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510(k) Data Aggregation
(30 days)
GWF
The Nicolet EDX is intended for the acquisition, display, analysis, storage, reporting, and management of electrophysiological information from the human nervous and muscular systems including Nerve Conduction (NCS), Electromyography (EMG), Evoked Potentials (EP), Autonomic Responses and Intra-Operative Monitoring including Electroencephalography (EEG).
Evoked Potentials (EP) includes Visual Evoked Potentials (VEP), Auditory Evoked Potentials (AEP), Somatosensory Evoked Potentials (SEP), Electroretinography (ERG), Electrooculography (EOG), P300. Motor Evoked Potentials (MEP) and Contingent Negative Variation (CNV). The Nicolet EDX with Natus Elite Software may be used to determine autonomic responses to physiologic stimuli by measuring the change in electrical resistance between two electrodes (Galvanic Skin Response and Sympathetic Skin Response). Autonomic testing also includes assessment of RR Interval variability. The Nicolet EDX with Natus Elite Software is used to detect the physiologic function of the nervous system, for the location of neural structures during surgery, and to support the diagnosis of neuromuscular disease or condition.
The listed modalities do include overlap in functionality. In general, Nerve Conduction Studies measure the electrical responses of the nerve; Electromyography measures the electrical activity of the muscle and Evoked Potentials measure electrical activity from the Central Nervous System.
The Nicolet EDX with Natus Elite Software is intended to be used by a qualified healthcare provider.
The Nicolet EDX system is designed for the acquisition, display, analysis, reporting, and management of electrophysiological information from the human nervous and muscular systems. The system is designed to perform Nerve Conduction (NCS), Electromyoaraphy (EMG), Evoked Potentials (EP), and Autonomic Responses. Nicolet EDX system provides a variety of tests spanning the various modalities.
The Nicolet EDX system consists of the following major components:
- Base unit
- Amplifier (2- or 8-channel)
- Control panels
- Computer- laptop or desktop (with display, keyboard and mouse)
- Display Monitor (for desktop system)
- Application Software (Natus Elite)
The Nicolet EDX optional accessories/ components consist of the following:
- Audio stimulators (Headphones or other auditory transducers)
- Visual stimulators (Natus Visual Stimulator, LED goggles or stimulus monitor)
- Electrical stimulators (RS10 comfort probe, WR50 comfort probe plus)
- Cart and associated accessories (such as arms, mounts and isolation transformer
- Miscellaneous options and accessories such as Patient Response button. Single/Triple footswitch, Tendon (Reflex) hammer, Natus photic stimulator, temperature probe, ultrasound device, bone conductor, printer, etc.
The electrodiagnostics system is powered by a connection to mains.
The entire user interface of Nicolet EDX system consists of two major elements:
- The primary means to interact with the system is via a personal computer (PC) running Natus Elite.
- The second means of interaction is the user interface elements on the hardware.
The Nicolet EDX is intended to be used by a qualified healthcare provider. This device does not provide any diagnostic conclusion about the patient's condition to the user. The intended use environment is in a professional healthcare facility environment.
This FDA 510(k) summary for the Nicolet EDX device does not contain the detailed information necessary to fully address all aspects of your request regarding acceptance criteria and study design.
However, based on the provided text, here's what can be extracted and inferred:
1. A table of acceptance criteria and the reported device performance
The document does not explicitly state "acceptance criteria" for the device's clinical performance with quantitative metrics. Instead, it compares the technological characteristics of the Nicolet EDX to predicate devices, implying that meeting or being substantially equivalent to these characteristics demonstrates acceptable performance.
Here's a table summarizing the technological characteristics described as identical or similar to predicate devices, which serve as an implicit benchmark for acceptance:
Characteristic | Nicolet EDX (This Submission) | Primary Predicate (K120979) | Reference Predicate (K243495) | Discussion of differences (from document) |
---|---|---|---|---|
1. General | ||||
Product Code | GWF, IKN | GWF | GWF | Identical to predicate. |
Indications for Use | Unchanged from primary predicate | Same as Nicolet EDX | Same as Nicolet EDX | Identical to predicate. |
Warnings | Items related to off label use or misuse. | Same | Same | Identical to predicate |
Contraindications | Not for use in flammable anesthetics or with defibrillation. | Same | Same | Identical to predicate |
Target Population | Patients with neuromuscular diseases (pediatric and adult) | Same | Same | Identical to predicate |
Environment of Use | Professional healthcare facility environment. | Same | Same | Identical to predicate |
2. General Design | ||||
General Systems Approach | Computer based equipment with dedicated hardware peripherals/components. | Same | Same | Identical to predicate |
User Input Device | Windows mouse/keyboard driven graphic interface with dedicated control panel. | Same | Same | Identical to predicate |
User Output Device | Digital color display and commercial printers. | Same | Same | Identical to predicate |
Patient Inputs | 1 to 8 channel amplifier, isolated | 1 to 8 channel amplifier, isolated | 1 to 4 channel amplifier, isolated | Identical to primary predicate. Similar to reference predicate. |
Signal Acquisition | Analog to digital conversion at 48 kHz per sample rate | Same | Same | Identical to primary predicate. |
Trigger Input (synchronization to external events) | Yes | Yes | Yes | Identical to predicate |
Trigger Output (synchronization for external devices) | Yes | Yes | Yes | Identical to predicate |
Footswitch | Yes | Yes | Yes | Identical to predicate |
Use of standard software platform (Operating System) | Yes, Microsoft Windows | Same | Same | Identical to predicate |
Customization of protocols | Via storage / retrieval of user defined settings | Same | Same | Identical to predicate |
Application flexibility / expandability | Via software update | Same | Same | Identical to predicate |
Patient circuitry isolation | Optic/transformer | Same | Same | Identical to predicate |
System Components | EDX base console, 2 electrical stimulators, auditory stimulator, trigger I/O, LED goggle interface; Control panel; Amplifier; Computer, monitor, keyboard, mouse, printer | Same | Base console, 1 electrical stimulator, auditory stimulators, trigger I/O, LED goggle interface; Control panel (integrated); Amplifier; Computer; Monitor; Keyboard; Mouse; Printer | Identical to predicate. Similar to the reference predicate. |
System computer interface | USB | USB | USB | Identical to predicate |
System power supply | Mains (100 -240VAC) thru an isolation transformer depending on system configuration | Same | Same | Identical to predicate |
3. Design - Acquisition | ||||
Number of channels | 1 to 8 | 1 to 8 | 1 to 4 | Identical to primary predicate. Similar to reference predicate. |
CMRR | >110 dB, 115 dB typical | >110 dB, 115 dB typical | >120 dB | Identical to primary predicate. Similar to reference predicate. |
Noise | 1000 MΩ | >1000 MΩ | >1000 MΩ | Identical to primary predicate. |
Low Filter | 0.05 Hz to 5 kHz | 0.05 Hz to 5 kHz | 0.05 Hz to 5 kHz | Identical to primary predicate. |
High Filter | 30 Hz to 20 kHz | 30 Hz to 20 kHz | 30 Hz to 20 kHz | Identical to predicate. |
Notch Filter | 50/60 selectable | 50/60 selectable | 50/60 selectable | Identical to primary predicate. |
A/D conversion | 24 bit | 24 bit | 24 bit | Identical to primary predicate. |
Sampling rate (cumulative) | 384 kHz | 384 kHz | 192 kHz | Identical to primary predicate. Similar to reference predicate. |
Trigger mode | Free-run, internal, external | Same | Same | Identical to primary predicate. Similar to reference predicate. |
Signal delay (pre/post) | -90% to +90% of sweep, depending on time base | Same | Same | Identical to primary predicate. |
Impedance meter | 500Ω to 480 kΩ | 500Ω to 480 kΩ | 1kΩ to 1,000 kΩ | Identical to primary predicate. Similar to reference predicate. |
4. Design - Stimulators | ||||
4.1 Electrical Stimulator | ||||
Type | Constant Current or Constant Voltage | Same | Constant Current | Identical to primary predicate. Similar to reference predicate. |
Number | 1 or 2 | 1 or 2 | 1 | Identical to primary predicate. Similar to reference predicate. |
Maximum Output | 100mA or 400V | 100mA or 400V | 100mA | Identical to primary predicate. Similar to reference predicate. |
Duration | 0.01 to 1 ms | 0.01 to 1 ms | 0.01 to 1 ms | Identical to primary predicate. |
Mode | Single or Train | Single or Train | Single or Train | Identical to primary predicate. |
Biphasic | Yes | Yes | Yes | Identical to primary predicate. |
4.2 Auditory Stimulator | ||||
Type | Click, Pip, Burst | Same | Same | Identical to primary predicate. |
Intensity | 0 to 139 dB pSPL | Same | Same | Identical to primary predicate. |
Polarity | Condensation, Rarefaction, Alternating | Same | Same | Identical to primary predicate. |
Tone Frequency | 125 to 8000 Hz | Same | Same | Identical to primary predicate. |
Click Duration | 0.05 to 1 ms | Same | Same | Identical to primary predicate. |
Side | Left, Right, Both | Same | Same | Identical to primary predicate. |
Transducers | Ear Phones, Inserts, Bone Vibrator | Same | Same | Identical to predicate. |
4.3 Visual Stimulator | ||||
LED Goggles | Yes | Yes | Yes | Identical to predicate |
5. EMG Application Modules | (All "Yes") | (All "Yes") | (All "Yes") | Identical to predicate |
6. Evoked Potential Application Modules | (All "Yes") | (All "Yes") | (All "Yes") | Identical to primary predicate |
7. Other Application Modules | (All "Yes") | (All "Yes") | (All "Yes") | Identical to primary predicate |
8. Additional Features | ||||
Automatic Report Narrative Generation | Yes | Yes | Yes | Identical to primary predicate |
Electrical Stimulus Automation | Yes | Yes | Yes | Identical to primary predicate |
9. Image Display and Control Interface | ||||
Display and control of noninvasive third party imaging modality (e.g., Ultrasound) | Yes, Integrated (concurrent) ultrasound display and control using Sonoscanner Ultrasound System (K232285) with Natus Elite software. | No, Supports ultrasound by supplying a third-party device which operates in a nonintegrated mode. Using the Sonoscanner Ultrasound System (K232285) | Yes, Integrated (concurrent) ultrasound display and control using Sonoscanner Ultrasound System (K232285) with Natus Elite software. | Identical to reference predicate. |
The study proving the device meets the acceptance criteria is detailed by the statement: "Verification and validation activities were conducted to establish the performance and safety characteristics of the Nicolet EDX. The results of these activities demonstrate that the Nicolet EDX is safe, effective, and performance is substantially equivalent to the predicate devices."
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
This information is not provided in the document. The 510(k) summary focuses on "substantial equivalence" based on technological characteristics and general verification/validation, rather than a clinical study with a specific test set, patient data, and provenance.
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)
This information is not provided as a detailed clinical study with ground truth established by experts is not described in this summary. The device is for electrophysiological information acquisition and analysis, where "ground truth" often refers to the actual physiological signals or clinical diagnoses, which would typically be assessed by qualified healthcare providers using established medical guidelines.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This information is not provided as a formal clinical study with adjudication of a test set is not detailed.
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
An MRMC study is not mentioned in this summary. The device description explicitly states: "This device does not provide any diagnostic conclusion about the patient's condition to the user." It is a diagnostic aid for acquiring and analyzing physiological information, not an AI-driven interpretive tool that would typically undergo MRMC studies to assess human reader improvement.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
A standalone algorithm performance study is not mentioned. The device is an electrodiagnostic system with software, but the summary does not present it as an autonomous AI system requiring standalone performance evaluation in the classification sense. Rather, it emphasizes its role as a tool for a "qualified healthcare provider."
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
Since a specific clinical study with a detailed test set is not described, the type of ground truth used is not specified. For a device like this, the "ground truth" for performance validation would likely involve:
- Technical Benchmarking: Verification that the electrical signals acquired and processed meet specified technical parameters by comparing them to known or simulated physiological signals, or against established high-fidelity measurement systems.
- Clinical Utility Confirmation: Ensuring that the output provides information that is consistent with expected physiological responses and is interpretable by healthcare professionals for supporting diagnosis.
8. The sample size for the training set
This information is not provided. This summary does not indicate that the device uses machine learning or AI models that require a "training set" in the conventional sense. The "Natus Elite Software" is application software for data acquisition, display, and analysis, not necessarily a predictive AI model requiring a distinct training dataset.
9. How the ground truth for the training set was established
As no training set is mentioned, the method for establishing its ground truth is not applicable/provided.
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(30 days)
GWF
The UltraPro is intended for the acquisition, display, analysis, storage, reporting, and management of electrophysiological information from the human nervous and muscular systems including Nerve Conduction (NCS), Electromyography (EMG), Evoked Potentials (EP), Autonomic Responses and Intra-Operative Monitoring including Electroencephalography (EEG).
Evoked Potentials (EP) includes Visual Evoked Potentials (VEP), Auditory Evoked Potentials (AEP), Somatosensory Evoked Potentials (SEP), Electroretinography (ERG), Electrooculography (EOG), P300. Motor Evoked Potentials (MEP) and Contingent Negative Variation (CNV). The UltraPro with Natus Elite Software may be used to determine autonomic responses to physiologic stimuli by measuring the change in electrical resistance between two electrodes (Galvanic Skin Response and Sympathetic Skin Response). Autonomic testing also includes assessment of RR Interval variability. The UltraPro with Natus Elite Software is used to detect the physiologic function of the nervous system, for the location of neural structures during surgery, and to support the diagnosis of neuromuscular disease or condition.
The listed modalities do include overlap in functionality. In general, Nerve Conduction Studies measure the electrical responses of the nerve; Electromyography measures the electrical activity of the muscle and Evoked Potentials measure electrical activity from the Central Nervous System.
The UltraPro with Natus Elite Software is intended to be used by a qualified healthcare provider.
The UltraPro S100 system is designed for the acquisition, display, analysis, reporting, and management of electrophysiological information from the human nervous and muscular systems. The system is designed to perform Nerve Conduction (NCS). Electromyography (EMG), Evoked Potentials (EP), and Autonomic Responses. UltraPro S100 system provides a variety of tests spanning the various modalities.
The UltraPro S100 system consists of the following major components:
- Main unit (also known as base unit or main base unit) with integrated control panel; ●
- Amplifier (3- or 4-channel);
- . Computer- laptop or desktop (with keyboard and mouse)
- Display Monitor (for desktop system)
- . Application Software (Natus Elite)
The UltraPro S100 has the following optional accessories/ components:
- Audio stimulators (Headphones or other auditory transducers)
- Visual stimulators (LED goggles or stimulus monitor)
- . Electrical stimulators (RS10 probes, stimulus probe with controls)
- Cart and associated accessories when using cart such as isolation transformer
- Miscellaneous accessories such as Patient Response button, Triple footswitch, Reflex hammer, temperature probe and adapter, ultrasound device, printer, etc.
The electrodiagnostics system is powered by a connection to mains.
The entire user interface of UltraPro S100 system consists of two major elements:
- The primary means to interact with the system is via a personal computer (PC) running ● Natus Elite.
- The second means of interaction is the user interface elements on the hardware.
The UltraPro S100 is intended to be used by a qualified healthcare provider. This device does not provide any diagnostic conclusion about the patient's condition to the user. The intended use environment is in a professional healthcare facility environment.
The provided text is a 510(k) Summary for the Natus Ultrapro S100 device. While it describes the device's indications for use and compares its technological characteristics to predicate devices, it does not contain information about the acceptance criteria or the specific study that proves the device meets those criteria, such as a clinical performance study with defined metrics like sensitivity, specificity, or accuracy. This document focuses on demonstrating substantial equivalence to a predicate device primarily through technical specifications and intended use.
Therefore, I cannot provide a table of acceptance criteria, reported device performance, sample sizes used for test/training sets, data provenance, number or qualifications of experts, adjudication methods, or details about MRMC or standalone studies based on the provided text. The document is primarily a comparison of features and intended use.
The "Conclusion" section on page 14 states: "Verification and validation activities were conducted to establish the performance and safety characteristics of the UltraPro S100. The results of these activities demonstrate that the UltraPro S100 is safe, effective, and performance is substantially equivalent to the predicate devices." However, it does not elaborate on what these activities entailed or the specific criteria and results.
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(90 days)
GWF
The Delphi Stimulator is intended to be used for stimulation of peripheral nerves for diagnostic purposes.
Delphi stimulator is a Magnetic stimulator used for Magnetic stimulation of peripheral nerves for diagnostic purposes. Magnetic stimulation is a non-invasive technique for stimulating neural tissue. Application areas of magnetic stimulation are a sub-set of the application areas for current stimulation. The Delphi stimulator is connected to a Magnetic Coil which transfers the magnetic stimulation to the tissue.
The stimulator consists of power electronics to generate the magnetic field in the Magnetic Coil. It is controlled via a user interface installed on a PC workstation connected to the stimulator. enabling the operator to overview all functions, stimulus sequences, controls, status and measured data. The magnetic pulse is Biphasic waveform and the stimulator can stimulate with a frequency of up to 3 pulses per second (pps).
The provided text does not contain information about acceptance criteria and a study that proves the device meets those criteria in the format requested. The document is an FDA 510(k) summary for the "Delphi Stimulator," which focuses on demonstrating substantial equivalence to a predicate device.
The "Performance Data" section (Section 10) lists various tests performed, but these are primarily bench tests for substantial equivalence, electrical safety, EMC, and software validation. It does not present specific acceptance criteria (e.g., minimum sensitivity or specificity targets) or a clinical study with human subjects to evaluate the device's diagnostic performance against such criteria.
The information provided is as follows:
1. A table of acceptance criteria and the reported device performance:
- No explicit table of acceptance criteria with corresponding device performance for diagnostic accuracy (e.g., sensitivity, specificity) is provided.
- The document mentions "Stimulation output comparison to Predicate" where the results "demonstrated substantial equivalency." This is a comparison for substantial equivalence, not a performance metric against a set acceptance criterion.
2. Sample size used for the test set and the data provenance:
- Not applicable. No clinical test set involving patient data is described. The performance data refers to nonclinical bench tests.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable. No clinical test set requiring expert-established ground truth is described.
4. Adjudication method for the test set:
- Not applicable. No clinical test set requiring adjudication is described.
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:
- Not applicable. This device is a stimulator for diagnostic purposes, not an AI-powered diagnostic system that assists human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This device is a stimulator, not an algorithm.
7. The type of ground truth used:
- Not applicable. For the bench tests performed, the "ground truth" would be the expected electrical and magnetic outputs, and adherence to safety and software standards, which were verified directly rather than against a clinical ground truth.
8. The sample size for the training set:
- Not applicable. This document describes a medical device, a stimulator, not a machine learning or AI model that requires a training set.
9. How the ground truth for the training set was established:
- Not applicable. As above, this document does not refer to a machine learning or AI model.
Summary of available "Performance Data" from the document:
Test | Test Method Summary | Results |
---|---|---|
Stimulator Output Comparison to Predicate | Stimulation output was measured in SMT units (Electrical field) and compared to the predicate (per FDA Class II Special Controls Guidance Document: Repetitive Transcranial Magnetic Stimulation (rTMS) Systems) | The obtained results demonstrated substantial equivalency |
System verification testing | The device was operated at various intensities to verify it functions as intended | No failures were observed; test passed. |
ASCA test for basic safety and essential performance | Testing per IEC 60601-1 and IEC 60601-1-2 | Pass |
Software testing | Software testing per the requirement of the software life cycle as defined in IEC 62304:2006 Amendment 2015 - Medical device software - Software life cycle processes. | Pass |
Cybersecurity assessment | Evaluation of threat per: - FDA Guidance, Post-market Management of Cybersecurity in Medical Devices - FDA Guidance, Cybersecurity in Medical Devices: Quality System Considerations and Content of Premarket Submissions. - AAMI TIR57:2016 Principles for Medical Device Security-Risk Management - FDA Guidance, Select Updates for the Premarket Cybersecurity Guidance: Section 524B of the FD&C Act | No vulnerabilities were found; labeling includes all required elements addressing cybersecurity |
In conclusion, the document describes non-clinical bench tests and adherence to safety and software standards to support the substantial equivalence claim, rather than a clinical study evaluating diagnostic performance against specific acceptance criteria.
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(115 days)
GWF
The SafeOp 3: Neural Informatix System is intended for use in monitoring neurological status by recording transcranial motor evoked potentials (MEP), somatosensory evoked potentials (SSEP), electromyography (EMG), or assessing the neuromuscular junction (NMJ). Neuromonitoring procedures include intracranial, intratemporal, extratemporal, neck dissections, upper and lower extremities, spinal degenerative treatments, pedicle screw fixation, intervertebral fusion cages, rhizotomy, orthopedic surgery, open/percutaneous, lumbar, thoracic, and cervical surgical procedures.
SafeOp 3 Accessories: The SafeOp Accessories are utilized in spine surgical procedures to assist in location of the nerves during or after preparation and placement of implants (intervertebral fusion cages and pedicle screw fixation devices) in open and percutaneous minimally invasive approaches.
The SafeOp™ 3: Neural Informatix System (SafeOp 3 System), consists of the SafeOp patient interface with power supply and IV pole mount, the Alpha Informatix Tablet with docking station and power supply and a data transfer USB cable. Associated disposable accessories consists of an electrode harness, surface and/or subdermal needle electrodes, MEP Activator, Cranial Hub, PMAP Dilators and stimulating probe or clip contained in various kits.
The subject device is intended for use by trained healthcare professionals, clinical neurophysiologists/technologists and appropriately trained non-clinical personnel. The subject device is intended for use in operating room environments of hospitals and surgical centers. System setup may be performed by both clinical and trained non-clinical personnel.
The subject device records the following modalities:
- Somatosensory evoked potentials (SSEP)
- Motor evoked potentials (MEP),
- . Train-of-four neuromuscular junction (TO4),
- Triggered electromyography (tEMG) and ●
- . Free run electromyography (sEMG)
The provided text does not contain detailed information about specific acceptance criteria for the device's performance, nor does it describe a study that rigorously proves the device meets such criteria through a clinical validation or similar performance evaluation.
The document is a 510(k) premarket notification summary for the "SafeOp 3: Neural Informatix System." Its primary purpose is to demonstrate substantial equivalence to a previously cleared predicate device (SafeOp2: Neural Informatix System, K213849, and reference device Cascade IOMAX Intraoperative Monitor, K162199), rather than to present a full clinical performance study with defined acceptance criteria and detailed results.
Here's a breakdown of what the document does say, and what it lacks in relation to your request:
What the document provides:
- Device Name: SafeOp 3: Neural Informatix System
- Intended Use/Indications for Use: Monitoring neurological status by recording transcranial motor evoked potentials (MEP), somatosensory evoked potentials (SSEP), electromyography (EMG), or assessing the neuromuscular junction (NMJ) during various surgical procedures.
- Technological Comparison: A table comparing the SafeOp 3 System to predicate and reference devices, focusing on technical specifications like monitoring modalities, amplifier channels, stimulation parameters (voltage, current, pulse duration, repetition rate), and filter ranges. This comparison primarily aims to establish that the differences in technology do not raise new questions of safety or effectiveness.
- Performance Data (Non-clinical): Mentions that "Nonclinical performance testing demonstrates that the subject SafeOp 3 System meets the functional, system, and software requirements." It also states "EMC and Electrical Safety Testing... was performed to ensure all functions... are electrically safe, and comply with recognized electrical safety standards." Usability testing was also performed.
- Clinical Information Disclaimer: Explicitly states, "Determination of substantial equivalence is not based on an assessment of clinical performance data."
What the document lacks significantly for your request:
- A table of acceptance criteria and reported device performance: This is the most significant omission for your request. The document details technical specifications and comparisons but does not provide quantitative performance metrics (e.g., accuracy, sensitivity, specificity, or specific error rates) against pre-defined acceptance thresholds for any of its functionalities (MEP, SSEP, EMG, NMJ). The performance data mentioned are non-clinical (functional, system, software, EMC, electrical safety, usability), not clinical performance metrics.
- Sample size used for the test set and data provenance: Since specific clinical performance studies are not detailed, this information is not provided.
- Number of experts used to establish ground truth and qualifications: Not applicable as a clinical ground truth establishment process for performance evaluation is not described.
- Adjudication method for the test set: Not applicable.
- MRMC comparative effectiveness study: No such study is mentioned or detailed.
- Standalone (algorithm only) performance: While the device is an "algorithm only" in a sense (it processes physiological signals), its performance isn't quantified in a standalone clinical evaluation or comparative study.
- Type of ground truth used: No clinical ground truth is described for performance evaluation.
- Sample size for the training set: Not applicable, as this is related to AI/ML development and training, which is not described. The device is a neuromonitoring system, not explicitly stated to be an AI/ML device in the context of this submission.
- How the ground truth for the training set was established: Not applicable.
Why this information is missing:
The FDA 510(k) pathway for "substantial equivalence" often relies on demonstrating that a new device is as safe and effective as a legally marketed predicate, without necessarily requiring new clinical trials or detailed performance studies if the technological differences are minor and well-understood. The focus is on showing that any differences do not introduce new safety or effectiveness concerns.
In summary, based solely on the provided text, I cannot complete the table of acceptance criteria or describe a study that proves the device meets these criteria in a clinical performance context. The document focuses on demonstrating substantial equivalence through technical comparison and non-clinical testing, rather than presenting clinical performance metrics.
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(94 days)
GWF
MEGA-IOM system with Neuro-IOM.NET software is a medical device intended for intraoperative neurophysiologic monitoring: the device provides information to assess a patient's neurophysiological status.
The system allows to monitor the functional integrity and/or mapping of central and peripheral nervous system including motor and sensory pathways.
It is provided in three different configurations:
I. 32/B
II. 32/S
III. 16/S
The system ensures the following IOM modalities: free-run EMG (electromyography), direct nerve stimulation including pedicle screw test, SSEP (somatosensory evoked potential), MEP (motor evoked potential), EEG (electroencephalography), AEP (auditory evoked potential), VEP (visual evoked potentials), direct cortical stimulation. Also the train-of-four (TOF) stimulation is performed.
The system is not intended to measure vital signs. It records the data to be interpreted by the neuromonitoring specialist.
MEGA-IOM system is intended for use in adults age 18 years and older.
The MEGA-IOM system with Neuro-IOM.NET software is intended for intraoperative neurophysiological monitoring (IOM).
The system is intended for monitoring the functional integrity and/ or mapping of central and peripheral nervous system including motor and sensory pathways.
Soterix Medical is assuming manufacturing of the predicate product cleared in K190703. This 510(k) submission includes the same hardware cleared with the predicate device system (no changes) and an updated version of the software compared to the predicate device.
Below, a high-level summary of the changes from the predicate are provided:
Software: The primary changes in this 510(k) submission are related to the software. The changes are troubleshooting updates for greater usability such as user interfaces and bug fixes. Detailed descriptions of these software changes per version are provided below:
Version 1.1.52.7: Fixes related to the stimulation stop after a few hours, adding a stimuli limit for double train stimulation, allowing pulse duration (200 microseconds) entry, masking noise limitation per IEC 60601-2-40 (Particular requirements for the basic safety and essential performance of electromyographs and evoked response equipment), reporting correct status of multichannel operation, prevent skipping of traces, and check for incompatible stimulation parameter entry.
Version 1.1.52.8: Fixes related to facilitating quick turning off stimulation, real-time stimulus change control, scrolling in spectral setup window, constraining window within pattern printout to screen, ensuring modality window description is unchanged, incorrect Ch 17 display in emulation mode, video filters error during installation, ensuring all text is displayed within visibility area, incorrect auditory evoked potentials (EPs) average calculation in emulation mode.
Version 1.1.52.9: Fixes related to exam saved message, flexibility to change test template sequence, sleep mode prevention, rendering speed, interpulse interval display correction, allowing comments in the event window, automatic creation of user template, template list update, impedance measurement window rendering, parameter display correction in EMG trigger window and Group mode, ensuring non-disappearance of red line around patient's birth date, enabling stimulation via local menu in Scoliosis test template, frame switching error during video recording, displaying correct device status.
Version 1.1.53.7: Fixes related to addition of video clip creation button, accidental stimulation activation protection, display of preliminary train in double train mode, voltage and charge value display in stimulation panel, allowing repetitive stimulation in Double Train and Train+Pulse modes, option to view amplitude values up to 10 microA, option to select scales in X axis, option to delay auto saving if stimulation in progress, option to titrate stimulation amplitude using mouse wheel, option to select grid type, confirmation on layout uninstallation, addition of the Pause button in Stimulation programs, option to select motor response search interval and displaying the motor response search interval, addition of measured impedance visualization, offering first the windows already available when adding a new window, preventing closure of window if input row is active in derivation test, enable display of additional TOF parameters, option to playback trace fragments, addition of Take a screenshot command, parameter trend export, pulse duration interval display in TES train, option to enter multiple-line comments, option to re-name layout, option to hide command list, ability to save only responses beyond a certain level, stimulator list scrolling, RMS noise value display, test template cloning, motor response onset marker, previous recorded traces display, layouts during new test reset, stimulator reminder mod, video file duration based on frame rate, saving of the number of traces, test template rewriting, group trace visualization display, layout switching, stimulation resumption post coagulator off, video playback if another program is run.
Version 1.1.53.8: Fixes related to allowing multiple image view within the image window, allowing EEG artifact recording, showing baseline in the Overlay mode, option to disable program, option to save screen shots to a specific folder, stimulation program panel addition, correction of autoincrement window bug, correction of DSA rendering.
Version 1.1.53.9: Fixes related to custom scale adjustment in Freerun window, randomly changing pulse intervals in multichannel mode, event trace copy to report, layout panel updating post deletion, sound, threshold, and color parameter display during new site addition, EMG channels in template during long-term monitoring, site visibility during stimulation in presence of temporary markers, auto sweep resets, temporary markers display, trace export to EDF, layout non-save post video window opening, type conversion in trace window.
Version 1.53.10: Fixes related to video window copying over to report, trace scale reset, appearance of average trace display in case of no averages due to artifacts, site name display in TOF window, saving of initial study state in autosave mode, incomplete installation of video components, volume increment of auditory stimulator signal volume.
Version 1.1.53.11: Fixes related to active probe switch-off during monitoring, limiting maximum increment adjustment of electrical stimulation amplitude to 1 mA and 5V, stimulus duration set-up when stimulation amplitude is increased, stimulation disablement after power supply resume, stimulus sound notification, text visualization in dialogue box, non-active stimulator panel, maximum stimulus artifact width display, minimum and maximum MEP trace markers.
Version 1.1.53.12: Fixes related to pulse width change during stimulation in multichannel mode, MS Office word report, TeamViewer, logo, and translation corrections.
Version 1.1.53.13: Fixes related to removal of sites containing TOF and logo change.
Version 1.1.53.14: Fixes related to start monitoring during video camera switch off, video recording in some interface languages, sound disablement during impedance measurement, printing test template, USB driver-related Windows 10 OS bugs.
In summary, the aforementioned software changes are related to resolving software bugs and increasing user convenience, but the changes do not impact the intended use, indications for use statement, contraindications, or warnings. They also don't increase the likelihood that the device will be used by a broader or different group of users and do not raise any new risks.
Labeling: Modifications have been made to labeling and these changes are related to the new device trade name and change in manufacturer. Instances of "Neuro-IOM" were changed to "MEGA-IOM" in the user manual and on the device labels. Soterix Medical is named the manufacturer and point of contact in the labeling including for all complaints and service requests.
Waveforms: The MEGA-IOM system has the same waveforms as the predicate device. No change to the waveforms.
The provided text is a 510(k) Premarket Notification from the FDA for the "MEGA-IOM system with Neuro-IOM.NET software". This document primarily focuses on demonstrating substantial equivalence to a predicate device (K190703 Neuro-IOM system with Neuro-IOM.NET software) rather than detailing extensive clinical studies with acceptance criteria for new device performance.
The submission is for a device that has primarily undergone software updates and a change in manufacturer. Therefore, the "study that proves the device meets the acceptance criteria" is in the form of software verification and validation, and comparison to the predicate device's established performance.
Here's an analysis based on the provided text:
1. A table of acceptance criteria and the reported device performance:
The document doesn't provide explicit "acceptance criteria" in the traditional sense of a clinical trial (e.g., target sensitivity/specificity for a diagnostic AI). Instead, the acceptance criteria are implicitly demonstrating that the updated software, in conjunction with the unchanged hardware, performs identically or equivalently to the predicate device. The performance is assessed by confirming that all functional and technical specifications remain the same.
Parameter | Acceptance Criteria (Implicit - Identical to Predicate) | Reported Device Performance (MEGA-IOM) | Comment |
---|---|---|---|
Device Name and Model | Neuro-IOM 16S, 32S, 32B with Neuro-IOM.NET software | MEGA-IOM 16S, 32S, 32B with Neuro-IOM.NET software | New trade name for the subject device. Functionally identical. |
Classification Name | Stimulator, Electrical, Evoked Response | Stimulator, Electrical, Evoked Response | Identical |
Product Codes | GWF (primary), GWE, GWJ, OLT, PDQ | GWF (primary), GWE, GWJ, OLT, PDQ | Identical |
Regulatory Class | Class II | Class II | Identical |
Classification Number | 21 CFR 882.1870 | 21 CFR 882.1870 | Identical |
Indications for Use (IFU) | Matches predicate (detailed in document) | Matches predicate (detailed in document) | Similar; new IFU includes new device name. All other wording identical. |
Intended User | Trained personnel only | Trained personnel only | Identical |
Device Hardware Setup | Connected to PC, not standalone | Connected to PC, not standalone | Identical (hardware is unchanged) |
Electrical Safety Standards | Conforms to specified standards (older versions acceptable for predicate) | Conforms to updated versions of same standards | Subject device conforms to updated versions of standards. |
Workflow, Menu | PC-controlled | PC-controlled | Identical |
Interface to Computer | USB | USB | Identical |
Channels | 16/32 | 16/32 | Identical |
1.5 mm touch-proof input jacks | Same | Same | Identical |
Cable Length | 5m | 5m | Identical |
Input Impedance | >1000 MOhm | >1000 MOhm | Identical |
Common Mode Rejection (CMRR) | >90 dB | >90 dB | Identical |
Low Frequency Filters | 0.2 Hz - 2000 Hz | 0.2 Hz - 2000 Hz | Identical |
High Frequency Filters | 10 Hz - 4 kHz | 10 Hz - 4 kHz | Identical |
Notch Filter | 50/60 Hz | 50/60 Hz | Identical |
Sample Rate | 50 kHz | 50 kHz | Identical |
Sensitivity | 0.05 µV/division to 20 mV/division | 0.05 µV/division to 20 mV/division | Identical |
Noise Level |
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(28 days)
GWF
The product is used for intraoperative monitoring and testing during surgical procedures
· to examine neuronal tissue (central and peripheral nervous system) by recording and stimulation
The product can be used during surgical procedures that justify non-therapeutic clinical use of the following modalities or their combinations:
- · Measurement:
- o Auditory evoked potentials (AEP)
- o Electroencephalography (EEG)
- o Electrocorticography (ECoG)
- o Electromyography (EMG)
- o Somatosensory evoked potentials (SSEP)
- o Motor evoked potentials (MEP)
- o Train of Four (TOF)
- · Stimulation:
- o Transcranial electrical stimulation (TES)
- o Direct cortical and subcortical stimulation (DCS)
- o Direct nerve stimulation (DNS)
- o Transcutaneous intraoperative nerve stimulation (TINS)
- o Direct muscle stimulation (DMS)
The ISIS Headboxes and the ISIS Neurostimulator constitute multimodal intraoperative neuromonitoring systems called ISIS IOM Systems. These systems consist of custom stimulation and recording hardware, a standard laptop or desktop personal computer running an off-the-shelf operating system, and operating software called NeuroExplorer. As an option, these systems mount on device carriers or housings tailored for intraoperative use.
The ISIS IOM Systems support the following measurement modalities:
- -Auditory Evoked Potentials
- -Transcranial and cortical Motor Evoked Potentials
- Somatosensory Evoked Potentials -
- Free-running and triggered Electromyography -
- Electroencephalography -
- Train of Four -
The provided document is a 510(k) summary for the ISIS Headboxes and ISIS Neurostimulator, which are intraoperative neuromonitoring systems. It focuses on demonstrating substantial equivalence to a predicate device (K212166) rather than establishing novel acceptance criteria and proving performance against them in a clinical study.
The document states that no additional clinical testing was performed for the subject devices. Instead, the submission relies on bench testing against established standards and internal requirements to demonstrate safety, effectiveness, and performance that is "as well as or better than" the predicate device.
Therefore, many of the requested elements for describing "acceptance criteria and the study that proves the device meets the acceptance criteria" in the context of a de novo AI/ML device (which often involves clinical performance metrics like sensitivity, specificity, etc.) are not directly applicable or available in this document.
Here's an attempt to extract the relevant information based on the provided text, acknowledging the limitations:
1. Table of Acceptance Criteria and Reported Device Performance
Since this is a submission demonstrating substantial equivalence to a predicate device through bench testing rather than a de novo AI/ML device with pre-defined performance metrics, the acceptance criteria are primarily related to adherence to international standards and internal requirements for electrical safety, EMC, and software validation.
Acceptance Criteria Category | Specific Criteria (Implicit or Explicit in Document) | Reported Device Performance |
---|---|---|
Biocompatibility | No patient contact materials | Not applicable |
Software | Conformance to: | Demonstrated compliance with predetermined specifications, applicable guidance documents, and standards. |
- FDA Guidance: Content of Premarket Submissions for Device Software Functions, Jun 14, 2023 | ||
- FDA guidance: Off-the-shelf software use in medical devices, August 11, 2023 | ||
- FDA guidance: General principles of software validation: Final guidance for industry and FDA staff, Jan 02, 2002 | ||
- FDA guidance: Content of premarket submissions for management of cybersecurity in medical devices, Oct 02, 2014 | ||
- IEC 62304:2006/AMD1:2015, Medical device software - Software life cycle processes | ||
Electrical Safety | Conformance to: | Test results demonstrate compliance with applicable standards. |
- IEC 60601-1:2005 + CORR. 1:2006 + CORR. 2:2007 + A1:2012 (or IEC 60601-1: 2012 reprint) | ||
- IEC 80601-2-26:2019 (Electroencephalographs) | ||
- IEC 60601-2-40:2016 (Electromyographs and evoked response equipment) | ||
Electromagnetic Compatibility | Conformance to: | Test results demonstrate compliance with applicable standards. |
- IEC 60601-1-2:2014 | ||
Performance Testing – Bench | Fulfillment of internal requirement specifications for: | Products successfully underwent bench testing, confirming fulfillment of requirements. |
- Electrical medical systems | ||
- System carrier | ||
- Amplifier (ISIS Headboxes) and stimulator (ISIS Neurostimulator) modules | ||
- Operating software (NeuroExplorer) incl. firmware | ||
- Accessories (adaptor boxes) | ||
- Custom Microsoft® Windows 10 image | ||
Human Factors | Demonstrates safety and no need for further UI improvement | Testing confirms products are safe to use. |
Overall Performance | As safe, as effective, and performs as well as or better than the legally marketed predicate. | Demonstrated. |
2. Sample Size Used for the Test Set and the Data Provenance
- Sample Size: Not applicable in the traditional sense of a clinical test set with patient data. The testing was primarily bench and software validation. The "sample size" would refer to the number of units tested, which is not specified, but implied to be sufficient for type testing.
- Data Provenance: The data refers to the results of internal bench tests and software validation activities, conducted by the manufacturer (inomed Medizintechnik GmbH) in Germany. It is entirely retrospective in the sense that it's performed on a developed product to meet predefined standards.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts
- This information is not provided because no clinical test set with expert-established ground truth was used. The ground truth for functional verification would be the expected output or behavior according to engineering specifications and regulatory standards.
4. Adjudication Method for the Test Set
- Not applicable as there was no clinical test set requiring expert adjudication.
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 comparative effectiveness study was done. The device is a neuromonitoring system, not an AI-assisted diagnostic or interpretive tool that would inherently involve "human readers" in that sense. The submission explicitly states: "No additional clinical testing was performed".
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- The document implies that the "software validation" and "bench testing" constitutes a standalone performance evaluation of the device's functional integrity as an algorithm/system. The software (NeuroExplorer) and hardware components were tested to ensure they meet their predetermined specifications and comply with relevant standards independently of human interpretation of clinical outcomes. However, this is not an "AI algorithm only" type of standalone performance, but rather functional performance of medical device software/hardware.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- For the bench and software testing, the "ground truth" would be established by the engineering specifications, international performance standards (e.g., IEC 60601 series), and documented functional requirements of the device. This is a technical (rather than clinical/biological) ground truth.
8. The sample size for the training set
- This device is not described as an AI/ML device that requires a "training set" in the context of machine learning model development. Therefore, this question is not applicable. The software development follows a traditional software lifecycle process, not a machine learning training paradigm.
9. How the ground truth for the training set was established
- Not applicable, as there is no mention of an AI/ML training set.
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(182 days)
GWF
The Guardian with Cascade Surgical Studio software is an electroneurodiagnostic device that acquires, displays, and stores physiologic data from peripheral sensory and motor nerves, muscles, and the central nervous system, generated either spontaneously or elicited by stimuli.
Guardian can perform somatosensory, auditory, and visual evoked potentials (EPs), electroencephalography (EEG), electrocorticography (ECoG), spontaneous and triggered electromyography (EMG), transcranial motor evoked potentials (TcMEP), direct cortical stimulation (DCS), direct nerve stimulation (TEMG, DNS), nerve conduction studies (NCS), and Train of Four (TOF) analysis.
Guardian can provide remote review outside of the operating room.
Guardian is used by or under the direction of a licensed physician, surgeon, or neurologist in a professional healthcare facility environment for pre-operative, intraoperative and post-operative testing.
The following functions are specifically supported individually or in combination:
Evoked Potentials (EPs): Guardian can provide electrical, auditory, and visual stimulation and measure, display, record, and store the electrical activity of the nervous system in response to the stimulations delivered.
Electroencephalography (EEG): Guardian can measure, display, record, and store electrical activity of the brain from two or more electrodes on the scalp.
Electrocorticography (ECoG): Guardian can measure, display, record, and store electrical activity directly from the brain using two or more electrodes.
Free Run Electromyography (EMG): Guardian can acquire, display, record, and store EMG activity of motor nerves.
Triggered Electromyography (TEMG): Guardian can electrically stimulate motor nerves, and display, record, and store the results.
Transcranial Motor Evoked Potentials (TcMEP): Guardian can deliver electrical transcranial stimulation, and display, record, and store the results.
Direct Cortical Stimulation (DCS): Guardian can deliver electrical stimulation to various areas of the cerebral cortex, and display, record, and store the results.
Direct Nerve Stimulation (DNS): Guardian can electrically stimulate cranial and peripheral nerves, and display, record, and store the results.
Nerve Conduction Study (NCS): Guardian can measure, display, record, and store sensory and motor nerve conduction time (latency) by applying a stimulus to peripheral nerves, the spinal cord, and the central nervous system.
Train of Four (TOF): Guardian can deliver a train of four pulses, and measure, display, record, and store the results.
The Cadwell Guardian is a multi-modality intraoperative neurophysiological monitoring system with up to 80 channels of data acquisition.
The Guardian system is designed to be flexible and scalable depending on customer and procedural requirements. All systems require a Power Comm and Guardian Base, which contains an electrical Transcranial Stimulator. The user may select up to two Omni Amplifiers, two ES-10 electrical stimulators, one AVX auditory and visual stimulator, and one SMX-32 EEG amplifier that contains a low current electrical stimulator, in order to meet specific requirements.
The Guardian requires a (PC) with Windows operating system. The Guardian system uses a new version (4.0) of previously cleared Cadwell Cascade Surgical Studio software. Surgical Studio acquires, stores and reviews a wide range of intraoperative neurophysiological data, such as EMG, EEG, SSEP, BAEP, VEP, MEP and TOF, and includes Report Generation.
The provided text describes the Cadwell Guardian device, its indications for use, and a comparison to predicate devices, but it does not contain information about specific acceptance criteria or a study proving the device meets those criteria with quantitative performance metrics (like sensitivity, specificity, or accuracy) derived from a test set of data.
The document states:
- "Performance Testing: The Cadwell Guardian was tested in accordance with internal software requirements, system requirements, and usability requirements. Test results indicate that the Cadwell Guardian complies with its predetermined specifications."
- "Conclusion: Verification and validation activities were conducted to establish the performance and safety characteristics of the Cadwell Guardian. The results of these activities demonstrate that the Cadwell Guardian is as safe, as effective, and performs as well as the predicate devices. Therefore, the Cadwell Guardian is considered substantially equivalent to the predicate devices."
This indicates that internal performance testing was conducted, and the device met its specifications, leading to a determination of substantial equivalence to predicate devices. However, the details of these "predetermined specifications" or "internal software requirements" in terms of specific performance metrics are not provided in the given text. There's no mention of a clinical study or a study involving a "test set" of data for algorithm performance, human reader performance, or ground truth establishment in the way typically expected for AI/CADe device submissions.
Therefore, I cannot populate the requested tables and sections with quantitative data from the provided text. The document focuses on regulatory approval through substantial equivalence based on technical characteristics and safety standards rather than a detailed performance study against specific acceptance criteria for an AI component.
Summary of missing information based on the request:
- Table of acceptance criteria and reported device performance: Not provided. The document states "complies with its predetermined specifications" but does not detail these specifications or measured performance.
- Sample size used for the test set and data provenance: No information on a specific "test set" for performance evaluation, nor its size, origin (country), or whether it was retrospective/prospective.
- Number of experts used to establish ground truth & qualifications: Not applicable, as there's no mention of a ground truth establishment process for a test set.
- Adjudication method: Not applicable.
- Multi-reader multi-case (MRMC) comparative effectiveness study: Not mentioned. The approval is based on substantial equivalence to existing devices, not a comparative effectiveness study involving human readers with/without AI assistance.
- Standalone (algorithm only) performance: Not mentioned, as the device is an electroneurodiagnostic system, not a standalone AI algorithm for interpretation.
- Type of ground truth used: Not applicable, as no external ground truth establishment is described for performance evaluation.
- Sample size for the training set: Not applicable, as the document doesn't describe an AI/ML component with a training set. The software is noted as "a new version (4.0) of previously cleared Cadwell Cascade Surgical Studio software."
- How ground truth for the training set was established: Not applicable.
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(89 days)
GWF
The SafeOp 2: Neural Informatix System is intended for use in monitoring neurological status by recording somatosensory evoked potentials (SSEP), electromyography (EMG), or assessing the neuromuscular junction (NMJ). Neuromonitoring procedures include intracranial, intratemporal, extratemporal, neck dissections, upper and lower extremities, spinal degenerative treatments, pedicle screw fixation, intervertebral fusion cages, rhizotomy, orthopedic surgery, open/percutaneous, lumbar, thoracic, and cervical surgical procedures.
The SafeOp™ 2: Neural Informatix System (SafeOp 2 System), formerly known as EPAD 2 (K182542), consists of the SafeOp head unit with power supply and IV pole mount, the Alpha Informatix Tablet with docking station and power supply and a data transfer USB cable. Associated disposable accessories consists of an electrode harness, surface and/or subdermal needle electrodes, and stimulating probe or clip contained in various kits. The SafeOp 2 System head unit contains a complete data acquisition system that has builtin stimulators, amplifiers, relays, A/D Converters, Digital Signal Processors, CPUs, and storage devices. The head unit interfaces with other equipment through communication ports and serves as the patient-contacting portion of the system where it is close to the surgical field. The head unit hardware contains an eight acquisition (input) channel and six-output channel Evoked Potential Stimulator that is used in the operating room to display nerve and muscle responses. The user can use these responses to diagnose insults to the peripheral or central nerves and to determine relative nerve location, proximity, and integrity data. The SafeOp 2 System application provides the primary graphical user interface and controls for the SafeOp 2 System. The application runs on a touchscreen tablet mobile device which connects to the head unit either via wired USB cable or wireless via Wi-Fi, enabling both user input (e.g., patient and procedure information, adjustment of stimulus and acquisition parameters) and display of output (e.g., display of acquired waveforms, data, messages and alerts to the clinician).
The provided text is a 510(k) summary for the SafeOp 2: Neural Informatix System. It primarily focuses on demonstrating substantial equivalence to a predicate device (EPAD™ 2 System, K182542) rather than presenting a detailed study proving the device meets specific acceptance criteria based on clinical performance.
Here's a breakdown of the requested information based on the provided text:
1. Table of acceptance criteria and the reported device performance
The document does not explicitly state quantitative "acceptance criteria" and "reported device performance" in the typical sense of a clinical study measuring diagnostic accuracy or treatment efficacy. Instead, it demonstrates "substantial equivalence" to a predicate device by comparing various specifications. The "acceptance criteria" for this submission would broadly be that the device's specifications and performance are comparable to the predicate, with any differences not introducing new safety or effectiveness concerns.
Specification/Property | Predicate Device (EPAD™ 2 System, K182542) | Subject Device (SafeOp™ 2 System) | Performance/Rationale |
---|---|---|---|
Intended Use/Indications for Use | Identical | Identical | Identical |
Device Class | II | II | Identical |
Product Code | GWF, GXY, GXZ, IKN, PDQ, ETN | GWF, GXY, GXZ, IKN, PDQ, ETN | Identical |
Regulation Number | §882.1870, §882.1320, §882.1350, §890.1375, §874.1820, §874.1820 | §882.1870, §882.1320, §882.1350, §890.1375, §874.1820, §874.1820 | Identical |
Device Classification Name | Stimulator, Electrical, Evoked Response | Stimulator, Electrical, Evoked Response | Identical |
Monitoring Modalities | EMG, SSEP, NMJ | EMG, SSEP, NMJ | Identical |
Head Unit Power Supply | 100 to 240 VAC, 50-60 Hz (input); 15 VDC, 2.5A (output) | 100 to 240 VAC, 50-60 Hz (input); 12 VDC, 2.5A (output) | Head unit power supply does not impact device performance when compared to the predicate. The change in power does not introduce new risks, or impact existing risks. Therefore, this difference does not affect device safety or effectiveness. |
Mode of Operation | Continuous | Continuous | Identical |
Dimensions | 12"W x 8"H x 2"D | 12"W x 8"H x 2"D | Identical |
Weight | 50 MΩ (at DC) | > 50 MΩ (at DC) | Identical |
Low Frequency Filter | 10 Hz (SSEP), 30 Hz (EMG) | 10 Hz (SSEP), 30 Hz (EMG) | Identical |
High Frequency Filter | 2.7 kHz (SSEP & EMG) | 2.7 kHz (SSEP & EMG) | Identical |
Notch Filter | 50 or 60 Hz | 50 or 60 Hz | Identical |
AlphaInformatix (AIX) Tablet OS | Android powered tablet | Windows 10 powered tablet | Completed V&V testing successfully demonstrates that the differences in the Operating Systems (OS) have no impact on device performance when compared to the predicate. The OS change does not introduce new risks, or impact existing risks. Therefore, this difference does not affect device safety or effectiveness. |
Remote Access | No | No | Identical |
Surface Electrode Anatomical Sites | SSEP: Upper/lower limbs and head/neck | SSEP: Upper/lower limbs and head/neck | Identical |
Surface Electrode Type | Customer cutaneous electrodes for use with SafeOp only. Single, double and triple electrodes. | Customer cutaneous electrodes for use with SafeOp only. Single, double and triple electrodes. | Identical |
Conductive Surface Area | 20x25mm | 25.4x25.4mm (1x1in.) | Completed V&V testing successfully demonstrates that the differences in the surface area has no impact on device performance when compared to the predicate. The change does not introduce new risks, or impact existing risks. Therefore, this difference does not affect device safety or effectiveness. |
Conductive Gel | Wet gel | Solid gel | Completed V&V testing successfully demonstrates that the differences in the conductive gel has no impact on device performance when compared to the predicate. The change does not introduce new risks, or impact existing risks. Therefore, this difference does not affect device safety or effectiveness. |
Connectors | Nicomatic three pin | Nicomatic three pin | Identical |
Current Density |
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(179 days)
GWF
ISIS Headbox 5042xx products:
The products are intended for intraoperative neuromonitoring; for recording of electrophysiological signals and stimulating of nerve and muscle tissues.
The products are intended for use in the operating room to measure and display the electrical signals generated by muscle, peripheral nerves and the central nervous system. The products support the clinical application of Electroencephalography (EEG), Electromyography (EMG), Somatosensory Evoked Potentials (SEP), Motor Evoked Potentials (MEP), and Auditory Evoked Potentials (AEP).
The products are not intended for monitoring life-sustaining functions.
ISIS Neurostimulator 504180:
The ISIS Neurostimulator is intended for provision of neurophysiological stimulation when used in surgical procedures and for diagnostics. It is suitable for continuous operation and can be used in the following fields:
- Transcranial electrical stimulation (TES)
- Direct cortical stimulation (DCS)
- Direct nerve stimulation (DNS)
- Transcutaneous electrical nerve stimulation (TNS)
- Direct muscle stimulation (DMS)
The ISIS Headboxes and the ISIS Neurostimulator constitute multimodality intraoperative neuromonitoring systems called ISIS IOM Systems. These systems consist of custom stimulation and recording hardware, a standard laptop or desktop personal computer running an off-the-shelf operating system, and operating software called NeuroExplorer. As an option, these systems mount on device carriers or housings tailored for intraoperative use.
The ISIS IOM Systems support the following measurement modalities:
- Auditory Evoked Potentials
- Transcranial and cortical Motor Evoked Potentials
- Somatosensory Evoked Potentials
- Freerunning and triggered Electromyography
- Electroencephalography
- Train of Four
The provided text describes a 510(k) summary for the Inomed Medizintechnik GmbH's "ISIS Headboxes and ISIS Neurostimulator" (ISIS IOM Systems: ISIS Xpert®, ISIS Xpert®Plus, ISIS Xpress). This document is a premarket notification to the FDA to demonstrate substantial equivalence to a legally marketed predicate device (Cadwell Industries Inc./Cascade Intraoperative Monitor K162199).
Crucially, this document does not contain acceptance criteria or a study proving device performance in the way a clinical study for a new diagnostic or AI-driven imaging device would. Instead, it focuses on demonstrating substantial equivalence to a predicate device through engineering performance testing (bench testing, electrical safety, EMC, software validation) and a comparison of technical specifications and intended uses.
Therefore, I cannot populate all sections of your requested table and provide information on aspects like sample size for test sets, ground truth establishment, expert adjudication, or MRMC studies, as these types of studies were explicitly not performed for this 510(k) submission. The document states: "No additional clinical testing was performed for the ISIS Headboxes and ISIS Neurostimulator... Therefore, this section does not apply."
Here's the information that can be extracted relevant to your request:
1. Table of Acceptance Criteria and Reported Device Performance
Since this is a substantial equivalence submission relying on engineering performance and comparison to a predicate, the "acceptance criteria" are primarily adherence to relevant electrical safety and electromagnetic compatibility (EMC) standards, and meeting predetermined specifications during bench testing and software validation. The "reported device performance" is the successful compliance with these standards and specifications.
Acceptance Criteria Type | Specific Criteria / Standard | Reported Device Performance | Notes |
---|---|---|---|
Software Validation | - Compliance with predetermined specifications. |
- Adherence to FDA guidance: "The content of premarket submissions for software contained in medical devices, May 11, 2005"
- Adherence to FDA guidance: "Off-the-shelf software use in medical devices, Sep 27, 2019"
- Adherence to FDA guidance: "General principles of software validation: Final guidance for industry and FDA staff, Jan 02, 2002"
- Adherence to FDA guidance: "Content of premarket submissions for management of cybersecurity in medical devices. Oct 02, 2014"
- Adherence to IEC 62304:2006, Medical device software - Software life cycle processes | "Test results demonstrate that the inomed NeuroExplorer Software complies with its predetermined specifications, the applicable guidance documents, and standards." | The software ("NeuroExplorer") is categorized as a "MODERATE level of concern software." |
| Electrical Safety | - Compliance with IEC 60601-1:2005 (Third Edition) + CORR. 1:2006 + CORR. 2:2007 + A1:2012 (or IEC 60601-1: 2012 reprint). - Compliance with IEC 80601-2-26:2019 (electroencephalographs).
- Compliance with IEC 60601-2-40:2016 (electromyographs and evoked response equipment). | "Test results demonstrate that the products comply with the applicable standards." | The document compares specific technical aspects like A/D resolution, hardware bandpass, sampling frequency, notch filter, CMRR, and amplifier noise to the predicate device, indicating equivalent or compliant performance with relevant standards. |
| Electromagnetic Compatibility (EMC) | - Compliance with IEC 60601-1-2:2014. | "Test results demonstrate that the products comply with the applicable standards." | |
| Bench/Performance Testing | - Fulfillment of requirements formulated at multiple levels: electrical medical systems, system carrier, amplifier (Headboxes) and stimulator (Neurostimulator) modules, operating software (NeuroExplorer) incl. firmware, and accessories. - Assessment of human factors influence on safety. | "The products successfully underwent the bench testing to confirm the fulfillment of the requirements at these levels as part of the verification and validation process."
"The testing of the influence of human factors on the devices demonstrates that the products are safe to use and that no further improvement of the user interface design relating to safety is necessary." | This testing is internal to the manufacturer's verification and validation process. The specific quantitative "requirements" are not detailed in this public summary but are typically part of internal design specifications. |
| Biocompatibility | N/A | N/A | The devices do not have patient contact materials, therefore testing was not applicable. |
2. Sample Size Used for the Test Set and the Data Provenance
This information is not applicable and not provided in the document. As stated, "No additional clinical testing was performed for the ISIS Headboxes and ISIS Neurostimulator... Therefore, this section does not apply." The testing described are engineering verification and validation tests, not clinical studies with patients or data sets in the typical sense for AI/diagnostic devices.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts
This information is not applicable. The performance testing was based on engineering standards and internal requirements, not expert-established ground truth from clinical data.
4. Adjudication Method for the Test Set
This information is not applicable. There was no clinical test set requiring adjudication in the context of this 510(k) submission.
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 comparative effectiveness study was done. This device is an intraoperative neuromonitoring system, not an AI-assisted diagnostic tool that would typically involve human readers interpreting AI output.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This information is not applicable. This device is an intraoperative neuromonitoring system, not primarily an algorithm performing a standalone diagnostic task. Its function is to measure and display electrophysiological signals and provide stimulation.
7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.)
The ground truth or reference for device performance was established through engineering standards, technical specifications, and internal functional requirements. For example, electrical outputs meet specified ranges, and input signals are recorded with specified fidelity according to IEC standards. This is not clinical ground truth (e.g., pathology report, expert diagnosis).
8. The Sample Size for the Training Set
This information is not applicable. The document does not describe the use of an AI algorithm that requires a training set in the context of a machine learning model for diagnosis or interpretation. The software validation refers to standard software development practices, not AI model training.
9. How the Ground Truth for the Training Set Was Established
This information is not applicable, as there was no mention of a training set for an AI algorithm.
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(681 days)
GWF
Stimulation of peripheral nerves for diagnostic purposes.
The MEGA-TMS is intended for stimulation of peripheral nerves for diagnostic purposes. The device introduces electrical stimulation to tissue through magnetic induction generated from the coil. The obtained responses of stimulated structures is recorded with an EMG system for further diagnostic evaluation. The MEGA-TMS device is intended to be paired with a Focus EMG device cleared under FDA 510(k): K102610. Magnetic stimulation is used for peripheral nerve conduction studies and to evaluate peripheral nervous system.
The provided text is a 510(k) summary for the MEGA-TMS device, which is an evoked response electrical stimulator used for diagnostic purposes. It primarily focuses on demonstrating substantial equivalence to predicate devices and does not describe a study to establish acceptance criteria for an AI/CADe device's performance.
Therefore, I cannot extract the requested information regarding AI/CADe acceptance criteria or the study proving a device meets them. The document mentions performance testing, but this refers to safety, EMC, design verification, and risk management for the electrical stimulator, not an AI or CADe system.
The closest relevant information, though not directly applicable to an AI device's performance, is under "Electric and Magnetic Field Characteristics," where measurements and simulations were performed for electric and magnetic fields. However, this pertains to the physical and electrical characteristics of the stimulator itself, not the diagnostic performance of an AI.
To directly answer your request based on the provided text, the document does not contain the specific information you are looking for regarding acceptance criteria and a study proving an AI/CADe device meets those criteria.
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