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510(k) Data Aggregation

    K Number
    K070608
    Date Cleared
    2007-07-18

    (135 days)

    Product Code
    Regulation Number
    882.1900
    Reference & Predicate Devices
    Predicate For
    Why did this record match?
    Reference Devices :

    K904926, K890495, K982595

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

    SmartEP is an evoked response testing and diagnostic device, that is capable of eliciting, acquiring, and measuring auditory, somatosensory, and visual evoked potential data, as well as providing nerve stimulation and monitoring.

    The intended use of the SmartEP device is to objectively record evoked responses from patients of all ages upon the presentation of sensory stimuli. The product is indicated for use as a diagnostic aid and adjunctive tool in sensory related disorders (i.e., auditory, somatosensory, visual) and in surgical procedures for inter-operative nerve monitoring.

    Device Description

    SmartEP is an evoked response system that is capable of eliciting, acquiring, and measuring auditory, somatosensory, and visual evoked potential data, as well as providing nerve stimulation/monitoring.
    The feature modifications described in this 510(k) are to incorporate additional/expanded indications to the SmartEP device for somatosensory evoked potential, visual evoked potential, and nerve stimulation testing to the previously FDA cleared indications for auditory evoked potential testing. Specifically, additional hardware and software features have been added to the original SmartEP device system to objectively acquire somatosensory/visual evoked potentials upon the presentation of a somatosensory/visual stimulus, and to provide nerve stimulation/monitoring functionality.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for the SmartEP device, seeking expanded indications for Somatosensory Evoked Potential (SEP), Visual Evoked Potential (VEP), and Nerve Stimulation/Monitoring. The core of the information regarding acceptance criteria and supporting studies is based on demonstrating substantial equivalence to predicate devices.

    Here's a breakdown of the requested information:


    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria are implicitly defined by the equivalence of key specifications and intended use to legally marketed predicate devices. The "reported device performance" is a demonstration that the SmartEP's characteristics meet or are comparable to those of the predicate devices. The tables provided (Table E-1 and Table E-2) serve as the primary evidence for this.

    Table 1: Acceptance Criteria and Reported Device Performance for SEP & VEP (Summarized from Table E-1)

    ParameterAcceptance Criteria (Predicate Device: Nicolet Viking II K890495)Reported SmartEP Performance (Device Under Review)
    Intended UseSEP: Stimulate, record, and process somatosensory evoked potentials. VEP: Stimulate, record, and process visual evoked potentials.Same
    Indications for UseRecording and analysis of physiological data necessary for the diagnosis of somatosensory and visual related disorders.Same
    Target PopulationAll AgesSame
    DesignExternal box housing circuitry connected to CPU via RS232 connection.External box housing circuitry connected to personal computer via a USB connection. (Note: This is a design difference, but implied functionally equivalent).
    MaterialsAssorted electrical components, circuit boards, SEP electrical stimulation box, SEP electrical stimulator probe, video monitor, and electrodes.Assorted electrical components, circuit boards, SEP electrical stimulation box, SEP electrical stimulator probe, visual stimulation LED array, and electrodes.
    SterilityNone RequiredSame
    BiocompatibilityCompletely BiocompatibleSame (specifically for SEP Stimulator Probe: Type-302 stainless steel, meets ISO-10993)
    Anatomical SitesSEP: Upper/lower limbs and head. VEP: Scalp.Same
    Energy DeliverySEP: Stimulation of upper or lower limbs with surface electrical signals. VEP: Stimulation of eyes with visual light patterns.Same
    Where UsedClinical SettingSame
    SafetyConforms to UL544 & IEC 60601-1Meets EN 60601-1
    Patient IsolationType BF (IEC 60601-1) (for data), Fiber Optic Signal Link.Type BF (IEC 60601-1) (for data), Fiber Optic Signal Link (for amp), Medical-grade power supplies, 4000Vdc, 10 MegaOhms (for power), 3500Vdc, 10 TeraOhms (for probe), Isolation transformers, Isolation amplifiers.
    Somatosensory Stimuli - TypeConstant Current or VoltageConstant Current
    Somatosensory Stimuli - Current Levels0 - 100 mA, 0 - 400V (into 4000 Ohms load)0 - 100 mA (400 Volt maximum) (into 4000 Ohms load)
    Visual Stimuli - Output IlluminationNone SpecifiedRed LED Light (Class I AEL Level), Peak Wavelength: 625 nm, Max Accessible Power: < 0.43 microWatts (at 30cm)
    Visual Stimuli - Repetition Rate0.1 - 30 Hz0.1 - 100 Hz

    Table 2: Acceptance Criteria and Reported Device Performance for Nerve Stimulation/Monitoring (Summarized from Table E-2)

    ParameterAcceptance Criteria (Predicate Device: NIM-Response K982595)Reported SmartEP Performance (Device Under Review)
    Intended UseStimulate, record, and process evoked nerve responses.Same
    Indications for UseNerve stimulation & monitoring.Same
    Target PopulationAll AgesSame
    DesignMain hardware receiver/monitor unit with touch-screen display (control test setup, monitoring, storage), connects to separate isolated Patient Interface Unit (input amplifier channels & output stimulator channels).External hardware receiver unit which connects to a separate isolated battery-powered Low-Current Stimulation Box for stimulation, a separate isolated bio-amplifier unit for acquisition, and a personal computer (via a USB connection) for test setup, processing, monitoring, and storage through software. (Note: Design difference, but claimed functionally equivalent).
    SterilityRequires use of sterile nerve stimulator probe (monopolar or bipolar) and sterile subdermal/needle electrodes for patient contact.Same (Nerve stimulator probe provided by outside vendor pre-packaged and sterile).
    BiocompatibilityCompletely Biocompatible (meeting ISO-10993 for soft tissue contact).Same
    Anatomical SitesPatient's exposed nerve/soft tissue, intramuscular, subdermal, skin, scalp, and possibly other body sites.Same
    Energy DeliveryStimulation of exposed nerve tissue with low-current electrical signals.Same
    Where UsedIntra-Operative/Surgical Setting.Same
    SafetyComplies with IEC 60601-1, UL2601-1, CSA22.2 No.601, AS3200.Complies with EN 60601-1.
    Patient IsolationType BF (IEC/EN 60601-1), 4000Vpp 60Hz dielectric withstand (power). Main Unit Fuse: TypeF 250V, 2-4 A. Stimulator Fuse: TypeF 250V, 32mA.Type BF (IEC 60601-1), 4000Vdc, 10 MegaOhms (power). Medical-grade power supply, Fiber Optic Signal Link (amplifier). Stimulator Fuse: 15.6 mA (1500ohm load impedance), Battery-powered stimulator, Isolation amplifier.
    Nerve Stimuli - TypeConstant Current, Pulsed.Same
    Nerve Stimuli - ShapeMonophasic pulses.Mono- or Biphasic pulses. (Note: This is a difference, but likely considered equivalent or enhanced functionality within the scope of intended use).
    Nerve Stimuli - Repetition Rate1, 4, 7, & 10 Hz.1 - 10 Hz. (Note: Wider range described for SmartEP, functionally equivalent).
    Nerve Stimuli - Current Levels0 - 3 mA (12 Volt maximum).0 - 5 mA (10 Volt maximum). (Note: Higher current range for SmartEP, within safety limits).

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

    The document does not report primary clinical data or a specific test set formed from human subjects for evaluating the performance of the SmartEP device with its expanded indications. Instead, the study relies on a comparative analysis of technical specifications and safety standards against legally marketed predicate devices.

    Therefore:

    • Sample size for test set: Not applicable, as performance was not demonstrated through a traditional clinical study with a test set of patient data.
    • Data provenance: Not applicable. The "data" used for comparison are the technical specifications and regulatory compliance of the predicate devices and the modified SmartEP.

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

    Not applicable. The ground truth, in this context, is the established safety and effectiveness profile of the predicate devices. This was determined by FDA clearance processes for those devices, not by new expert consensus for this 510(k). The current submission relies on the regulatory acceptance of the predicate devices as the benchmark for "ground truth" regarding safety and performance.


    4. Adjudication Method for the Test Set

    Not applicable, as no human subject test set or associated ground truth adjudication was performed as part 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

    Not applicable. This device is an evoked response testing and diagnostic system, not an AI-assisted diagnostic imaging or interpretation tool that would involve human readers or MRMC studies. Its function is to elicit, acquire, and measure physiological data, rather than interpret complex images or provide AI-driven assistance to human readers.


    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    Not applicable. This device is a measurement instrument; its "performance" is assessed by its ability to accurately measure physiological responses within specified technical parameters, not by an algorithm's standalone diagnostic accuracy in the absence of human operation or interpretation.


    7. The Type of Ground Truth Used

    The ground truth used is the established safety, performance, and regulatory compliance of legally marketed predicate devices. The SmartEP device demonstrates substantial equivalence by comparing its technical characteristics, intended use, indications for use, and safety features directly against those of the Nicolet Viking II (for SEP and VEP) and the Medtronic XOMED NIM-Response (for Nerve Stimulation/Monitoring).


    8. The Sample Size for the Training Set

    Not applicable. The device is not a machine learning or AI algorithm that requires a training set of data. Its development and modification process involved engineering design, verification, and validation against specified requirements and safety standards, rather than data-driven machine learning.


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

    Not applicable, as there is no training set for this device.

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