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510(k) Data Aggregation
(172 days)
REMI Remote EEG Monitoring System
The REMI Remote EEG Monitoring System is indicated for use in healthcare settings where near real-time and/or remote EEG is warranted and in ambulatory settings where remote EEG is warranted. REMI System uses single patient, disposable, wearable sensors intended to amplify, capture, and wirelessly transmit a single channel of electrical activity of the brain for a duration up to 30 days.
REMI System uses the REMI Mobile software application that runs on qualified commercial off-the-shelf mobile computing platforms. REMI Mobile displays user setup information to trained medical professionals and provides notifications to medical professionals and ambulatory users. REMI Mobile receives and transmits data from connected REMI Sensors to the secure REMI Cloud where it is stored and prepared for review on qualified EEG viewing software.
REMI System does not make any diagnostic conclusion about the subject's condition and is intended as a physiological signal monitor. REMI System is indicated for use with adult and pediatric patients (1+ years).
The REMI System has three major components:
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- REMI Sensor A disposable EEG sensor which is placed on the patient's scalp using a conductive REMI Sticker
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- REMI Mobile A mobile medical application that is designed to run on a qualified commercial-off-the-shelf mobile computing platform (an Android tablet for use in healthcare settings, and a portable/wearable Android device (phone or smartwatch) for use in ambulatory settings), acquire EEG data transmitted from REMI Sensors and then transmit the EEG data and associated patient information via wireless encrypted transmission to.
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- REMI Cloud A HIPAA-compliant secure cloud storage and data processing platform where data is processed into a qualified EEG reviewing software format for neurological review.
The provided document is a 510(k) Pre-market Notification Summary for the REMI Remote EEG Monitoring System (K243185). This document details the device's characteristics, indications for use, and the studies conducted to demonstrate its substantial equivalence to a predicate device (REMI Remote EEG Monitoring System, K230933).
Based on the provided information, here's a description of the acceptance criteria and the study that proves the device meets them:
1. Table of Acceptance Criteria and Reported Device Performance
The document primarily relies on comparisons to its own predicate device (K230933) and general performance testing against recognized standards. Specific quantitative acceptance criteria are not explicitly detailed in a table format within this summary, but the general assertion is that the device met all predetermined acceptance criteria derived from the listed tests.
Test Type | Acceptance Criteria (Implicit) | Reported Device Performance |
---|---|---|
General Electrical Safety, EMC, and Ingress Protection | Compliance with relevant IEC standards (IEC 60601-1, IEC 60601-1-2, IEC 60601-2-26, IEC 60601-1-11). | Testing conducted to and met the requirements of the specified IEC standards. |
Wireless Technology Testing | Wireless connectivity can be initiated, is stable, and accurately transfers EEG signals. Connection maintained for a minimum of 48 continuous hours. | Wireless connectivity was tested (in accordance with IEC 60601-1-2 and IEC 60601-1-11 requirements) and demonstrated to initiate, maintain stability, and accurately transfer EEG signals. A wireless connection was confirmed to be maintained for a minimum of 48 continuous hours. |
Environmental/Shelf life | Device functions as intended after accelerated aging. | Accelerated aging and subsequent functional verification testing were performed. (Outcome states "met all predetermined acceptance criteria"). |
Packaging Performance | Device maintains integrity and function after ship testing. | Ship testing and subsequent functional verification testing were performed. (Outcome states "met all predetermined acceptance criteria"). |
Biocompatibility | Long-term contact with intact skin is safe (non-cytotoxic, non-sensitizing, non-irritating). | Biocompatibility testing for long-term contact with intact skin was performed per ISO-10993-1, ISO 10993-10, and ISO 10993-23 for all patient-contacting components. (Outcome states "safe and effective for its intended use" and "met all predetermined acceptance criteria"). |
Usability/Human Factors | Tasks associated with device use are safe and effective. | Human factors/usability testing was conducted to evaluate tasks associated with use of the device. (Outcome states "met all predetermined acceptance criteria"). |
Software Verification Testing | End-to-end functionality: Acquire EEG, transmit to mobile, transmit to cloud, viewable in qualified software. Essential performance met. | End-to-end testing confirmed: (1) REMI System acquires EEG signals from REMI Sensors and transmits to REMI Mobile software, (2) REMI Mobile transfers EEG data to REMI Cloud, and (3) final EEG file format within REMI Cloud is viewable in qualified EEG viewing software. This demonstrated that the REMI System meets its Essential Performance and fulfills system requirements. |
Clinical Performance (Extension to 1-6 years pediatric patients) | REMI System (including new hydrocolloid REMI Sticker) is safe and effective for monitoring EEG in pediatric patients aged 1 to |
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(89 days)
Remi Custom Night Guard
The Remi Night Guard is indicated for protection of teeth and restorations against grinding and clenching.
The Remi Custom Night Guard is a mouth guard used as a barrier between teeth for nighttime teeth grinding by creating physical separation between upper and lower tooth surfaces preventing tooth damage caused by bruxism (e.g., grinding and clenching).
This document is a 510(k) Premarket Notification from the FDA regarding a dental device called the "Remi Custom Night Guard." It states that the device is substantially equivalent to a legally marketed predicate device (LIJIA Night Guard), meaning a full clinical study with acceptance criteria and a detailed study report is not required.
Therefore, the document does not contain the information requested in the prompt regarding acceptance criteria and a study proving the device meets those criteria.
The document explicitly states:
- "no clinical studies were deemed necessary to demonstrate the safety and effectiveness of the subject device." (page 6)
Instead, the submission relies on:
- Comparison to a Predicate Device: The Remi Custom Night Guard is shown to have the same indications for use, product code, classification, anatomical sites, sterility, patient removability, and general technological features as the predicate LIJIA Night Guard (K241369).
- Non-Clinical Performance Testing:
- Durability testing: Completed, but no details on specific acceptance criteria or results are provided.
- Internal manufacturing validation: Performed to test the dimensional accuracy of the manufacturing process, but no specific acceptance criteria or results are provided.
- Biocompatibility testing: Performed in accordance with ISO 10993, with cytotoxicity testing completed. No specific acceptance criteria or results are provided beyond the statement that it was completed.
In summary, because this is a 510(k) submission based on substantial equivalence to a predicate device and explicitly states that no clinical studies were deemed necessary, the detailed information about acceptance criteria and a study to prove device performance (as requested in the prompt) is not present in this document.
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(229 days)
ReminGel
To relieve dental hypersensitivity caused by bleaching procedures, cold, heat, acids, or sweets.
ReminGel is a convenient, premixed, ready-to-use, opaque aqueous-based gel. ReminGel consists of suspended hydroxyapatite and calcium and phosphate salts that help restore a tooth's hydroxyapatite structure through remineralization. This remineralization results in tubule occlusion and blocks fluid flow in dentinal tubules, thereby relieving dentinal sensitivity. ReminGel blocks nerve excitability through potassium release. ReminGel is packaged in a 3oz (90mL) tube. ReminGel is for prescription use (Rx) and over-the-counter (OTC) use. ReminGel can be applied to teeth using dental appliances (e.g. fluoride tray, whitening tray, periotray, etc.) or via a toothbrush.
Here's a breakdown of the acceptance criteria and study information for ReminGel, based on the provided FDA 510(k) summary:
Acceptance Criteria and Reported Device Performance
Acceptance Criteria (Anticipated Performance) | Reported Device Performance (ReminGel) |
---|---|
Tubule Occlusion: Visibly occlude dentinal tubules to inhibit dentin sensitivity. | Visibly occluded dentinal tubules, demonstrating inhibition of dentin sensitivity. (Identical to predicate device Super Seal) |
Shelf-Life: Minimum of 2 years. | 2 years (determined through accelerated shelf-life testing; real-time aging ongoing). |
Transit Performance: Withstand simulated transit conditions. | Performed satisfactorily post-transit, confirming no negative effect on the product. |
Cytotoxicity: Demonstrate acceptable levels of biocompatibility. | Yielded better cytotoxicity results compared to the predicate device, SuperSeal. |
Irritation: Be a non-irritant. | Found to be a non-irritant. |
Sensitization: Be a non-sensitizing agent. | Found to be a non-sensitizing agent. |
Study Details
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Sample Size used for the test set and data provenance:
- Tubule Occlusion Testing: Resected human teeth were used. The exact sample size ("N") is not specified.
- Biocompatibility Testing (Cytotoxicity, Irritation, Sensitization): Not specified in terms of human subjects or teeth. These are in vitro and in vivo tests, typically performed on cell cultures or animal models for initial screening (as per ISO 10993 standards listed). The document does not provide details on the specific samples used for these tests.
- Shelf-Life Testing: Not specified.
- Transit Testing: Not specified.
- Data Provenance: Not explicitly stated, but based on the in vitro nature of the tubule occlusion study on "resected human teeth," it implies laboratory testing rather than a clinical trial in patients. The biocompatibility tests are also laboratory-based. It is retrospective in the sense that the results were gathered and submitted as part of the 510(k) submission, not a prospective clinical trial.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable/Not specified. The studies cited are non-clinical (laboratory/bench testing). For tubule occlusion, the "ground truth" would be the visible occlusion as observed through microscopy, which doesn't directly involve multiple expert adjudicators for "truth" establishment in the way clinical images would.
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Adjudication method for the test set:
- Not applicable. As the studies are non-clinical, there is no expert adjudication method like 2+1 or 3+1 typically used for clinical image interpretation.
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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:
- No MRMC study was conducted. This device (ReminGel) is a medical product (cavity varnish) and not an AI/software-as-a-medical-device that would typically involve human readers and AI assistance for interpretation.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This is not an algorithm or AI device.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- Tubule Occlusion: Visual observation of dentinal tubule occlusion (likely microscopic evaluation).
- Shelf-Life: Measured physical and chemical properties over time.
- Transit, Cytotoxicity, Irritation, Sensitization: Results from standardized laboratory test methods (e.g., ISO 10993 series).
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The sample size for the training set:
- Not applicable. This is a medical product, not a machine learning/AI model that requires a training set.
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How the ground truth for the training set was established:
- Not applicable, as there is no training set for this type of device.
Overall Context: The 510(k) summary focuses on demonstrating substantial equivalence to a predicate device (Super Seal) and a reference device (Senzzzz Away) through non-clinical performance and biocompatibility testing, rather than extensive clinical efficacy trials. Clinical performance was explicitly "not deemed necessary" for this submission, likely due to the established mechanism of action and similarity to legally marketed devices.
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(251 days)
REMI-AI Rapid Detection Module (REMI-AI RDM)
The REMI-AI Rapid Detection Module (REMI-AI RDM) is a seizure detection module which is integrated into the REMI Remote EEG Monitoring System and is only indicated for use within non-ICU (Intensive Care Unit) healthcare settings. REMI-AI RDM has not been validated for and is not indicated for detection of electrographic status epilepticus.
REMI-AI RDM conducts automated analysis of REMI EEG data in near real-time and provides notifications of potential electrographic seizures (events) through the REMI System when seizure prevalence of 10% or greater (indicating seizure activity of at least 30 seconds within a 5-minute rolling window) is detected. When seizure prevalence is displayed, the notification also displays the corresponding event detection confidence. Notifications are intended to be used by qualified clinicians who will exercise professional judgment in their application. Detected events are also annotated in the associated REMI EEG record as an aide to the qualified physician's REMI EEG review.
Delays of up to several minutes may occur between the detection of an event and the generation of an event notification, and are thus not a substitute for real-time monitoring. REMI-AI RDM does not make any diagnostic conclusion about the subject's condition and is intended as a physiological signal monitor. REMI-AI RDM is indicated for use with adult and pediatric patients (6+ years).
REMI-AI RDM conducts automated analysis of EEG data collected by the REMI System in near real-time. REMI-AI RDM provides notifications of the prevalence and confidence of potential electrographic seizures, having a combined prevalence of 10% or greater, which correlates with a duration of at least 30 seconds of activity within a rolling 5 minute window of EEG.
REMI-AI RDM notifications are presented through the REMI Mobile software application, and are intended to be used by qualified clinicians who will exercise professional judgment in their interpretation. Notifications include the prevalence and confidence value for the event and are marked in the associated EEG record in order to assist qualified clinicians in their assessment.
REMI-AI RDM notifications identify when a section of EEG is consistent with seizure characteristics it has been trained to recognize. When a notification is presented, clinical context and facility procedures should inform next steps in patient evaluation and management. REMI-AI RDM does not make any treatment or management recommendations.
Here's a summary of the acceptance criteria and study details for the REMI-AI Rapid Detection Module (REMI-AI RDM), based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria | Target | Reported Device Performance |
---|---|---|
Event-Level Sensitivity | > 70% | > 70% (95% Cl lower bound of 78.9%) |
False Alarm Rate (FAR) |
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(201 days)
REMI AI Discrete Detection Module
The REMI-AI Discrete Detection Module (REMI-AI DDM) is indicated for the analysis of REMI Remote EEG Monitoring System electroencephalogram (EEG) recordings. REMI-AI DDM is intended to be used by physicians qualified to analyze and interpret EEG who will exercise professional judgment in using the information.
As an aide to the qualified physician's REMI EEG review, REMI-AI DDM marks previously acquired sections of REMI EEG that may correspond to neurological events of interest indicative of potential electrographic seizures lasting at least 10 seconds in duration. REMI-AI DDM is indicated for use with adult and pediatric patients (6+ years).
REMI-AI DDM does not mark REMI EEG records in real time and does not provide any diagnostic conclusion about the patient's condition to the user.
REMI-Al Discrete Detection Module (REMI-AI DDM) is a software as a medical device (SaMD) that automatically identifies and annotates discrete seizure-like events in previously acquired electroencephalography (EEG) traces to aid a qualified physician in their review of REMI EEG records. REMI-AI DDM analyzes previously acquired EEG data from 4-channel recordings obtained from bilateral, bipolar scalp EEG recordings at both the frontal and temporoparietal regions, collected and stored by the REMI Remote EEG Monitoring System. REMI-AI DDM analyzes EEG recordings and detects regions of the data that may correspond to electrographic seizures lasting at least 10 seconds in duration. These regions are annotated in the REMI EEG file as discrete events and are provided to assist in REMI EEG review.
Here's an analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text:
Acceptance Criteria and Device Performance
Acceptance Criteria | Reported Device Performance |
---|---|
Event-Level Sensitivity > 70% | 86.2% (with a calculated 95% CI lower bound of 79.5%) Across all 31 patients with seizures. |
Pediatric (6-21 years): 83.0% (95% CI: 73.1, 93.3) | |
Adult (22+ years): 90.0% (95% CI: 81.5, 100.0) | |
EMU: 87.5% (95% CI: 80.0, 94.4) | |
Ambulatory: 80.0% (95% CI: 71.0, 100.0) | |
False Alarm Rate (FAR) 70% | 92.2% (with a 95% CI Lower Bound of 86.5%). |
Pediatric (6-21 years): 87.8% (95% CI: 77.0, 97.0) | |
Adult (22+ years): 95.5% (95% CI: 90.0, 100.0) | |
EMU: 92.2% (95% CI: 85.9, 97.3) | |
Ambulatory: 92.5% (95% CI: 77.5, 100.0) | |
Mean Per-Patient FAR |
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(88 days)
REMI Remote EEG Monitoring System
The REMI Remote EEG Monitoring System is indicated for use in healthcare settings where near real-time and/or remote EEG is warranted and in ambulatory settings where remote EEG is warranted. REMI uses single patient, disposable, wearable sensors intended to amplify, capture, and wirelessly transmit a single channel of electrical activity of the brain for a duration up to 30 days.
The REMI System uses the REMI-Mobile software application that runs on qualified portable general purpose computing platforms. REMI-Mobile displays user setup information to trained medical professionals and provides notifications to medical professionals and ambulatory users. REMI-Mobile receives and transmits data from connected REMI Sensors to the secure REMI-Cloud where it is stored and prepared for review on qualified EEG viewing software.
REMI does not make any diagnostic conclusion about the subject's condition and is intended as a physiological signal monitor. The REMI System is indicated for use with adult and pediatric patients (6+ years).
The REMI System has three major components:
- REMI Sensor A disposable EEG sensor which is placed on the patient's scalp using a conductive REMI Sticker
- REMI Mobile A mobile medical application that is designed to run on a qualified commercial-off-the-shelf mobile computing platform (an Android tablet for use in healthcare settings, and a portable/wearable Android smartwatch for use in ambulatory settings), acquire EEG data transmitted from REMI Sensors and then transmit the EEG data and associated patient information via wireless encrypted transmission to,
- REMI Cloud A HIPAA-compliant secure cloud storage and data processing platform where data is processed into a qualified EEG reviewing software format for neurological review.
This 510(k) submission includes the addition of the Android smartwatch for ambulatory use and increases the duration of monitoring to up to 30 days.
The provided text describes the REMI Remote EEG Monitoring System and its substantial equivalence to a predicate device. However, it does not include specific quantitative acceptance criteria or detailed study results that would typically be associated with performance metrics like sensitivity, specificity, accuracy, or effect sizes for AI assistance. The document focuses on demonstrating substantial equivalence through testing of electrical safety, wireless technology, software, and human factors.
Here's an attempt to answer your questions based on the available information, with acknowledgements where information is missing.
1. A table of acceptance criteria and the reported device performance
Based on the provided text, the acceptance criteria are generally framed around meeting regulatory standards and functional requirements rather than quantitative performance metrics for diagnostic accuracy.
Acceptance Criteria Category | Reported Device Performance |
---|---|
Electrical Safety / EMC / Ingress Protection | Met all relevant standards: IEC 60601-1, IEC 60601-1-2, IEC 60601-2-26, IEC 60601-1-11:2015 /A1:2021. |
Wireless Technology Functionality | - Wireless connections can be initiated, are stable, and accurately transfer EEG signals. |
- Wireless connection maintained for a minimum of 48 continuous hours. |
| Environmental/Shelf life | Accelerated aging and subsequent functional verification testing conducted. (No specific performance metrics are given, but implies successful completion). |
| Packaging Performance | Ship testing and subsequent functional verification testing conducted. (No specific performance metrics are given, but implies successful completion). |
| Biocompatibility | Patient-contacting components verified with Irritation, Sensitization, and Cytotoxicity testing per ISO 10993-5:2009 and ISO 10993-10:2010 for a prolonged time period. (Identical to predicate device). |
| Usability/ Human Factors | Evaluated tasks associated with use of the device. (Implies successful evaluation, no specific outcomes provided). |
| Software Functionality | Updated REMI Mobile software successfully supports portable/wearable ambulatory use by initiating sessions from a primary computing platform (Android tablet) to a portable/wearable computing platform (Wear OS smartwatch). |
| Bench Testing (End-to-End System Performance) | - Able to acquire EEG signals using REMI Sensors and transmit to REMI Mobile software. - REMI Mobile able to transfer EEG data to REMI Cloud.
- Final EEG file format within REMI Cloud is viewable in qualified EEG viewing software.
- System meets its Essential Performance (record digitized EEG data with patient-applied sensors, transfer wirelessly to cloud-based archive) and fulfills system requirements. |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
The document does not specify sample sizes for any of the described tests. It mentions "testing conducted," "accelerated aging," "ship testing," and "human factors/usability testing," but provides no details on the number of units, subjects, or data points involved. Similarly, data provenance (country of origin, retrospective/prospective) is not mentioned.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
The document does not describe any study establishing ground truth with expert review for a diagnostic purpose. The device is explicitly stated to "not make any diagnostic conclusion" and is "intended as a physiological signal monitor." Therefore, this question is not applicable in the context of the provided information.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Since no expert-based ground truth establishment or diagnostic performance evaluation is detailed, there is no mention of an adjudication method.
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
No MRMC study is mentioned. The device is a physiological signal monitor and does not involve AI assistance for human readers in a diagnostic context.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
The device itself is a system for acquiring and transmitting EEG data for review by medical professionals on qualified EEG viewing software. It does not perform standalone diagnostic algorithms. Its "Essential Performance" is to record digitized EEG data and transfer it.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
Given that the device is a physiological signal monitor and "does not make any diagnostic conclusion," the concept of "ground truth" as typically used for diagnostic or screening devices (e.g., pathology, expert consensus on a disease state) is not applicable here. The ground truth for its performance would be the accuracy of EEG signal acquisition and transmission, which is assessed through bench testing and compliance with electrical standards.
8. The sample size for the training set
The document does not describe any machine learning or AI-based component that would require a "training set." The software updates mentioned are for supporting new hardware (smartwatch) and extending monitoring duration, not for developing new diagnostic algorithms.
9. How the ground truth for the training set was established
Not applicable, as no training set for an AI/ML algorithm is described.
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(131 days)
Remi Robotic Navigation System
The Remi Robotic Navigation System is intended for use as an aid for precisely locating anatomical structures and for the spatial positioning and orientation of a tool holder or guide tube to be used by surgeons for navigating and/or guiding compatible surgical instruments in open or percutaneous spinal procedures in reference to rigid patient anatomy and fiducials that can be identified on a 3D imaging scan or 2D fluoroscopic images. The Remi Robotic Navigation System is indicated for assisting the surgeon in placing pedicle screws in the posterior lumbar region (L1-S1). The system is designed for lumbar pedicle screw placement with the prone position and is compatible with the Accelus LineSider Spinal System.
The Remi Robotic Navigation System (Remi) is an image guided system primarily comprised of a computer workstation, software, a trajectory system, including a targeting platform, a camera, and various image guided instruments intended for assisting the surgeon in placing screws in the pedicles of the lumbar spine. The system operates in a similar manner to other optical-based image y systems.
The provided text describes a 510(k) premarket notification for the Remi Robotic Navigation System (K223350). The submission focuses on demonstrating substantial equivalence to its predicate devices, particularly an earlier version of the Remi Robotic Navigation System (K223070) and the EXCELSIUS GPS (K171651). The key change in the subject device is the addition of compatibility with 2D fluoroscopic imaging systems for pedicle screw placement in the posterior lumbar region (L1-S1).
Here's a breakdown of the requested information based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly present a table of acceptance criteria with corresponding performance metrics for the tested device. It broadly states that "The testing shows that the use of the 2D fluoroscopic images with the Remi system is equivalent to the use of the validated 3D imaging systems." and that the device "continues to meet design requirements, is as safe and effective as the predicate device, and performs according to its intended use."
However, the "POSITIONING ACCURACY (BENCH)" for the Primary Predicate Device is listed as: 0.74 ± 0.36 mm (worst case); 95% CI: 1.46mm (worst case). Since the subject device "Same as Primary Predicate" for this characteristic and the testing was done to demonstrate equivalence, it can be inferred that the acceptance criterion for accuracy for the new functionality is to maintain this level of accuracy or be equivalent to it.
Acceptance Criterion (Inferred from Predicate) | Reported Device Performance (Equivalent to Predicate) |
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Positioning Accuracy: ≤ 0.74 ± 0.36 mm (worst case), 95% CI: 1.46mm (worst case) | Maintained (Stated as "Same as Primary Predicate" and "equivalent to the use of the validated 3D imaging systems") |
Software System Functionality | Met (Software System Test performed) |
Navigation Accuracy | Verified (Navigation Accuracy Verification performed) |
System Accuracy | Validated (System Accuracy Validation performed) |
ASTM F2554 Compliance | Met (ASTM F2554 Accuracy Test performed) |
Software Unit and Integration | Met (Software Unit and Integration Tests performed) |
2. Sample Size Used for the Test Set and Data Provenance
The document mentions "Performance Testing - Bench" was conducted, including "Navigation Accuracy Verification," "System Accuracy Validation," "Software System Test," "ASTM F2554 Accuracy Test," and "Software Unit and Integration Tests." However, specific sample sizes for these tests (e.g., number of cases, images, or measurements) are not provided.
The data provenance is not explicitly stated in terms of country of origin or whether it was retrospective or prospective. Given that it is bench testing, it is likely that the data was generated in a controlled laboratory or testing environment rather than being derived from patient cases.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications
This information is not provided. The document describes bench testing, which typically uses defined physical standards or simulated scenarios to establish ground truth rather than expert consensus on clinical images/data.
4. Adjudication Method for the Test Set
This information is not provided. Adjudication methods (like 2+1, 3+1) are typically used in studies involving human interpretation of clinical data and subsequent consensus determination. Since the testing described is bench testing, such an adjudication method is unlikely to apply.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No MRMC comparative effectiveness study is mentioned. The submission focuses on demonstrating substantial equivalence through bench testing, verifying that the added 2D fluoroscopy functionality maintains the device's accuracy and safety profiles compared to its predicate with 3D imaging. There is no information regarding human readers improving with or without AI assistance.
6. Standalone Performance Study
Yes, a standalone (algorithm only) performance study was done. The performance testing described (Navigation Accuracy Verification, System Accuracy Validation, Software System Test, ASTM F2554 Accuracy Test, Software Unit and Integration Tests) are all characteristics of a standalone performance evaluation, focusing on the device's technical capabilities without human interaction determining performance outcomes within the tests themselves. The stated purpose was "to demonstrate that the updated requirement for this change was met and to ensure the risk profile of Remi was maintained," specifically concerning "the use of the 2D fluoroscopic images with the Remi system is equivalent to the use of the validated 3D imaging systems."
7. Type of Ground Truth Used
The ground truth for the bench testing would likely involve engineered physical phantoms, precisely manufactured test fixtures, and controlled experimental setups with known geometric parameters and validated measurements. For example, for "Navigation Accuracy Verification" and "System Accuracy Validation," physical measurements against a known standard or calibrated instruments would establish the ground truth. For "Software System Test" and "Software Unit and Integration Tests," the ground truth would be defined by the software's specified functional requirements and expected outputs.
8. Sample Size for the Training Set
The document does not provide information about a training set or its sample size. The submission is for a modification to an existing cleared device, specifically adding 2D fluoroscopic image compatibility. While the software was updated to support this, including an algorithm correcting distortion, the text implies that the evaluation focused on the performance of the system with the new capability rather than the development of a completely new AI algorithm requiring extensive training data. If machine learning was used for the distortion correction, details about its training would typically be in a separate section not provided here.
9. How the Ground Truth for the Training Set Was Established
As no training set is explicitly mentioned, this information is not provided.
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(28 days)
Remi Robotic Navigation System
The REMI™ Robotic Navigation System is intended for use as an aid for precisely locating anatomical structures and for the spatial positioning and orientation of a tool holder or guide tube to be used by surgeons for navigating and/or guiding compatible surgical instruments in open or percutaneous spinal procedures in reference to rigid patient anatomy and fiducials that can be identified on a 3D imaging scan. The REMI™ Robotic Navigation System is indicated for assisting the surgeon in placing pedicle screws in the posterior lumbar region (LI-S1). The system is designed for lumbar pedicle screw placement with the prone position and is compatible with the Accelus LineSider® Spinal System.
The Remi Robotic Navigation System (Remi) is an image guided system primarily comprised of a computer workstation, software, a trajectory system, including a targeting platform, a camera, and various image guided instruments intended for assisting the surgeon in placing screws in the pedicles of the lumbar spine. The system operates in a similar manner to other optical-based image y systems.
The provided text outlines the FDA 510(k) clearance for the REMI Robotic Navigation System, focusing on its substantial equivalence to a predicate device. However, it does not contain a detailed study report or explicit acceptance criteria with reported device performance metrics in the format requested.
The document primarily focuses on demonstrating that the updated REMI system, with additional compatible 3D imaging systems, is substantially equivalent to its predicate. The "Performance Testing - Bench" section mentions tests conducted but does not provide specific numerical acceptance criteria or performance results.
Therefore, much of the requested information cannot be extracted directly from the provided text. I will indicate where information is missing or inferred.
Acceptance Criteria and Device Performance
Acceptance Criteria | Reported Device Performance |
---|---|
Accuracy (Bench) - Worst Case | 0.74 ± 0.36 mm |
(95% CI: 1.46mm) - This is the reported performance of the predicate device, which the subject device is stated to be "Same as Predicate." | |
Image Quality (with added 3D imagers) | Stated to be "equivalent" to the predicate's performance with the Medtronic O-arm. (No specific metric provided) |
Image Transfer Speed (with added 3D imagers) | Stated to be "equivalent" to the predicate's performance with the Medtronic O-arm. (No specific metric provided) |
Image Registration Speed (with added 3D imagers) | Stated to be "equivalent" to the predicate's performance with the Medtronic O-arm. (No specific metric provided) |
Registration Accuracy (with added 3D imagers) | Stated to be "equivalent" to the predicate's performance with the Medtronic O-arm. (No specific metric provided) |
Usability Validation | Testing was done to ensure the risk profile was maintained. (No specific metric or outcome provided) |
Compatibility with PSIS Pins | Biocompatibility assessment for Ti6Al4V ELI (used in PSIS pins) included in K190360 (referring to a previous clearance for the pedicle screws). |
Robot collision avoidance/detection | Manual movement of Trajectory Platform to gross location. Small fine tuning of Trajectory Platform location is automatic but is current limited to cease when platform encounters a force greater than 9lbs. (This is for the predicate, and again, the subject device is "Same as Predicate.") |
Study Details from the provided text:
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Sample size used for the test set and the data provenance:
- The document mentions "Performance Testing - Bench" and "Verification and validation testing" but does not specify the sample size for any test set or the data provenance (e.g., country of origin, retrospective/prospective). It suggests bench testing was primarily used for equivalence.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- No information provided. The "performance testing" described appears to be technical validation against specified equivalence factors rather than expert review of clinical outcomes or images.
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Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- No information provided.
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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:
- No, an MRMC study was not described. This device is a robotic navigation system for spinal surgery, not an AI-assisted diagnostic imaging interpretation tool that would typically involve human readers. Its purpose is to aid surgeons in pedicle screw placement.
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If a standalone (i.e. algorithm only without human-in-the loop performance) was done:
- The document does not explicitly describe a "standalone" algorithmic performance test in the context of an AI-only system. The device is a navigation system that guides a human surgeon. Its performance metrics, like accuracy, are inherently tied to the system's ability to guide to a planned trajectory, which can be measured quantitatively in bench tests. The bench testing mentioned covers aspects like "Accuracy," "Image Quality," "Image Transfer Speed," and "Image Registration Speed."
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- Based on the description of "Performance Testing - Bench" and "Accuracy verification on anatomical landmarks" (for the predicate), the ground truth for accuracy testing would typically involve precisely measured physical points or targets on a phantom or model, measured by a highly accurate reference system (e.g., CMM). For image quality, transfer, and registration speed, the ground truth would be objectively defined technical specifications or measurements.
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The sample size for the training set:
- No information provided about a "training set." The REMI system is a robotic navigation system, not described as a deep learning or machine learning-based algorithm that typically requires a large training dataset for model development. The system uses pre-programmed logic, image processing, and control algorithms.
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How the ground truth for the training set was established:
- Not applicable, as no training set for an AI/ML model is mentioned.
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(90 days)
REMI
The REMI Platform is intended to be used in healthcare settings where near real-time and/or remote EEG is warranted. REMI consists of Epilog disposable Sensors - a single patient, disposable, wearable sensor intended to amplify, capture, and wirelessly transmit a single channel of electrical activity of the brain for up to 48 hours. The REM-Mobile software and REMI-Tablet are intended to receive and transmit data from four Epilog Sensors to secure cloud storage for subsequent viewing and reviewing of EEG on third-party software.
REMI does not make any diagnosis or recommendations and is intended only as a physiological signal monitor. Epilog Sensors are intended for use by trained medical professional healthcare facility environment.
Epilog Sensors are intended for use with adult and pediatric patients (6+). (Rx only).
REMI amplifies the electroencephalogram (EEG) from a patient's scalp. After amplification, the EEG are sent to the REMI-Tablet running the REMI-Mobile Application. REMI-Mobile combines the EEG from four Epilog Sensors and patient information and relays the data to a cloud server running Persyst software. The EEG data is accessible through the Persyst Mobile interface. REMI is designed for use with adult and pediatric patients (6+). The user interface for the REMI-Tablet is an 10" LCD touchscreen display.
The user interface for Epilog Sensors is a single button kevpad overmolded in each Sensor, REMI-Tablet power is through A/C adapter as well as limited onboard rechargeable battery. Epilog Sensor power is through a single-use primary coin cell. Using its wireless link, the Epilog Sensors can exchange EEG data and commands with the REMI-Mobile application running on the REMI-Tablet.
REMI has three major components:
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Epilog-D disposable EEG sensors,
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REMI-Mobile - mobile OS application designed to run on a medical-grade tablet, acquire EEG data transmitted from Epilog devices along with user-entered patient and device information, and then transmit the EEG data and patient/device information via wireless encrypted WiFi to.
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REMI-Cloud – A HIPAA-compliant cloud storage and data processing platform where data is processed into a format that a FDA-cleared (K171184) EEG reviewing software called Persyst can use, which will allow remote neurological review.
The firm Epitel, Inc. did not conduct a clinical study to prove the device meets acceptance criteria. Instead, they performed non-clinical performance testing and biocompatibility testing. The device is a physiological signal monitor and does not make diagnoses or recommendations. Therefore, the information provided below is a summary of the non-clinical and biocompatibility tests performed.
1. A table of acceptance criteria and the reported device performance
Test Category | Acceptance Criteria | Reported Device Performance |
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Non-Clinical Testing | ||
Electrical Safety | Compliance with IEC 60601-1 (General requirements for safety of medical electrical equipment) | Compliance was demonstrated. |
Electromagnetic Compatibility (EMC) | Compliance with IEC 60601-1-2 (EMC - Requirements and Tests) | Compliance was demonstrated for both emissions and immunity. |
Electroencephalograph Specific Safety | Compliance with IEC 60601-2-26 (Particular requirements for the safety of electroencephalographs) | Compliance was demonstrated. |
FCC/IC Intentional Radiator | Compliance with FCC Part 15 Radiated Emissions and Class B Conducted Emissions | Compliance was demonstrated. |
Biocompatibility Testing | ||
Irritation | Verified through testing per ISO 10993-10:2010 | Testing was performed per ISO 10993-10:2010, verifying biocompatibility. The Epilog Sticker was tested for prolonged (>24 hour but 24 hour but 24 hour but |
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(58 days)
Remington Medical, Inc. Automatic Cutting Needle (NAC)
Remington Medical, Inc. Automatic Cutting Needle (NAC) is intended for use in obtaining biopsies from soft tissues such as liver, kidney, prostate, spleen, lymph nodes and various soft tissue tumors. It is not intended for use in bone.
The Remington Medical Inc. Automatic Cutting Needle (NAC) is a device used for obtaining biopsies from soft tissues such as liver, kidnev, prostate, spleen, lymph nodes and various soft tissue tumors in combination with compatible commercial biopsy instrument(s)/gun(s) which are FDA cleared and distributed in the US Market. The Automatic Cutting Needles (NAC) are available in five qauges (differentiated by color) and seven needle lengths. The Automatic Cutting Needle (NAC) is advanced via the compatible commercial biopsy instrument/gun into the desired tissue to obtain a sample for histological examination. The Automatic Cutting Needle (NAC) is a sterile, single patient use and non-pyrogenic device.
The provided text describes a 510(k) premarket notification for the Remington Medical, Inc. Automatic Cutting Needle (NAC). This document focuses on demonstrating substantial equivalence to a predicate device, rather than proving a device meets specific performance acceptance criteria through a clinical study or AI model evaluation.
Therefore, many of the requested details, such as those related to AI algorithm performance, training/test set data, expert ground truth establishment, MRMC studies, or standalone algorithm performance, are not applicable to this type of regulatory submission. This is a traditional medical device, not an AI/ML enabled device.
Based on the provided information, here's what can be extracted and what cannot:
1. Table of Acceptance Criteria and Reported Device Performance:
There isn't a table of specific performance acceptance criteria in the sense of accuracy, sensitivity, or specificity metrics typical for AI/ML devices. Instead, the "acceptance criteria" are implied by the non-clinical testing performed to establish substantial equivalence. The "reported device performance" are the results of these non-clinical tests demonstrating the device's physical and functional properties are comparable to the predicate.
Acceptance Criteria (Implied by Study Type) | Reported Device Performance (Summary) |
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Dimensional Requirements | Met (results demonstrated equivalence to predicate) |
Stylet / Cannula to Hub Tensile Strength | Met (results demonstrated equivalence to predicate) |
Equipment Interface | Met (results demonstrated equivalence to predicate) |
Integrity of the Sterile Barrier | Met (results demonstrated equivalence to predicate) |
Biocompatibility | Met (results demonstrated equivalence to predicate) |
Pyrogenicity | Met (results demonstrated equivalence to predicate) |
Sterility Assurance | Met (results demonstrated equivalence to predicate) |
Distribution Simulation | Met (results demonstrated equivalence to predicate) |
Simulated Use Soft Tissue Sampling (Ex Vivo) | Met (results demonstrated equivalence to predicate for obtaining biopsies) |
2. Sample size used for the test set and the data provenance:
- Test Set Sample Size: Not explicitly stated as a numerical sample size of "cases" like in an AI study. The tests listed are non-clinical (e.g., mechanical, material, engineering tests) performed on samples of the device itself.
- Data Provenance: The tests are ex-vivo (meaning, performed outside of a living organism, likely in a lab setting using tissue phantoms or excised animal tissue for the "Simulated Use Soft Tissue Sampling"). The document does not specify a country of origin for the data beyond being conducted by Remington Medical, Inc. for their 510(k) submission. It is by definition "prospective" testing of manufactured devices for regulatory submission.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable. Ground truth in the context of clinical or AI studies (e.g., disease presence) is not relevant here. The "ground truth" for these engineering tests would be the established specifications and performance of the predicate device, against which the subject device's non-clinical performance is compared. This is a comparison of physical device characteristics.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not applicable. Adjudication methods are for resolving discrepancies in expert interpretations of medical data (e.g., radiologist reads), which is not part of this 510(k) submission's non-clinical testing.
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:
- No. An MRMC study was not done, as this is for a traditional biopsy needle, not an AI-enabled device.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done:
- No. This is not an algorithm, but a physical medical device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):
- Not applicable in the AI/clinical sense. The "ground truth" for the non-clinical tests is based on engineering specifications, material properties, and the established performance characteristics of the predicate device. For the "Simulated Use Soft Tissue Sampling," the ground truth would be the ability to successfully obtain a biopsy sample comparable to that obtained by the predicate.
8. The sample size for the training set:
- Not applicable. There is no "training set" as this is not an AI/ML device.
9. How the ground truth for the training set was established:
- Not applicable. There is no "training set" or "ground truth" for it in the context of an AI/ML device.
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