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510(k) Data Aggregation

    K Number
    K191346
    Date Cleared
    2020-02-14

    (270 days)

    Product Code
    Regulation Number
    882.1310
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Blackrock NeuroCoG Subdural Cortical Electrodes (Strips and Grids) are intended for temporary (<30 days) use with recording, monitoring, and stimulation equipment for the recording, and stimulation of electrical signals on the surface of the brain. The recording of electrical activity supports definition of the location of epileptogenic foci and brain mapping.

    Device Description

    Cortical Electrode (Per FDA Classification)

    AI/ML Overview

    This document is a Traditional 510(k) Summary for the Blackrock NeuroCoG Subdural Cortical Electrodes (Strips and Grids). It asserts substantial equivalence to a predicate device (AD-TECH Subdural Cortical Electrodes) rather than claiming specific performance criteria and a study to meet them. Therefore, the requested information on acceptance criteria and a study proving the device meets them cannot be directly extracted as it would for a claim of new performance.

    However, I can interpret the document's content to provide related information about the device's safety and effectiveness testing where it implicitly establishes "acceptance criteria" through conformance to recognized standards and successful test results.

    Here's a breakdown of the available information, structured to align as closely as possible with your request:


    Acceptance Criteria and Device Performance (Indirectly Derived from Safety and Performance Testing)

    The document focuses on demonstrating substantial equivalence to a predicate device, which means proving the new device is as safe and effective as the legally marketed predicate. The "acceptance criteria" are generally implied to be compliance with relevant standards and successful completion of various tests, demonstrating that the device performs as intended and does not raise new questions of safety or efficacy.

    CategoryAcceptance Criteria (Implicit/Standard-based)Reported Device Performance (Results)
    BiocompatibilityISO 10993 Series (parts 1, 4, 5, 6, 10, 11) and ASTM F756-17, ASTM F2901:2019 standards for biological compatibility (e.g., non-hemolytic, non-cytotoxic, non-irritant, non-sensitizer, non-toxic, non-demyelinating, non-neurodegenerative, non-astrocytotic, non-microglial-proliferative with subdural rabbit brain implantation)Hemolysis: Non-hemolytic (Indirect Contact) Cytotoxicity: Non-cytotoxic (L929 MEM Elution) Implantation: Non-demyelinating, Non-neurodegenerative, Non-astrocytotic, and Non-microglial-proliferative (Subdural Rabbit Brain) Irritation: Non-irritant (Intracutaneous Reactivity) Sensitization: Non-sensitizer (Kligman Maximization) Acute Systemic Toxicity: Non-toxic (Systemic Injection)
    PyrogenicityANSI/AAMI ST72:2011/(R)2016 for bacterial endotoxins; Endotoxin limit of 2.15 EU/Device (0.06 EU/ml) based on potential contact with Cerebrospinal Fluid.BET/LAL: Non-pyrogenic (Kinetic Chromogenic Technique)
    SterilizationConformance to ISO 11135-1, ISO 11138-1, ISO 11138-2 standards for Ethylene Oxide sterilization (implied to achieve sterility assurance level).Ethylene Oxide sterilization method, "Sterile only" status. (Specific sterility assurance level not quantified here, but compliance to standards indicates successful sterilization).
    Packaging IntegrityConformance to ASTM F88/F88M-15, ASTM F1886-16, ASTM F1980-16, ASTM F2096-11, BS/EN/ISO 11607-1:2017 for seal strength, visual inspection, accelerated aging, and gross leak detection.Studies are ongoing, but "Currently 1 year (per accelerated aging) and 1-year and 5-year real-time aging studies are ongoing)" leading to an initial 1-year shelf life. Packaging configuration is double (Tyvek) pouched and placed in a chipboard box.
    Electrical PerformanceElectrical continuity, resistance, dielectric strength, impedance, and charge injection capacity (on new and aged products). For patient cable: channel mapping, resistance, shorts, dielectric strength, and impedance.The devices were physically tested for dielectric strength, impedance, resistance and charge injection capacity on new and aged products. The NeuroCoG Patient Cable was tested for channel mapping, resistance, shorts, dielectric strength, and impedance. Results are stated as successful but not quantified with specific values in this summary.
    Mechanical PerformanceTensile strength, bending, and chemical compatibility on new and aged products. For patient cable: tensile strength, mating, bending, dropping, and chemical compatibility.The Blackrock NeuroCoG Subdural Electrodes were physically tested for tensile strength, bending, and chemical compatibility on new and aged products, as well as underwent extensive verification of their mechanical properties. The NeuroCoG Patient Cable was tested for tensile strength, mating, bending, dropping, and chemical compatibility. Results are stated as successful but not quantified with specific values in this summary.
    Cleaning & Disinfection (Patient Cable)AAMI TIR12:2010, AAMI TIR30:2011(R)2016 for cleaning (protein and carbohydrate markers) and low-level disinfection (6-log reduction in bacteria).Cleaning: Protein Marker: <6.4 µg/cm²; Carbohydrate Marker: <1.8 µg/cm² (British soil, CaviWipes and CaviCide) Disinfection: 6-log reduction in bacteria (Low-level disinfection with CaviWipes and CaviCide)
    MRI SafetyImplied criteria related to potential hazards in an MR environment.Labeled as MR Unsafe. (Indication that it was evaluated and found not safe for MR environments, hence the labeling).

    Detailed Information on Studies:

    1. Sample sizes used for the test set and the data provenance:

      • Biocompatibility (Implantation Test): Performed on "Subdural Rabbit Brain". The exact number of rabbits used is not specified in this document. Data provenance is implied to be laboratory testing.
      • Cleaning/Disinfection (Patient Cable): No specific sample size for the "test set" (i.e., number of cables) is mentioned, but the methods were "British soil, CaviWipes, and CaviCide" and "Low-level disinfection with CaviWipes and CaviCide". Data provenance is laboratory testing.
      • Other tests (Hemolysis, Cytotoxicity, Irritation, Sensitization, Acute Systemic Toxicity, BET/LAL, Electrical, Mechanical, Packaging): The document refers to various standards (e.g., ISO, ASTM, AAMI TIR) that typically specify sample sizes for these types of tests. However, the specific sample sizes used by Blackrock Microsystems for each test are not detailed in this 510(k) summary. The studies are laboratory-based.
      • Retrospective or Prospective: All listed testing appears to be prospective laboratory testing or material characterization, rather than human clinical studies.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • This question is not applicable in the context of this device and submission. The "ground truth" for these types of tests (biocompatibility, electrical, mechanical, sterilization, packaging) is established by adherence to recognized scientific and engineering standards and methodologies, not by expert interpretation of clinical data or images. The "experts" would be the scientists and engineers conducting the tests and verifying compliance with the standards, whose qualifications are implied by their ability to conduct such highly specialized testing.
    3. Adjudication method (e.g., 2+1, 3+1, none) for the test set:

      • This is not applicable as the tests are analytical/performance-based, not interpretative (like image reading for diagnostic devices). Results are compared against predefined acceptance criteria from standards, not adjudicated by human readers.
    4. 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 is not applicable. The Blackrock NeuroCoG Subdural Cortical Electrodes are physical medical devices (electrodes and cables) used for recording and stimulation. They are not AI-powered diagnostic devices, and no human reader interpretation or AI assistance is involved in their direct function.
    5. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:

      • This is not applicable. The device is a passive electrical conductor and does not involve an algorithm or AI.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

      • The "ground truth" for the various tests mentioned is based on established scientific and engineering principles, recognized international standards (ISO, ASTM, AAMI), and predefined acceptance limits derived from these standards. For example, for biocompatibility assays, the ground truth is the chemical and biological response of materials as measured by standardized laboratory methods (e.g., cell viability in cytotoxicity, hemolytic index in hemolysis). For electrical and mechanical tests, it's the physical properties meeting defined specifications.
    7. The sample size for the training set:

      • This is not applicable. The device is a passive physical medical device and does not utilize a "training set" in the context of machine learning or AI algorithms. Its design and manufacturing are based on engineering principles and materials science.
    8. How the ground truth for the training set was established:

      • This is not applicable, as there is no "training set" for this device.
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