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510(k) Data Aggregation
(135 days)
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.
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.
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)
| Parameter | Acceptance Criteria (Predicate Device: Nicolet Viking II K890495) | Reported SmartEP Performance (Device Under Review) |
|---|---|---|
| Intended Use | SEP: Stimulate, record, and process somatosensory evoked potentials. VEP: Stimulate, record, and process visual evoked potentials. | Same |
| Indications for Use | Recording and analysis of physiological data necessary for the diagnosis of somatosensory and visual related disorders. | Same |
| Target Population | All Ages | Same |
| Design | External 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). |
| Materials | Assorted 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. |
| Sterility | None Required | Same |
| Biocompatibility | Completely Biocompatible | Same (specifically for SEP Stimulator Probe: Type-302 stainless steel, meets ISO-10993) |
| Anatomical Sites | SEP: Upper/lower limbs and head. VEP: Scalp. | Same |
| Energy Delivery | SEP: Stimulation of upper or lower limbs with surface electrical signals. VEP: Stimulation of eyes with visual light patterns. | Same |
| Where Used | Clinical Setting | Same |
| Safety | Conforms to UL544 & IEC 60601-1 | Meets EN 60601-1 |
| Patient Isolation | Type 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 - Type | Constant Current or Voltage | Constant Current |
| Somatosensory Stimuli - Current Levels | 0 - 100 mA, 0 - 400V (into 4000 Ohms load) | 0 - 100 mA (400 Volt maximum) (into 4000 Ohms load) |
| Visual Stimuli - Output Illumination | None Specified | Red LED Light (Class I AEL Level), Peak Wavelength: 625 nm, Max Accessible Power: < 0.43 microWatts (at 30cm) |
| Visual Stimuli - Repetition Rate | 0.1 - 30 Hz | 0.1 - 100 Hz |
Table 2: Acceptance Criteria and Reported Device Performance for Nerve Stimulation/Monitoring (Summarized from Table E-2)
| Parameter | Acceptance Criteria (Predicate Device: NIM-Response K982595) | Reported SmartEP Performance (Device Under Review) |
|---|---|---|
| Intended Use | Stimulate, record, and process evoked nerve responses. | Same |
| Indications for Use | Nerve stimulation & monitoring. | Same |
| Target Population | All Ages | Same |
| Design | Main 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). |
| Sterility | Requires 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). |
| Biocompatibility | Completely Biocompatible (meeting ISO-10993 for soft tissue contact). | Same |
| Anatomical Sites | Patient's exposed nerve/soft tissue, intramuscular, subdermal, skin, scalp, and possibly other body sites. | Same |
| Energy Delivery | Stimulation of exposed nerve tissue with low-current electrical signals. | Same |
| Where Used | Intra-Operative/Surgical Setting. | Same |
| Safety | Complies with IEC 60601-1, UL2601-1, CSA22.2 No.601, AS3200. | Complies with EN 60601-1. |
| Patient Isolation | Type 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 - Type | Constant Current, Pulsed. | Same |
| Nerve Stimuli - Shape | Monophasic 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 Rate | 1, 4, 7, & 10 Hz. | 1 - 10 Hz. (Note: Wider range described for SmartEP, functionally equivalent). |
| Nerve Stimuli - Current Levels | 0 - 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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(226 days)
The subject monitor detects bioelectrical signals from muscles for the purpose of guiding injections into the muscles identified. Although the monitor is indicated for guidance of any muscle-specific injection, it is typically used for injections into muscles of the head and neck. This includes botulinum toxin injections of facial and laryngeal muscles.
The subject monitor is intended to detect bioelectrical signals from muscles for the subject monitor in intentions into the muscles identified, including botulinum toxin injections of eye muscles.
The proposed EMG monitoring system is composed of a small, handheld monitor, a reusable patient interface cable and a disposable injector needle electrode. Commercially available surface electrodes, to act as references, may elcotrode. Onlinerally aranabitropoposed system as these are readily available or may not be provided with the proposed keys on the front console -- ON/OFF, at the politic of the of Check, Volume Down, and Mute. The software of the proposed EMG monitoring system interprets console key presses from the user and performs the action associated with that key.
The provided text is a 510(k) summary for the XOMED® AccuGuide Muscle Injection Monitor. As a 510(k) submission, the primary goal is to demonstrate substantial equivalence to a predicate device, not necessarily to prove absolute performance against predefined acceptance criteria from novel studies. Therefore, the information provided focuses on comparing the new device to existing, legally marketed devices.
Based on the document, here's a breakdown of the requested information, with specific answers where available and explanations where information is not present in the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The 510(k) submission does not present specific quantitative acceptance criteria or a dedicated performance study with a table of results. Instead, it relies on demonstrating that the proposed device, the AccuGuide, is substantially equivalent to a predicate device (Allergan BOTOX® Injection Amplifier) in terms of intended use, technology, and safety/effectiveness. This means it's assumed to meet the same unstated performance benchmarks as the predicate.
For the purpose of this request, we can infer the "acceptance criteria" and "reported performance" are met if the device is deemed substantially equivalent to the predicate.
| Acceptance Criteria (Inferred from Substantial Equivalence to Predicate) | Reported Device Performance (as implied by 510(k)) |
|---|---|
| Detect bioelectrical signals from muscles | The AccuGuide system uses "identical injection needle electrodes to pick-up EMG from the target muscle" as the predicate. |
| Guide injections into muscles identified | Both the AccuGuide and predicate "transform the EMG signal into an audible response." The AccuGuide also provides a "visible response via an LCD bargraph display." The presence of an appropriate EMG response, in conjunction with a specific muscle movement, confirms the location. |
| Be safe and effective for intended use (e.g., botulinum toxin injections) | The device's components and operating principles are sufficiently similar to the predicate that it would not raise new questions of safety or effectiveness. |
2. Sample Size Used for the Test Set and the Data Provenance
The provided 510(k) summary does not describe a specific "test set" or a performance study with a defined sample size for the AccuGuide device. The submission relies on a comparison to a predicate device and existing knowledge of EMG technology. Therefore:
- Sample Size for Test Set: Not applicable / Not provided.
- Data Provenance: Not applicable, as no specific test data set is described for the new device. The comparison is based on the known performance and characteristics of the predicate device (Allergan BOTOX® Injection Amplifier), which is a "currently marketed" device. This implies its performance is established from its prior marketing and regulatory clearance, which would have involved some form of testing, but details are not provided here for the predicate either.
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 in the 510(k) summary. Given that no specific test set or performance study is detailed for the AccuGuide, there is no mention of experts establishing a ground truth for such a study. The substantial equivalence argument relies on the established use and safety/effectiveness of the predicate device.
4. Adjudication Method for the Test Set
This information is not provided in the 510(k) summary. As there's no described test set or performance study, there's 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
- MRMC Study Done: No, an MRMC comparative effectiveness study was not conducted or reported in this 510(k) submission.
- AI Assistance: The device described is an EMG monitor, a hardware medical device that provides bioelectrical signal detection. It does not incorporate Artificial Intelligence (AI) for interpretation or assistance in the way current AI-driven diagnostic tools do. Therefore, the concept of "human readers improve with AI vs without AI assistance" is not applicable here.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Standalone Performance: Not applicable. The AccuGuide is a hardware device (EMG monitor) designed to provide real-time feedback (audible and visible through LCD bargraph) to a human user (clinician) to guide injections. It does not operate as a standalone "algorithm" generating diagnoses or interpretations without human involvement in the clinical context. Its function is to assist in real-time muscle localization during a procedure.
7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.)
Since no specific performance study is detailed, the type of ground truth for the AccuGuide's performance is not explicitly stated. However, the basis for its perceived "truth" or effectiveness stems from the functionality of its predicate device, the Allergan BOTOX® Injection Amplifier. The fundamental "ground truth" for these types of EMG monitors is the accurate detection of muscle electrical activity (bioelectrical signals) in the target muscle, confirmed by clinical observation (e.g., specific muscle movement in conjunction with the EMG response) and the subsequent successful and safe injection into that muscle, leading to the desired therapeutic outcome. This is a clinically established method for guiding precise injections.
8. The Sample Size for the Training Set
The provided 510(k) summary does not describe a "training set" for the AccuGuide. This device is a traditional hardware medical device, not a machine learning model that requires a training set in the conventional sense. The design and validation would have followed standard engineering and quality system processes, rather than machine learning training.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as no training set for a machine learning model is described for this device.
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