K133355 · Cadwell Industries, Inc. · GWQ · Jan 29, 2014 · Neurology
Device Facts
Record ID
K133355
Device Name
CADWELL FLEX EEG/PSG
Applicant
Cadwell Industries, Inc.
Product Code
GWQ · Neurology
Decision Date
Jan 29, 2014
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 882.1400
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The Cadwell Flex system is indicated for prescription use to acquire, record, transmit and display physiological and environmental data for electroencephalographic (EEG) and polysomnographic (PSG) ambulatory and/or clinical studies of patients of all ages.
Device Story
Cadwell Flex is an EEG/PSG system for physiological and environmental data acquisition. Input includes up to 32 channels of EEG data, 8 active-reference signals, and microphone audio. System operates in two modes: Ambulatory (onboard non-volatile memory storage) and Clinical (real-time host PC connection). Optional components include video recording and photic stimulator. Host PC runs software to acquire, store, transmit, view, print data, and generate reports. Healthcare providers use output for EEG/PSG waveform analysis to support clinical decision-making. Device is intended for hospital or home use, operated by trained personnel.
Clinical Evidence
No clinical data provided. Substantial equivalence is supported by bench testing, including software and hardware verification and validation, and electromagnetic compatibility and safety testing.
Technological Characteristics
System includes acquisition hardware and host PC software. Features 32 EEG channels, 8 active-reference inputs, and 2 additional inputs. Sampling rate 3200 Hz; 16-bit A/D resolution. Connectivity via USB or onboard non-volatile memory. Power via battery or USB. Includes impedance check functionality. Software supports data acquisition, storage, transmission, viewing, printing, and report generation.
Indications for Use
Indicated for prescription use in patients of all ages requiring EEG or PSG ambulatory or clinical studies.
Regulatory Classification
Identification
An electroencephalograph is a device used to measure and record the electrical activity of the patient's brain obtained by placing two or more electrodes on the head.
{0}------------------------------------------------
K133356 JAN 2 9 2014
:
.
| Submitter: | Cadwell<br>909 N. Kellogg Street<br>Kennewick, Washington 99336<br>509-735-6481 |
|----------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | John Cadwell Jr<br>Electrical Engineer<br>Cadwell Laboratories, Inc. |
| Date Prepared: | October 31, 2013 |
| Trade Name: | Cadwell Flex |
| Regulation Name: | Electroencephalograph, Evoked Response Photic<br>Stimulator, Physiological Signal Amplifier |
| Regulation Number: | 21 CFR 882.1400, 21 CFR 882.1890, 21 CFR 882.1835 |
| Regulatory Classification: | Class II |
| Product Code: | GWQ, OMC, OLV, GWL, OLT, GWE, GWL |
| Classification Panel: | Neurological |
| Predicate Devices: | EB Neuro BE micro Trea (K093728)<br>Cadwell Kilowin (K971214) |
| Device Description: | The Cadwell Flex EEG/PSG system consists of: (1)<br>acquisition hardware that can acquire, record, store, and<br>transfer up to 32 channels of EEG data, 8 active-reference<br>signal, and audio signals from a microphone, and has<br>EzNet-module-compatibility, (2).software_that_allows_a_user<br>to acquire, store, transmit, view and print data, and to create<br>reports based on the data, (3) optional video recording, (4)<br>an optional photic stimulator, and (5) a host electronic<br>device (typically a PC) capable of running the software and<br>interfacing with the acquisition, video recording, and photic<br>stimulation devices.<br><br>The Cadwell Flex EEG/PSG system is capable of two<br>modes of operation: (1) Ambulatory, where the acquisition<br>hardware acquires, records, and stores physiological and/or |
Section 05: 510K Summary
・・.
Page I of 3
{1}------------------------------------------------
## 510k Summary
environmental data to onboard mass-storage non-volatile memory, and said data is later transferred to a host electronic device, and (2) Clinical, where the host electronic device is connected to the acquisition hardware during data acquisition and recording, with mass-storage occurring on the host.
The Cadwell Flex EEG/PSG system software is capable of interfacing with additional software used to perform EEG/PSG waveform analysis.
Indications for Use: The Cadwell Flex system is indicated Indications for Use: for prescription use to acquire, record, transmit and display physiological and environmental data for electroencephalographic (EEG) and polysomnographic (PSG) ambulatory and/or clinical studies of patients of all ages.
### Substantial Equivalence:
Using the characteristics shown in the following table, the Cadwell Flex is shown to be substantially equivalent to the referenced predicate devices.
| Product | EBNeuro<br>BEmicro | Kilowin | Cadwell Flex |
|---------------------------|--------------------------------------------------|----------------------------------------------|-----------------------------------|
| 510K | K093728 | K97214 | TBD |
| Device class | Class II | Class II | Class II |
| Product Codes | OLV, GWQ, GWL,<br>MNR, DQA | GWE, GWF, GWJ,<br>GWQ, IKN, JXE, OLT,<br>OLV | GWQ, OLV, GWL, OLT,<br>GWE |
| Target Population | Pediatric through<br>adult | Patients of all ages | Patients of all ages |
| Recording<br>Modality | Attended and<br>unattended | Attended | Attended or unattended |
| Use Environment | Hospital and home | Operating room or clinic | Hospital or home |
| Prescription<br>Status | Available only on<br>the order of a<br>physician | By prescription only | By prescription only |
| Power | Battery powered or<br>USB powered | AC power | Battery powered or USB<br>powered |
| Number of EEG<br>Channels | 21 | 24-64 | 32 |
| Other Inputs | 1 digital | 12 ECG and 1-16 EMG | 8 active/reference, 2<br>other |
| A/D Resolution | 16 bit | 16 bit | 16 bit |
| Sampling Rate | Up to 2048<br>samples/s | 3200 Hz | 3200 Hz |
| Impedance Check | Yes | Yes | Yes |
Section 05: 510K Summary
Page 2 of 3
{2}------------------------------------------------
Image /page/2/Picture/0 description: The image shows the word "CADWELL" in a stylized font. The "C" is replaced with a circle containing a symbol resembling a heartbeat. The letters are bold and have a textured appearance, giving them a slightly rough or grainy look. The overall design is simple yet distinctive, likely representing a brand or company name.
# 510k Summary
Testing:
Conclusion:
Software and hardware verification and validation, and clectromagnetic compatibility and safety testing were performed.
The Cadwell Flex system is substantially equivalent to The Cativen Tres in design, use, technology, and function.
Section 05: 510K Summary
Page 3 of 3
{3}------------------------------------------------
DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo consists of a stylized caduceus symbol, which is a staff with two snakes coiled around it, placed within a circle. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged around the circumference of the circle. The logo is presented in black and white.
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
January 29, 2014
Cadwell Laboratories c/o Mr. John Cadwell Jr. 909 N. Kellogg Street Kennewick, WA 99336
Re: K133355
Trade/Device Name: Cadwell Flex Regulation Number: 21 CFR 882.1400 Regulation Name: Electroencephalogram Regulatory Class: Class II Product Code: GWQ, OMC, OLV, GWL, OLT, GWE Dated: October 13, 2013 Received: October 13, 2013
Dear Mr. Cadwell:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration. Iisting of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set
{4}------------------------------------------------
Page 2 - Mr. John Cadwell Jr.
forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportalProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours.
Carlos L. Pena -S
Carlos L. Peña, Ph.D., M.S. Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
{5}------------------------------------------------
#### DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
#### Indications for Use
Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement on last page.
#### 510(k) Number (if known) K133355
#### Device Name Cadwell Flex
#### Indications for Use (Describe)
The Cadwell Flex system is indicated for prescription use to acquire, record, transmit and environmental data for electroencephalographic (EEG) and polysomnographic (PSG) ambulatory and/or clinical studies of all ages.
#### Type of Use (Select one or both, as applicable) .
X Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
#### PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.
#### FOR FDA USE ONLY
Concurrence of Center for Devices and Radiological Health (CDRH) (Signalure)
Carlos L. Pena -S
{6}------------------------------------------------
This section applies only to requirements of the Paperwork Reduction Act of 1995.
### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW."
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
> Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov
"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."
.
Predicate graph will load when search results are available.
Embedding visualization will load when search results are available.
PDF viewer will load when search results are available.
Loading panels...
Select an item from Submissions
Click any panel, subpart, regulation, product code, or device to see details here.
Section Matches
Results will appear here.
Product Code Matches
Results will appear here.
Special Control Matches
Results will appear here.
Loading collections...
Loading
My Alerts
You will receive email notifications based on the filters and frequency you set for each alert.
Sort by:
Create Alert
Search Filters
Agent Token
Create a read-only bearer token for Claude, ChatGPT, or other agents that can call HTTP APIs.
Copy this now. It will not be shown again.
Connected apps
Apps you authorized through browser sign-in. Disconnecting revokes their access immediately.
Learn the FDA Browser
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.