The Neurosign® V4 Intraoperative Nerve Monitor is intended for locating and identifying cranial and peripheral motor and mixed motor-sensory nerves during surgery, including spinal nerve roots.
Device Story
Neurosign V4 is a multi-channel intraoperative nerve monitor (IONM) used in ENT and neurosurgery. It collects EMG signals from muscles via needle or surface electrodes connected to a 4-channel or 8-channel pre-amplifier. The device detects muscle contractions resulting from mechanical manipulation or electrical stimulation of nerves. It amplifies these signals, providing audible feedback and visual waveform displays on a 15-inch color touchscreen. A stimulator pod allows surgeons to map and locate nerves during procedures. A mute sensor can silence audio during electrocautery interference. Operated by clinical staff in surgical environments, the device assists in nerve identification and preservation, potentially reducing the risk of iatrogenic nerve injury. The system includes hardware, software, and accessories.
Clinical Evidence
Bench testing only. Testing included electrical safety (IEC 60601-1), electromagnetic compatibility (IEC 60601-1-2), alarm systems (IEC 60601-1-8), and biocompatibility (ISO 10993-1, -5, -10). Usability/human factors testing (AAMI/ANSI HE75, IEC 62366-1) confirmed the safety and effectiveness of the 8-channel configuration. No clinical data was required or provided.
Technological Characteristics
Integrated system with 15-inch color touchscreen, rotary controls, and 4 or 8-channel pre-amplifier. Stimulator supports constant current (10µA–10mA) or constant voltage (10mV–10V) modes. Connectivity via electrode inputs. Compliant with IEC 60601-1, IEC 60601-1-2, and IEC 60601-1-8. Biocompatible materials per ISO 10993.
Indications for Use
Indicated for patients undergoing intracranial, extracranial, extratemporal, neck dissections, thoracic, and spinal surgeries (including degenerative treatments, pedicle screw procedures, fusion cages, rhizotomy, orthopedic, and open/percutaneous lumbar procedures) requiring cranial and peripheral motor and mixed motor-sensory nerve monitoring.
Regulatory Classification
Identification
A surgical nerve stimulator/locator is a device that is intended to provide electrical stimulation to the body to locate and identify nerves and to test their excitability.
Neurosign® Nerve Monitor, Model Neurosign® 400 and Neurosign® 800 (K053141)
Submission Summary (Full Text)
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April 1, 2021
Magstim Company Ltd. Tom Campbell Chief Quality & Regulatory Affairs Officer Spring Gardens Whitland, Carmarthenshire SA34 0HR United Kingdom
Re: K203684
Trade/Device Name: Neurosign V4 Intraoperative Nerve Monitor Regulation Number: 21 CFR 874.1820 Regulation Name: Surgical nerve stimulator/locator Regulatory Class: Class II Product Code: PDQ
Dear Tom Campbell:
The Food and Drug Administration (FDA) is sending this letter to notify you of an administrative change related to your previous substantial equivalence (SE) determination letter dated March 17, 2021. Specifically, FDA is updating this SE Letter due to typographical errors in the Indications for Use Statement as an administrative correction.
Please note that the 510(k) submission was not re-reviewed. For questions regarding this letter please contact Jay Gupta, OHT5: Office of Neurological and Physical Medicine Devices, Jay Gupta, 301-796-2795, jay.gupta@fda.hhs.gov.
Sincerely,
# Jay R. Gupta -S
Jay Gupta Assistant Director DHT5A: Division of Neurosurgical, Neurointerventional and Neurodiagnostic Devices OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
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March 17, 2021
Magstim Company Ltd. Tom Campbell Chief Quality & Regulatory Affairs Officer Spring Gardens Whitland, Carmarthenshire SA34 0HR United Kingdom
Re: K203684
Trade/Device Name: Neurosign V4 Intraoperative Nerve Monitor Regulation Number: 21 CFR 874.1820 Regulation Name: Surgical Nerve Stimulator/Locator Regulatory Class: Class II Product Code: PDQ Dated: December 17, 2020 Received: December 17, 2020
Dear Tom Campbell:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing 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
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801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4. Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
# Jay R. Gupta -S
Jay Gupta Assistant Director DHT5A: Division of Neurosurgical, Neurointerventional and Neurodiagnostic Devices OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K203684
Device Name Neurosign® V4 Intraoperative Nerve Monitor
Indications for Use (Describe)
The Neurosign® V4 Intraoperative Nerve Monitor is intended for locating and identifying cranial and peripheral motor and mixed motor-sensory nerves during surgery, including spinal nerve roots.
Indications for Neurosign® V4 EMG Monitoring Procedures include: Intracranial, Extracranial, Extratemporal, Neck Dissections, Thoracic Surgeries, and Upper and Lower Extremities.
Indications for spinal procedures which may use Neurosign® V4 EMG monitoring include: Degenerative Treatments, Pedicle Screw Procedures, Fusion Cages, Rhizotomy, Orthopedic Surgery and Open and Percutaneous Lumbar Procedures.
X Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
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# K203684 Traditional 510(k) SUMMARY Magstim's Neurosign® V4 Intraoperative Nerve Monitor
Prepared according to the requirements outlined in 21 CFR 807.92
#### Submitter's Name, Address, Telephone Number, Contact Person and Date Prepared
Magstim Company Limited Spring Gardens, Whitland, Carmarthenshire SA34 OHR, United Kingdom
Phone: +44 (0) 1994 240798 Facsimile: +44 (0) 1994 240061
Contact Person: Tom Campbell, Chief Quality & Regulatory Affairs Officer requlatory@magstim.com
Date Prepared: March 17, 2021
#### Trade Name of Device
Neurosign® V4 Intraoperative Nerve Monitor
#### Common or Usual Name
Neurosurgical Nerve Locator
#### Classification
Neurosurgical Nerve Locator
21 CFR 874.1820, Class II, product code PDQ
#### Predicate Devices
K181559 Neurosign® V4 Intraoperative Nerve Monitor. The Magstim Company Limited (Primary Predicate Device), 21 CFR 874.1820, PDQ, ETN
K053141 Neurosign® Nerve Monitor, Model Neurosign® 400 and Neurosign® 800, The Magstim Company Limited (Secondary Predicate), 21 CFR 874.1820, ETN
#### Device Description
The Neurosign® V4 Intraoperative Nerve Monitor (IONM) is a multi-channel nerve monitor designed for use in Ear, Nose and Throat (ENT) surgery and neurosurgery. The subject device differs from its primary predicate due to the introduction of improved Pre-amplifier and Stimulator pod cables, as well the addition of an 8-channel Pre-amplifier variant.
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Using needle or surface electrodes 1 connected to the Pre-amplifier, the nerve monitor detects electromyographic (EMG) signals within muscles caused by the contraction of the muscle due to mechanical manipulation or electrical stimulation of the nerve controlling it. The Neurosign® V4 then amplifies the EMG data into an audible signal and displays the data as a waveform on the active monitoring screen.
The Neurosign® V4 Intraoperative Nerve Monitor is used for patient treatment by prescription only under the supervision of a licensed physician.
The Neurosign® V4 is an integrated system consisting of a combination of hardware, software, and accessories. Its technological characteristics are described in further detail below.
## Intended Use
The Neurosign® V4 Intraoperative Nerve Monitor is intended for locating and identifying cranial and peripheral motor and mixed motor-sensory nerves during surgery, including spinal nerve roots.
## Technological Characteristics
The Neurosign® V4 is comprised of following components:
- 1. Neurosign® V4 Intraoperative Nerve Monitor
- 2. Neurosign® V4 Pre-amplifier:
- a. Neurosign® V4 Pre-amplifier 4-Channel
- b. Neurosign® V4 Pre-amplifier 8-Channel
- 3. Neurosign® V4 Stimulator Pod
- 4. Neurosign® V4 Mute Sensor
The Neurosign® V4 Intraoperative Nerve Monitor (IONM) includes a user interface comprised of an audio output, a color graphics display with a touch screen and dedicated rotary controls for frequently adjusted parameters.
EMG signals are collected from the patient using needle and surface electrodes [1] connected to the Neurosian® V4 Pre-amplifier. The pre-amplifier is available in a 4-channel or 8-channel variant, allowing the user to monitor up to eight separate neural pathways depending on the pre-amplifier used. The Neurosign® V4 Pre-amplifier collects, processes and transmits the EMG signals to the IONM for display and for an audio output.
The Neurosign® V4 Stimulator Pod allows the simultaneous connection of two stimulating probes for the mapping and locating of nerves within tissue, and to test the nerve activity at various stages during surgery.
Software documentation for a "major" level of concern has been provided.
<sup>1</sup> Single use electrodes and probes not subject to this submission
<sup>2</sup> Single use electrodes and probes not subject to this submission
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# Non-Clinical Testing Table 1: Summary of Non-Clinical Testing
| Test | Method | Results/ Comment |
|----------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Electrical Safety<br>Mechanical Safety | ANSI/AAMI ES60601-1:2005/(R)2012 and<br>A1:2012-<br>Medical electrical equipment - Part 1:<br>General requirements for<br>basic safety and essential performance;<br>FDA Recognition Number: 19-4 | A sample Neurosign® V4 (4-Channel<br>and 8-Channel Variants) has been<br>tested and found to be compliant to the<br>requirements of IEC 60601-1 by<br>independent test laboratory Element<br>Materials Technology, to demonstrate<br>safety and effectiveness of the system<br>following incorporation of new/different<br>characteristics as compared to the<br>predicate device.<br><br>Following the design changes to the Pre<br>amplifier and Stimulator Pod cables,<br>non-clinical bench testing was performed<br>by Magstim confirming that there is no<br>discernable difference in the isolation<br>parameters of the new cable design in<br>comparison to the old. |
| Electromagnetic<br>Compatibility | IEC 60601-1-2: 2014 -<br>Medical electrical equipment - Part 1-2:<br>General requirements for basic safety and<br>essential performance -<br>Collateral standard: Electromagnetic<br>compatibility -Requirements and tests;<br>FDA recognition number: 19-8 | A sample Neurosign® V4 (4-Channel)<br>has been tested and found to be<br>compliant to the requirements of EN<br>60601-1-2 by independent test<br>laboratory Eurofins Hursley, to<br>demonstrate safety and effectiveness o<br>the system following incorporation of<br>new/different characteristics as<br>compared to the predicate device.<br><br>Following the design change to the Pre-<br>amplifier and Stimulator Pod cables,<br>non-clinical bench testing was performed<br>by Magstim concluding there is no<br>discernable difference in the EMC<br>performance of the new cable design in<br>comparison to the old. |
| Alarm Systems | IEC 60601-1-8 -<br>Medical electrical equipment - Part 1-8:<br>General requirements for basic safety and<br>essential performance - Collateral<br>Standard: General requirements, tests and<br>guidance for alarm systems in medical<br>electrical equipment and medical electrical<br>systems; FDA Recognition Number: 5-76 | A sample Neurosign® V4 has been<br>tested and found to be compliant to the<br>requirements of IEC 60601-1-8 by<br>independent test laboratory Element<br>Materials Technology, thus<br>demonstrating the Neurosign® V4 is<br>substantially equivalent to the legally<br>marketed predicate device. |
| Biocompatibility | ISO 10993-1:2009 - Biological Evaluation<br>of Medical Devices - Part 1: Evaluation and<br>testing within a risk management process | The Neurosign®V4 Nerve Monitor is no<br>intended to come into contact with the<br>patient, as patient contact is achieved |
| Human Factors Testing | ISO 10993-5:2009 - Biological evaluation<br>of medical devices -- Part 5: Tests for in<br>vitro cytotoxicity; FDA Recognition<br>Number: 2-245 | via use of single use electrodes and<br>probes.<br>However, the Stimulator Pod, Pre-<br>amplifier and connecting leads may<br>come into contact with the patient. |
| | ISO 10993-10:2010 - Biological evaluation<br>of medical devices - Part 10: Tests for<br>irritation and skin sensitization; FDA<br>Recognition Number: 2-174 | Samples of these materials have been<br>tested and found to be compliant to the<br>requirements of ISO 10993-1, ISO<br>10993-5 and ISO 10993-10 by an<br>independent test laboratory, thus<br>demonstrating the Neurosign® V4 is<br>substantially equivalent to the legally<br>marketed predicate device. |
| | AAMI/ANSI HE75 - Human Factors<br>Engineering - Design of Medical Devices;<br>FDA Recognition Number: 5-57 | Usability testing was performed to<br>analyze the user experience of the 8-<br>Channel Neurosign® V4.<br>The Human Factors Engineering report<br>verifies the Neurosign V4, using the 8-<br>channel pre-amplifier, to be safe and<br>effective for the intended users, uses,<br>and use environments thus<br>demonstrating the Neurosign® V4 is<br>substantially equivalent to the legally<br>marketed predicate device. |
| | IEC 62366-1 - Medical Devices - Part 1:<br>Application of Usability Engineering To<br>Medical Devices; FDA Recognition<br>Number: 5-114 | |
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The software verification and validation testing further demonstrated that the software performs as intended and in accordance with specifications. In accordance with ISO14971, risks associated with the Neurosign® V4 have been identified, assessed and, where necessary, mitigated with risk control measures to an acceptable level.
# Substantial Equivalence Discussion
The Neurosign® V4 (subject of this submission) is substantially equivalent to the primary predicate device, the Neurosign® V4 Intraoperative Nerve Monitor (K181559) and the secondary predicate device, the Neurosign® Nerve Monitor Model Neurosign® 400 and Model Neurosign® 800® (K053141).
The intended use and indications for use are identical between the Neurosign® V4 (subject of this submission) and the primary predicate device, the Neurosign® V4 Intraoperative Nerve Monitor (K181559).
All devices have the same four principal components:
- (1) Intraoperative Nerve Monitor,
- (2) Pre-amplifier,
- (3) Stimulator and
- (4) Mute Sensor.
The notable difference between the subject device Neurosign® V4 and that which was cleared earlier in K181559 includes the redesign of the Pre-amplifier and Stimulator pod
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cables to improve reliability and malleability during use, as well the addition of an 8-channel Pre-amplifier variant, enabling the user to monitor up to eight separate neural pathways at risk during surgery. The Neurosign® V4 8-Channel Pre-amplifier is substantially equivalent to the Neurosign® V4 4-Channel Pre-amplifier previously cleared under K181559, with the addition of 4 additional electrode channels.
Furthermore, the addition of an 8-channel Pre-amplifier is supported by the clearance of the secondary predicate device (K053141), as the secondary predicate includes the option to monitor up to eight separate neural pathways at risk during surgery.
The Principles of Operation are identical to the primary predicate device, the Neurosign® V4 Intraoperative Nerve Monitor (K181559). Both the subject device and the predicate device systems are all systems that are intended for use in collecting, processing and representing EMG signals from nerves at of choice during surgery.
Both the subject and predicate devices use a stimulator for the mapping and locating of nerves within tissue and testing the nerve activity at various stages during surgery. All offer the option to use a mute sensor to silence the audio output during episodes of RF interference from electrocautery.
A summary of the similarities and minor differences between the Neurosign® V4, the previous Neurosign® V4 (primary predicate device) and the Neurosign® Nerve Monitor Model Neurosign® 400 and Model Neurosign® 800 (Secondary Predicate Device) are described in Table 2.
### Conclusions
In summary, the subject and predicate devices are substantially equivalent based on their identical intended use and similar technological characteristics, which have been tested according to the applicable non-clinical performance testing.
Non-clinical test data demonstrates that the Neurosign® V4 is as safe and effective as the predicate devices.
Thus, the Neurosign® V4 Intraoperative Nerve Monitor is substantially equivalent to the primary predicate device, the Neurosign® V4 Intraoperative Nerve Monitor (K181559), and the secondary predicate device, the Neurosign® Nerve Monitor, Model Neurosign® 400.
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# Table 2: Substantial Equivalence Summary
| Criteria of<br>Comparison | K203684<br>Neurosign® V4 Intraoperative<br>Nerve Monitor<br>(Subject of this submission) | K181559<br>Neurosign® V4<br>Intraoperative Nerve<br>Monitor<br>(Primary Predicate Device) | K053141<br>Neurosign® Nerve Monitor,<br>Model Neurosign® 400 and<br>Model Neurosign® 800®<br>(Secondary Predicate<br>Device) |
|----------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------|
| Manufacturer | Magstim Company Limited | Magstim Company Limited | Magstim Company Limited |
| Device Name | Neurosign® V4 Intraoperative<br>Nerve Monitor | Neurosign® V4<br>Intraoperative Nerve<br>Monitor | Neurosign® Nerve Monitor,<br>Model Neurosign® 400 |
| Product code(s)<br>& regulation | PDQ<br>21 CFR 874.1820 | PDQ, ETN<br>21 CFR 874.1820 | ETN<br>21 CFR 874.1820 |
| Intended Use/<br>Indications for<br>Use | The Neurosign® V4<br>Intraoperative Nerve Monitor<br>is intended for locating and<br>identifying cranial and<br>peripheral motor and mixed<br>motor-sensory nerves during<br>surgery, including spinal<br>nerve roots.<br>Indications for Neurosign®<br>V4 EMG Monitoring<br>Procedures include:<br>Intracranial, Extracranial,<br>Intratemporal, Extratemporal,<br>Neck Dissections, Thoracic<br>Surgeries, and Upper and<br>Lower Extremities.<br>Indications for spinal<br>procedures which may use<br>Neurosign® V4 EMG<br>monitoring include:<br>Degenerative Treatments,<br>Pedicle Screw Procedures,<br>Fusion Cages, Rhizotomy,<br>Orthopedic Surgery and<br>Open and Percutaneous<br>Lumbar Procedures. | The Neurosign® V4<br>Intraoperative Nerve<br>Monitor is intended for<br>locating and identifying<br>cranial and peripheral motor<br>and mixed motor-sensory<br>nerves during surgery,<br>including spinal nerve roots.<br>Indications for Neurosign®<br>V4 EMG Monitoring<br>Procedures include:<br>Intracranial, Extracranial,<br>Intratemporal,<br>Extratemporal, Neck<br>Dissections, Thoracic<br>Surgeries, and Upper and<br>Lower Extremities.<br>Indications for spinal<br>procedures which may use<br>Neurosign® V4 EMG<br>monitoring include:<br>Degenerative Treatments<br>Pedicle Screw Procedures,<br>Fusion Cages, Rhizotomy,<br>Orthopedic Surgery and<br>Open and Percutaneous<br>Lumbar Procedures. | To locate and identify<br>cranial motor nerves during<br>ENT and intra-cranial<br>procedures. |
| Intraoperative Nerve Monitor | | | |
| Type of monitor | EMG | EMG | EMG |
| System<br>hardware | Digital | Digital | Digital |
| Display | 15" color touchscreen | 15" color touchscreen | 125mm x 95mm<br>electroluminescent display |
| Criteria of<br>Comparison | K203684<br>Neurosign® V4 Intraoperative<br>Nerve Monitor<br>(Subject of this submission) | K181559<br>Neurosign® V4<br>Intraoperative Nerve<br>Monitor<br>(Primary Predicate Device) | K053141<br>Neurosign® Nerve Monitor,<br>Model Neurosign® 400 and<br>Model Neurosign® 800®<br>(Secondary Predicate<br>Device) |
| Stimulator<br>adjust | By control knob | By control knob | By control knob |
| Volume adjust | By control knob; individual<br>channels by touchscreen | By control knob; individual<br>channels by touchscreen | By control knob |
| Needle<br>placement<br>impedance<br>checking | Yes | Yes | No |
| | Amplifier | | |
| Number of<br>channels | 4 (4-Channel Pre-amplifier)<br>8 (8-Channel Pre-amplifier) | 4 | 4 (Neurosign® 400)<br>8 (Neurosign® 800) |
| Color coded<br>electrode<br>sockets | Yes | Yes | Yes |
| Bandwidth | 10Hz - 1kHz | 10Hz - 1kHz | 10Hz - 5kHz |
| Common mode<br>rejection ratio | > 90dB @ 50/60Hz | > 90dB @ 50/60Hz | > 95dB @ 50/60Hz |
| | Stimulator | | |
| Stimulator<br>channels | Channel 1: 2 probes | Channel 1: 2 probes | Channel 1: 2 probes |
| Operational<br>mode | Constant Current or<br>Constant Voltage | Constant Current or<br>Constant Voltage | Constant Current or<br>Constant Voltage |
| Current ranges | 10μΑ – 10mA | 10μA - 10mA | 50µA - 10mA |
| Voltage ranges | 10mV - 10V | 10mV - 10V | 50mV - 10V |
| Accuracy | Current Stimulating Mode<br>± 10% (1mA – 10mA), into<br>1kΩ load<br>± 25% (10μA - 990 μA), into<br>1kΩ load<br><br>Voltage Stimulating Mode<br>± 10% (1V - 10V), into 1kΩ<br>load<br>± 25% (10mV - 990 mV), into<br>1kΩ load | Current Stimulating Mode<br>± 10% (1mA – 10mA), into<br>1kΩ load<br>± 25% (10μA - 990 μA), into<br>1kΩ load<br><br>Voltage Stimulating Mode<br>± 10% (1V - 10V), into 1kΩ<br>load<br>± 25% (10mV - 990 mV),<br>into 1kΩ load | Current Stimulating Mode<br>± 10% (50µA - 10mA), into<br>1kΩ load<br><br>Voltage Stimulating Mode<br>± 10% (50mV – 10V), into<br>1kΩ load |
| | Mute Sensor | | |
| Available | Yes | Yes | Yes |
| | Operational Environment | | |
| Criteria of<br>Comparison | K203684<br>Neurosign® V4 Intraoperative<br>Nerve Monitor<br>(Subject of this submission) | K181559<br>Neurosign® V4<br>Intraoperative Nerve<br>Monitor<br>(Primary Predicate Device) | K053141<br>Neurosign® Nerve Monitor,<br>Model Neurosign® 400 and<br>Model Neurosign® 800®<br>(Secondary Predicate<br>Device) |
| Operating<br>temperature | 5°C to 40°C | 5°C to 40°C | 5°C to 30°C |
| Relative<br>humidity | 10% to 80% (non-<br>condensing) | 10% to 80% (non-<br>condensing) | 30% to 70% (non-<br>condensing) |
| Atmospheric<br>pressure | 70kPa to 106kPa | 70kPa to 106kPa | 50kPa to 106kPa |
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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.