance criteria and the study proving the device meets these criteria are detailed in the "Non-clinical Testing" section of the 510(k) summary.

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria / CharacteristicReported Device Performance
    Core Centering & SizeVerified through microscopic visual examination.
    Microscopic Visual ExaminationConducted to assess overall quality.
    SharpeningMicroscopic visual examination with special attention to bevel convergence, burrs, and point. Also includes a foam test.
    Electrical Continuity of all polesVerified using an audible ohmmeter.
    Electrical Isolation of all polesVerified using an audible ohmmeter.
    Needle hypodermic shell examinationAssessed for straightness and stated length.
    Handle Mold DesignVisual and audible ohmmeter for electrical aspects.
    Connector InterfaceVisual and audible ohmmeter for electrical aspects.
    SterilityAchieved through Gamma Irradiation.
    BiocompatibilityMaterials (Stainless Steel & Platinum) are biocompatible.
    Mechanical SafetyPackaged needle covered with a needle cover.

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

    The document does not explicitly state a separate "test set" sample size in the traditional sense for a clinical study. The device performance was evaluated through a series of internal "Non-clinical Testing" procedures, which include:

    • Process Control: Verification of manufacturing processes.
    • Process Verification: Done according to established control processes.
    • Design Verification: Performed using samples from the first production run, with methods identical to the Process Approval phase.

    The "samples from the first production run" serve as the test set for design verification. The exact number of samples tested at each stage (Process Control, Process Verification, Design Verification) is not specified.

    Data Provenance: The data appears to be retrospective and internal, derived from the manufacturer's own quality control and design verification processes conducted in the U.S. (Lutz, FL).

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

    The document does not mention the use of external experts or a formal ground truth establishment process involving experts for the "Non-clinical Testing." The assessments were primarily based on internal quality control and manufacturing process verification, likely performed by manufacturing and quality control personnel. Their specific qualifications are not detailed.

    4. Adjudication Method for the Test Set

    No formal adjudication method (e.g., 2+1, 3+1) is described. The "Non-clinical Testing" relies on direct measurements, visual inspections, and functional tests (like ohmmeter readings) against predefined specifications. Discrepancies would likely be addressed through internal quality control protocols.

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

    No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. The submission focuses on the safety and effectiveness of the device itself through non-clinical bench testing, not on the improvement of human reader performance with or without AI assistance.

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

    The device is a physical medical instrument (a needle electrode), not an algorithm or an AI-powered system. Therefore, the concept of "standalone (algorithm only)" performance is not applicable. The performance described relates to the physical and electrical characteristics of the needle.

    7. The Type of Ground Truth Used

    The "ground truth" for the non-clinical testing appears to be based on:

    • Engineering Specifications/Design Parameters: For characteristics like core centering, size, length, and straightness.
    • Established Quality Control Standards: For visual examinations (burrs, bevel convergence, point) and functional tests (electrical continuity, isolation).
    • Industry Standards: Compliance with various ISO and AAMI/ANSI standards (e.g., ISO 13485, ISO 14971, ISO 10993-1, ISO 9626, ISO 7864).

    8. The Sample Size for the Training Set

    The concept of a "training set" is not applicable as this is a physical medical device, not an AI/ML algorithm. The document describes manufacturing processes and design verification, not algorithm development.

    9. How the Ground Truth for the Training Set was Established

    Not applicable, as there is no training set mentioned in the context of this device.

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