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510(k) Data Aggregation
(71 days)
The EEG NeuroAmp is intended for biofeedback and relaxation purposes. To perform its intended function it must be used in combination with a computer and appropriate software.
For purposes of this training task, information for feedback may be derived from one or two channels of EEG and from as many as three channels of peripheral physiology measures such as are conventionally used in biofeedback.
The EEG NeuroAmp is intended to be used in the office by trained professionals who can ensure sound handling practices.
The EEG NeuroAmp is not intended for diagnostic purposes.
The purpose of the EEG NeuroAmp is to act as user-friendly high-performance interface between client and clinician computer for EEG biofeedback) and/or peripheral biofeedback therapy. The EEG NeuroAmp contains four function blocks:
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- EEG amplifier, two channels, aligned and high-resolution
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- Built-in impedance meter for five electrodes helps achieve good electrode contact and warns if electrodes are worn out
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- Peripheral sensor amplifiers, three channels, allow measurement of peripheral biofeedback signals such as GSR (Galvanic Skin Response) and temperature. The latter may be by means of a contact probe (thermistor) or non-contact infrared thermal sensor (infrared thermometer).
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- An output for audio/visual/tactile feedback
The Corscience GmbH & Co. KG EEG NeuroAmp is a biofeedback device intended for biofeedback and relaxation purposes.
Here's an analysis based on the provided document:
1. Table of Acceptance Criteria and Reported Device Performance:
The document primarily focuses on demonstrating substantial equivalence to predicate devices and compliance with relevant standards. It does not explicitly define "acceptance criteria" in terms of specific performance metrics for the overall device's therapeutic effectiveness (e.g., a percentage reduction in a particular symptom). Instead, the acceptance is based on meeting safety and technical standards and demonstrating comparable performance to predicate devices for its intended use.
However, some technical specifications can be viewed as performance characteristics that were likely expected to meet certain thresholds or be comparable to predicate devices.
| Parameter | Acceptance Criteria (Implied by Predicate/Standards) | Reported Device Performance (EEG NeuroAmp) |
|---|---|---|
| Intended Use | Biofeedback and relaxation purposes. Must be used with computer and software. Data from 1-2 EEG channels and up to 3 peripheral physiology measures. For use by trained professionals in an office setting. Not for diagnostic purposes. | The EEG NeuroAmp is intended for biofeedback and relaxation purposes. To perform its intended function it must be used in combination with a computer and appropriate software (Cygnet). For purposes of this training task, information for feedback may be derived from one or two channels of EEG and from as many as three channels of peripheral physiology measures such as are conventionally used in biofeedback. The EEG NeuroAmp is intended to be used in the office by trained professionals who can ensure sound handling practices. The EEG NeuroAmp is not intended for diagnostic purposes. |
| Power Supply | Acceptable and safe power source. | Power supply via USB port (galvanic isolation according to IEC 60601-1). |
| Software | Functional and appropriate for biofeedback. | Cygnet |
| No. of Input Channels | Comparable to predicate devices (BrainMaster had 2, ProComp had 8). | 5 |
| No. of Output Channels | Comparable to predicate devices (Predicates had 0). | 1 |
| ADC Resolution | Comparable to predicate devices (BrainMaster 8 bit, ProComp 14 bit). | 13 bit |
| Anti-aliasing Filter | Present for effective signal processing. | 5th order Butterworth |
| DC Gain Accuracy | Comparable to predicate devices (BrainMaster ±5%, ProComp ±0.5%). | ±1% |
| DC Offset | Comparable to predicate devices (BrainMaster +4 LSB, ProComp +3 LSB). | +1 LSB |
| Bandwidth (3dB) & Sample Rate | Appropriate for EEG and peripheral biofeedback. | EEG amplifier (2 channels): 0.08 Hz (1st order roll-off) ...70 (5th order roll-off). Sample rate for 50Hz line: 1000 sps. Sample rate for 60Hz line: 960 sps. Subsample rate = sample rate / 4 (250/240). Peripheral Amplifier (3 channels): DC ... 10Hz. Same sampling rate scheme. |
| Full-scale Input Range, DC | Appropriate for biofeedback signals. | ± 250 mV |
| Overvoltage Warning | Desirable for safety (ProComp/BrainMaster lacked this). | Yes |
| Impedance Measurement | Ability to check electrode contact quality. | Both channels simultaneously; displayed by colored LED bars on device. Needs to be engaged explicitly, disabled during EEG neurofeedback. |
| CMRR - EEG sensor only | High common-mode rejection for signal quality (>100 dB for BrainMaster, >130 dB for ProComp). | >130 dB |
| Temperature Range (pIRx3 accessory) | Suitable for forehead temperature measurement. | 29°C - 43°C or 84°F - 109°F |
| Accuracy (pIRx3 accessory) | Accurate enough for biofeedback (ProComp ±1.0°C). | < 1°K |
| Safety and EMC (Electrical Medical Safety) | Compliance with IEC 60601-1 and IEC 60601-1-2. | Full compliance demonstrated by accredited laboratories. Galvanically isolated from computer by medical grade isolating transformer. |
| Software Validation | Validated for intended function. | Tested as described in section 16 "Software" (details not provided in the excerpt). |
| Biocompatibility | Compliance with ISO 10993-1 for patient-contacting parts. | Housing material passed all tests for ISO 10993-1. Elastic belt: conforms to German "Oko-Tex-Standard," passed dermal irritation and sensitization tests, but did not pass cytotoxicity due to cotton material and is suitable for use on intact skin only (implies an acceptance of this limitation). |
Study Proving Acceptance Criteria are Met:
The document describes a series of tests and comparisons to predicate devices to demonstrate substantial equivalence and safety rather than a single "study" proving therapeutic effectiveness against pre-defined clinical acceptance criteria.
The primary "study" or demonstration of meeting acceptance criteria consists of:
- Bench Testing and Compliance with Standards: The EEG NeuroAmp and its accessory were tested according to international standards for electrical medical devices and biocompatibility.
- Comparison to Predicate Devices: A detailed comparison table (Section 5.12) is provided, highlighting the similarities in intended use and technical specifications, and justifying any differences.
2. Sample Size Used for the Test Set and Data Provenance:
- Test Set Sample Size: The document does not refer to a "test set" in the context of patient data or clinical outcomes. The testing primarily involved bench testing of the device's hardware and software against technical specifications and safety standards. There is no indication of patient data being used for device performance evaluation.
- Data Provenance: Not applicable, as there is no patient data described as part of the performance evaluation. The data provenance described relates to manufacturing standards and regulatory compliance.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications:
- Ground Truth Experts: Not applicable in the context of clinical ground truth. The "ground truth" for the device's acceptable performance was established by its compliance with recognized international standards (IEC 60601-1, IEC 60601-1-2, ISO 10993-1) and comparison to the technical specifications of legally marketed predicate devices. The experts involved would be engineers and testing personnel at accredited laboratories. Their qualifications are implicitly that they are subject matter experts in the respective testing domains (e.g., electrical safety, EMC, biocompatibility).
4. Adjudication Method for the Test Set:
- Adjudication Method: Not applicable. There was no clinical data requiring expert adjudication. Device performance was assessed against technical specifications and regulatory 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:
- MRMC Study: No. This device is a biofeedback device, not an AI-powered diagnostic or assistive tool for human readers. No MRMC comparative effectiveness study was conducted.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- Standalone Performance: Not applicable in the context of an algorithm's diagnostic performance. The device's "standalone" performance refers to its ability to accurately measure and process physiological signals according to its technical specifications, which was assessed through bench testing and compliance with standards. The device itself is an interface and amplifier, and its function is to provide accurate data to the clinician's software, which is then used in a human-in-the-loop biofeedback process.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- Type of Ground Truth: The ground truth used was technical specifications, international safety standards, and performance characteristics of legally marketed predicate devices. For example, a specified gain accuracy of ±1% or a CMRR of >130 dB would be the "ground truth" to which the device's measured performance was compared during testing.
8. The sample size for the training set:
- Training Set Sample Size: Not applicable. This device is a hardware biofeedback system, not an AI/ML algorithm that requires a training set of data.
9. How the ground truth for the training set was established:
- Ground Truth for Training Set: Not applicable. As there is no AI/ML algorithm involved, there is no training set or ground truth for such a set.
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