K112733 · Etymotic Research, Inc. · EWO · Dec 16, 2011 · Ear, Nose, Throat
Device Facts
Record ID
K112733
Device Name
ER35 ERO-SCAN PRO HEARING TEST SYSTEM
Applicant
Etymotic Research, Inc.
Product Code
EWO · Ear, Nose, Throat
Decision Date
Dec 16, 2011
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 874.1050
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The ER35 is intended to be a test instrument that measures otoacoustic emissions, tympanic membrane performance (tympanometry), and acoustic reflex.
Device Story
ER35 ERO-SCAN Pro is a microprocessor-controlled instrument for screening otoacoustic emissions (OAEs), tympanic membrane performance (tympanometry), and acoustic reflex. Device inputs include physiological signals related to cochlear and middle ear function. It processes these signals to generate test data, which is stored in internal flash memory and displayed on a graphic LCD. Output can be printed or transferred to a computer. Used in clinical settings by healthcare professionals to assess hearing function in infants, children, and adults. Results assist clinicians in evaluating cochlear and middle ear health, facilitating diagnostic decision-making for patients with normal or impaired hearing.
Clinical Evidence
Clinical validation involved testing male and female participants across an appropriate age range with variable audiometric profiles (normal and impaired hearing). No adverse effects or complications were reported. Performance data supports substantial equivalence.
Technological Characteristics
Microprocessor-controlled; powered by 4 AA Alkaline cells; internal flash memory for data storage; graphic LCD display. Complies with ANSI S3.39-1987 (R2007), ANSI S3.6-2004, IEC 60601-1:2000, and IEC 60645-5:2004.
Indications for Use
Indicated for testing cochlear and middle ear function in infants, children, and adults via OAEs, tympanometry, and acoustic reflex.
Regulatory Classification
Identification
An audiometer or automated audiometer is an electroacoustic device that produces controlled levels of test tones and signals intended for use in conducting diagnostic hearing evaluations and assisting in the diagnosis of possible otologic disorders.
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Etymotic Research, Inc. Page 7
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#### 3.0 510(K) SUMMARY
| Date Prepared: | December 5, 2011 |
|----------------|------------------|
|----------------|------------------|
# Submitter Information:
| Company Name: | Etymotic Research, Inc. |
|------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------|
| Company Address: | Etymotic Research, Inc.<br>61 Martin Lane<br>Elk Grove Village, IL 60007 |
| Contact Person: | Steve Iseberg<br>Manager of Instrumentation Products<br>Etymotic Research, Inc.<br>Tel: (847) 228-0006<br>Fax: (847) 228-6836<br>s iseberg@etymotic.com |
## Device Information:
| Trade Name: | ER35 ERO-SCAN Pro Hearing Test System |
|----------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Common Name: | ER35 ERO-SCAN Pro (ER35) |
| Classification Name: | Audiometer and Auditory Impedance Tester |
| Device Class: | Class II, 510(k) Exempt, 21 CFR §874.1050<br>Class II, 21 CFR §874.1090 |
| Predicate Devices: | ERO•SCAN Otoacoustic Test Instrument (K980533;<br>K010165)<br>Etymotic Research, Inc. |
| | GSI 2000 (TympStar™) Middle Ear Analyzer (K000097)<br>VIASYS Healthcare (formerly Grason-Stadler Inc.) |
| | Interacoustics AT235H Impedance Audiometer (K994254)<br>Interacoustics A/S |
| Device Description: | The ER35 is a microprocessor-controlled instrument<br>designed to screen otoacoustic emissions, tympanic<br>membrane performance, and acoustic reflex. Test<br>information is stored in memory, displayed on a graphic<br>LCD, and can be printed by a printer or stored on a |
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computer. The product is manufactured and delivered completely assembled to the retailer using materials and techniques widely used by manufacturers of hearing devices.
Intended Use: The ER35 is intended to be a test instrument that measures otoacoustic emissions, tympanic membrane performance (tympanometry), and acoustic reflex.
Indications for Use: The ER35 ERO•SCAN Pro Hearing Test System is indicated for testing of cochlear and middle ear function in infants, children, and adults by measuring otoacoustic emissions (OAEs), tympanometry, and acoustic reflex.
### Comparison to Predicate Device:
All device parameters are similar for the product which is the subject of this 510(k) and the predicate devices. The intended use (including patient population) for the ER35 is consistent with those of the cited predicate devices.
Technological characteristics (i.e., design, material, and energy source) are identical to the ERO.SCAN Otoacoustic Test Instrument (K980533; K010165). The device is powered by 4 AA Alkaline cells, storing data (test records) via internal flash memory. The added functionality beyond OAEs does not affect the overall technological function and operation, compared to the predicate devices.
Certain performance specifications may vary compared to predicate devices, but in these cases, sufficient performance testing has been done to support substantial equivalence determination.
Non-clinical and clinical validation was performed in accordance with recognized consensus standards for this type of device. The ER35 has been demonstrated to be in compliance with the following performance and safety standards:
- . Specifications for Instruments to Measure Aural Impedance and Admittance (Aural Acoustic Emissions) (ANSI S3.39-1987 (R2007)), American National Standards Institute, New York, 1996;
#### Performance testing:
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- Medical Electrical Equipment, Part 1: General . Requirements for Safety (IEC 60601-1:2000), International Electrotechnical Commission, Geneva, 2000; and
- . Specification for Audiometers (Dental/ENT) (ANSI S3.6-2004), American National Standards Institute, New York, 2004.
The ER35 is also in compliance with the following voluntary performance and safety standards: Instruments for the Measurement of Aural Acoustic Impedance / Admittance (IEC 60645-5:2004), International Electrotechnical Commission, Geneva, 2004.
Subjects tested included both male and female participants, an appropriate age range, and variable audiometric profiles (i.e., subjects with normal range hearing and impaired hearing function). No adverse effects or complications occurred. Performance data collected supports a substantial equivalence determination.
### Conclusion:
The ER35 utilizes the same technology and has the same intended use as the cited predicate devices, and is therefore substantially equivalent (21 §CFR 807.92(a)(3)).
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Image /page/3/Picture/1 description: The image shows the logo for the Department of Health & Human Services (HHS). The logo features a stylized caduceus, a symbol often associated with healthcare, with three parallel lines forming the snake and staff. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular fashion around the caduceus.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
DEC 1 6 2011
Etymotic Research, Inc. c/o Mr. Jack Kent Becker & Associates Consulting, Inc. 2001 Pennsylvania Avenue NW, Suite 950 Washington, DC 20006
Re: K112733
Trade/Device Name: ER35 ERO●SCAN Pro Hearing Test System Regulation Number: 21 CFR 874.1050 Regulation Name: Audiometer Regulatory Class: Class II Product Code: EWO: ETY Dated: September 20, 2011 Received: September 20, 2011
Dear Mr. Kent:
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, 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.
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Page 2 - Mr. Jack Kent
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 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 go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.html for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. 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/ReportaProblem/default.htmi 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,
Malvina B. Eydelman, M.D.
Director Division of Ophthalmic, Neurological, and Ear, Nose and Throat Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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K112733
#### 2.0 STATEMENT OF INDICATIONS FOR USE
510(k) Number (if known): K112733
Device Name:
ER35 ERO.SCAN Pro Hearing Test System
Indications for Use:
The ER35 ERO•SCAN Pro Hearing Test System is indicated for testing of cochlear and middle ear function in infants, children, and adults by measuring otoacoustic emissions (OAEs), tympanometry, and acoustic reflex.
Prescription Use X (Part 21 CFR §801 Subpart D)
AND/OR
Over-The-Counter Use (21 CFR \$801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE – CONTINUE ON ANOTHER PAGE OF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Page 1 of 1
(Division Sign-Off) Division of Ophthalmic, Neurological and Ear, Nose and Throat Devices
KI12733 510(k) Number_
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.