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510(k) Data Aggregation

    K Number
    K193159
    Date Cleared
    2020-12-30

    (411 days)

    Product Code
    Regulation Number
    882.1400
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The EEG NeuroAmp II.5s is intended to acquire, display, store and archive the electroencephalographic (EEG) signals from a patient's brain obtained by placing two or more electrodes on the head. It must be used in combination with appropriate software and computer. The EEG NeuroAmp II.5s is also intended to be used to provide stimulation and recording of visual and auditory evoked response potentials with appropriate software, computer, and accessories.

    The EEG NeuroAmp II.5s can also be used for biofeedback and relaxation purposes of this training task, information for feedback may be derived from the electroencephalographic signals and from as many as eight channels of peripheral physiology measures such as are conventionally used in biofeedback.

    The EEG NeuroAmp II.5s is intended to be used only by trained professionals who can ensure sound handling practices. The device is intended for use in clinical environments (not surgical or emergency environments) as well as in medical and therapeutic practices. It can be used with patients of all ages but is not designed for fetal use.

    The device does not draw any diagnostic conclusion. Recorded data of electroencephalogram (EEG) signals or event related potentials (ERPs) need to be interpreted by a clinical expert. The results of such interpretation must be considered only in conjunction with other clinical findings.

    Device Description

    The EEG NeuroAmp II.5s is a user-friendly high-performance interface between client and clinician computer. It can be used in two different functionalities: In an EEG/ERP measurement and in an EEG biofeedback (neurofeedback) and/or peripheral biofeedback setting. The EEG NeuroAmp 11.5s device itself contains three function blocks:

      1. EEG amplifier, two channels, interface for 23- or 39-channel EEG recording front-end
      1. Impedance meter function
      1. peripheral channels for additional sensors, ERP synchronization and biofeedback

    Apart from the EEG-biofeedback functionality, together with the x23/x39 accessories, it is possible to utilize the equipment as an EEG/ERP measurement device. A 23- or 39-channel EEG can be measured with conventional EEG caps, which are not part of the device, according to the standard 10-20 system. The device does not draw any diagnostic conclusions and does not invite the clinician to do so. Recorded data of electroencephalogram (EEG) signals need to be interpreted by a clinical expert. The results of such interpretation must be considered in conjunction with other clinical findings to provide context. There is no therapeutic effect of the EEG NeuroAmp II.5s used in this setting.

    The NeuroAmp x23/x39 devices are a full 23-/39-channel digital EEG recording front-end with integrated impedance meter. They are an accessory to the EEG NeuroAmp 11.5s and work only in conjunction with it.

    AI/ML Overview

    The Corscience EEG NeuroAmp II.5s is an electroencephalograph device that functions for EEG/ERP measurement and biofeedback. The device received 510(k) clearance based on substantial equivalence to predicate devices, demonstrating its safety and effectiveness through performance testing against relevant IEC and ISO standards.

    Here's a breakdown of the requested information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria for the EEG NeuroAmp II.5s are implicitly defined by its performance against the specified technical requirements, which are shown to be equivalent or superior to predicate devices. The "Discussion on safety and effectiveness" column in the comparative table effectively serves as the acceptance criteria and performance review.

    SpecificationAcceptance Criteria (from predicate comparison)Reported Device Performance (EEG NeuroAmp II.5s)
    EEG/ERP Measurement Functionality
    Indications for Use (short version)Acquire, display, store, and archive electrical activity of a patient's brain (Mitsar EEG and Natus Brain Monitor also allow stimulation and recording of evoked response potentials).Acquire, display, store and archive the electroencephalographic (EEG) signals from a patient's brain obtained by placing two or more electrodes on the head incl. stimulation and recording of visual and auditory evoked response potentials.
    Common name, Product code, Regulation numberGWQ, 21 CFR 882.1400 (Mitsar EEG); GWQ & OLV, 21 CFR 882.1400 (Natus Brain Monitor)EEG/ERP measurement & biofeedback device, GWQ, GWE, GWJ, OLV & HCC, 21 CFR 882.1400, 21 CFR 882.5050, 21 CFR 882.1890 & 21 CFR 882.1900
    Power supplyPrimarily USB port for power, with galvanic isolation (for EEG NeuroAmp, presumed for Mitsar EEG).Power supply via USB port (galvanic isolation according to IEC 60601-1)
    SoftwareEEG Studio (Mitsar EEG); Natus NeuroWorks™/SleepWorks (Natus Brain Monitor)ERPrec
    Windows 10 and 7 compatibleWindows 7, perhaps also Windows 10 (Mitsar EEG); Yes (Natus Brain Monitor)Yes
    EEG channels21 + 4 active/reference pairs, one auxiliary channel (Mitsar EEG); 40 (Natus Brain Monitor)up to 41 plus 8 peripheral channels
    Resolution EEG channels16 bit (Mitsar EEG); 24 bit (16 bit stored) (Natus Brain Monitor)24 bit, stored loss-free 24bit and full sampling rate
    Sampling frequency500 Hz per channel, multiplexed (Mitsar EEG); 256, 512, 1024, 2048, 4096 (Natus Brain Monitor)1Msample/second gross sampling rate, down sampled to 250 or 500 sps. synchronous sampling over all EEG- and peripheral channels
    Common-Mode Rejection Ratio (CMRR)at least 100 dB at 10 Hz (Mitsar EEG); >106db@60Hz (Natus Brain Monitor)>130 dB
    Notch filter-30 dB at 50(60) Hz (Mitsar EEG); No data (Natus Brain Monitor)<-60 dB at 50 or 60 Hz,optional setting in software. Recording always unfiltered raw signal.
    Input impedance EEG channels> 200 MΩ (Mitsar EEG); >1000 MOhm (Natus Brain Monitor)>1000 MOhm
    Bandwidth (3dB) and sample rate0.16 – 70 Hz (Mitsar EEG); 0.1 Hz – 100 Hz (Natus Brain Monitor)DC ... 100Hz/160Hz
    Impedance measurement EEG electrodes (electrode contact quality)Yes, 5kΩ – 40kΩ (Mitsar EEG); Yes, 2.5kΩ, 5kΩ, 10kΩ, 25kΩ (Natus Brain Monitor)Yes, 0 ... 140kΩ
    Input Noise< 1.5 µV peak to peak (Mitsar EEG); ≤ 2 uV pk-to-pk (0.1Hz to 100 Hz) (Natus Brain Monitor)< 0.01µV/√Hz; < 1.0 µV peak toPeak
    Overvoltage warningNo data (Mitsar EEG and Natus Brain Monitor)yes
    Input signal range10 - 5000 µV (Mitsar EEG); 20mV pk-to-pk, +/- 0.3VDC (Natus Brain Monitor)1100mVp-p
    Maximum Operational DC input voltage electrode offset±350 mV (Offset tolerance) (Mitsar EEG); ±300mV (Natus Brain Monitor)±550mV
    ERP measurement: synchronization mechanism and precision in msEvent button, No active synchronization, Accuracy/jitter: ±10ms/<20ms (Mitsar EEG); Integrated 8-bit trigger, Accuracy/jitter: ±10ms/<20ms (Natus Brain Monitor)Active audio and video synchronization with Sync device; Event button, 24 bit trigger.. Accuracy/jitter: ±1ms/<1ms
    Visual and auditory stimuli for ERP measurementStimulus presentation software incorporated, Audio and video sensors for initial calibration (Mitsar EEG); No data (Natus Brain Monitor)Stimulus presentation software incorporated in software ERPrec Audio and video sensors for continuous calibration and selftest of the system initial to each recording.
    Measurement of physiological dataMulti-purpose inputs for peripheral biosignal acquisition (Mitsar EEG); SpO2 Pulse Rate, Plethysmogram, PPG (Natus Brain Monitor)Combination sensor, applied to the finger, for heart rate and galvanic skin response (GSR). Skin temperature of the finger can be measured, not absolute values, only trends. No therapeutic effect of sensor.
    Video recordingPossible (Mitsar EEG and Natus Brain Monitor)Possible
    EEG-Biofeedback (Neurofeedback) Functionality
    Indications for UseBiofeedback and relaxation purposes (EEG NeuroAmp)Biofeedback and relaxation purposes
    Common name, Product code, Regulation numberBiofeedback device, HCC, 21 CFR 882.5050 (EEG NeuroAmp)EEG/ERP measurement & biofeedback device, GWQ, GWE, GWJ, OLV & HCC, 21 CFR 882.1400, 21 CFR 882.5050, 21 CFR 882.1890 & 21 CFR 882.1900
    Power supplyPower supply via USB port (galvanic isolation according to IEC 60601-1) (EEG NeuroAmp)Power supply via USB port (galvanic isolation according to IEC 60601-1)
    SoftwareCygnet, BEE Lab (EEG NeuroAmp)Cygnet, BEE Lab
    Windows 10 and 7 compatibleYes (EEG NeuroAmp)Yes
    x23/x39 EEG amplifier interfaceNo (EEG NeuroAmp)Yes
    No. peripheral channels inputs3 (EEG NeuroAmp)8
    No. peripheral channels outputs1 (EEG NeuroAmp)8
    EEG resolution13 bit (EEG NeuroAmp)32 bit
    Input noise< 1.5 µVp-p (EEG NeuroAmp)< 0.01 µV/ √Hz ; < 1.0 µVp-p
    Overvoltage warningYes (EEG NeuroAmp)yes
    EEG bandwidth0.056 ... 70Hz (EEG NeuroAmp)DC ... 100/160Hz
    Peripheral channel resolution13 bit (EEG NeuroAmp)24 bit
    Peripheral channel bandwidthDC ... 70Hz (EEG NeuroAmp)DC ... 100/160Hz

    2. Sample size used for the test set and data provenance

    The document does not describe a clinical study with a "test set" of patient data for the device to be evaluated. The performance testing conducted was:

    • Electrical Safety: Bench testing according to IEC 60601-1.
    • Electromagnetic Compatibility: Bench testing according to IEC 60601-1-2 and IEC 60601-2-26.
    • Performance Testing (Hardware): Bench testing in accordance with internal requirements and applicable clauses of IEC 62366-1, IEC 80601-2-26, and IEC 60601-2-40.

    The accessorizes were also tested to ISO 10993-1, IEC 60601-1 and IEC 60601-1-2.

    Therefore, there is no mention of sample size or data provenance in terms of patient data.

    3. Number of experts used to establish the ground truth for the test set and their qualifications

    This information is not applicable as there was no test set of patient data requiring expert ground truth establishment. The device capabilities were verified through technical bench testing against established engineering standards and specifications.

    4. Adjudication method for the test set

    This information is not applicable as there was no test set of patient data requiring adjudication.

    5. Multi-reader multi-case (MRMC) comparative effectiveness study

    No MRMC study was performed or described. The study focused on technical equivalence and performance against predicate devices and standards, not on human reader performance with or without AI assistance. The device does not draw any diagnostic conclusion and requires interpretation by a clinical expert.

    6. Standalone (i.e. algorithm only without human-in-the-loop performance) study

    No standalone performance study of an algorithm was conducted or described. The device is a hardware system for acquiring, displaying, storing, and archiving EEG signals, with capabilities for biofeedback and evoked response potentials. It's explicitly stated that the device "does not draw any diagnostic conclusion" and "Recorded data... need to be interpreted by a clinical expert."

    7. Type of ground truth used

    The "ground truth" for evaluating the EEG NeuroAmp II.5s was based on:

    • Adherence to international electrical safety and EMC standards (IEC 60601-1, IEC 60601-1-2, IEC 60601-2-26, ISO 10993-1 for accessories).
    • Compliance with device-specific performance standards for electroencephalographs and evoked response equipment (IEC 80601-2-26, IEC 60601-2-40).
    • Comparison of technical specifications against legally marketed predicate devices (Mitsar EEG K143233, Natus Brain Monitor K180290, EEG NeuroAmp K073557) to demonstrate substantial equivalence and often superior performance.

    8. Sample size for the training set

    This information is not applicable as the device is a medical measurement instrument and not an AI/ML algorithm that requires a training set of data.

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

    This information is not applicable as there was no training set of data.

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