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510(k) Data Aggregation

    K Number
    K112319
    Date Cleared
    2012-01-27

    (169 days)

    Product Code
    Regulation Number
    882.1320
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    ELECTRO-CAP SYSTEM

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

    The Electro-Cap System is intended for use in routine clinical and research settings where rapid placement of a number of EEG electrodes is desired.

    Device Description

    The Electro-Cap System is an EEG electrode positioning system used to quickly place the standard 20 EEG electrodes and also a large number of electrodes in a uniform and consistent manner on the head and body in order to transmit electrophysiological signals from an individual to data collection devices. The Electro-Cap is made from a spandex type material with recessed electrodes in plastic mounts attached to the cap. The standard cap covers the entire scalp and is held in place with chin straps, or with cap straps attached to a body harness. The Surgical Cap material is cut slightly different to allow the cap to fit securely over the ears to hold it in place. The spandex type material holds the electrodes securely in position during an EEG recording. Wires are attached to each electrode and exit the cap to form a cable, which is used to connect the cap to the EEG equipment, either through an adapter cable, or in some instances, directly to the equipment with the connector on the cap. The electrical activity of the brain is transferred through the Electro-Gel to the recessed electrode and then to the EEG or computer equipment for evaluation.

    AI/ML Overview

    The Electro-Cap System is a device designed for rapid placement of EEG electrodes. The provided 510(k) summary (K112319) indicates that the device is substantially equivalent to its predicate devices, rather than performing a specific study to prove it meets acceptance criteria with quantifiable metrics. The substantial equivalence argument relies on comparing the device's technological characteristics, indications for use, and performance requirements to those of existing legally marketed predicate devices.

    Here's an breakdown of the information requested, based on the provided document:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly define "acceptance criteria" in the format of pass/fail metrics. Instead, it compares the proposed device's characteristics and performance requirements to those of predicate devices to establish substantial equivalence. The key performance requirement is the ability to transmit electrophysiological signals with a maximum impedance of 5K/Ohms.

    Feature / Performance RequirementAcceptance Criteria (Implied by Predicate Devices)Reported Device Performance (Electro-Cap System K112319)
    Indication for UseIntended for use in routine clinical settings where rapid placement of a number of EEG electrodes is desired.The Electro-Cap is intended for use in routine clinical settings where rapid placement of a number of EEG electrodes is desired. (Later updated to "routine clinical and research settings")
    Environment of UseElectrophysiologicalElectrophysiological
    Intended UserNeurologistsNeurologists
    Target PatientAdults and ChildrenAdults and Children
    Where UsedOn the headOn the head
    Number of Contacts1 to 256 electrodes (range among predicates)2 - 256
    Size of CapsVarious- babies to Large (25 cm to 65 cm range among predicates)Various- babies to Large (26 cm to 66 cm)
    Performance (Signal Transmission)Needs to transmit electrophysiological signals from an individual to data collection devices with a maximum impedance of 5K/Ohms. Does not transmit electrical current, nor are they intended to be used for stimulation.Needs to transmit electrophysiological signals from an individual to data collection devices with a maximum impedance of 5K/Ohms. Does not transmit electrical current, nor are they intended to be used for stimulation. (Stated as conforming to predicate requirements)
    Biocompatibility TestingNo biocompatibility testing conducted by most predicates.None was conducted.
    Conformity to Standards/SpecificationsAAMI Standards Specifications for ECG Cables and Lead-Wires and Other Devices that use Patient Cables, EC53-1995, and the IEC Standard 60601-1 Subclause 56.3, (c).In conformance with AAMI Standards Specifications for ECG Cables and Lead-Wires and Other Devices that use Patient Cables, EC53-1995, and the IEC Standard 60601-1 Subclause 56.3, (c).

    Note: The document focuses on demonstrating that the new device shares fundamental technological characteristics and performance requirements with devices already on the market, implying that these established characteristics represent the "acceptance criteria" for this type of device. No specific clinical trial or performance study comparing the device against a quantitative acceptance threshold is presented.

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

    Not applicable. The document describes a comparison to predicate devices to demonstrate substantial equivalence, rather than a clinical performance study with a dedicated test set. Therefore, there is no sample size for a test set or data provenance in the context of an evaluative study.

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

    Not applicable. As no clinical performance study with a test set was conducted, there were no experts establishing ground truth for such a set. The "experts" involved are implicitly the regulatory bodies and the manufacturer's internal team who determined the device's characteristics and its equivalence to predicates.

    4. Adjudication Method for the Test Set

    Not applicable. No test set or an adjudication method for one is described.

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

    No. There is no mention of a Multi-Reader Multi-Case (MRMC) comparative effectiveness study, nor any evaluation of human reader improvement with or without AI assistance. This device is a physical EEG electrode positioning system, not an AI-powered diagnostic tool.

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

    Not applicable. The device is a physical medical device (EEG electrode positioning system), not an algorithm or AI. Therefore, a "standalone algorithm performance" study is not relevant.

    7. The Type of Ground Truth Used (Expert Consensus, Pathology, Outcomes Data, etc.)

    Not applicable. The "ground truth" in this context is the established functionality and safety of the predicate devices. The new device is deemed substantially equivalent because its fundamental design, intended use, and performance requirements align with these existing, approved devices. No new ground truth for a novel claim is being established beyond this equivalence.

    8. The Sample Size for the Training Set

    Not applicable. There is no mention of a "training set" as this device is a physical product and not an algorithm requiring training data.

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

    Not applicable. As there is no training set mentioned, the establishment of ground truth for it is not relevant.

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