NIHON KOHDEN QP-160 AK TREND PROGRAM WITH THE ADDITION OF DSA ASYMMETRY TREND AND FFT P
K120485 · Nihon Kohden America, Inc. · OMA · Mar 16, 2012 · Neurology
Device Facts
Record ID
K120485
Device Name
NIHON KOHDEN QP-160 AK TREND PROGRAM WITH THE ADDITION OF DSA ASYMMETRY TREND AND FFT P
Applicant
Nihon Kohden America, Inc.
Product Code
OMA · Neurology
Decision Date
Mar 16, 2012
Decision
SESE
Submission Type
Special
Regulation
21 CFR 882.1400
Device Class
Class 2
Attributes
Software as a Medical Device
Indications for Use
The OP-160AK Trend program is a software-only device intended to be installed on the EEG-1200A series electroencephalograph to record, calculate, and display EEG data obtained from the EEG-1200A system. This device is intended to be used by qualified medical practitioners, trained in Electroencephalography, who will exercise professional judgment when using the information. The intended use for each of the software's outputs is as follows: - The EEG and aEEG wayeforms are intended to help the user monitor the state of the . brain. - The user-defined Fast Fourier Transform (FFT) parameters of this software (FFT power) . are intended to help the user analyze the EEG waveform. - The burst suppression parameters of this software (interval and bursts per . minute) are intended to aid in the identification and characterization of areas of burstsuppression pattern in the EEG. This device does not provide any diagnostic conclusion about the patient's condition to the user. The device is intended for use by medical personnel in any location within a medical facility, laboratory, clinic or nursing home or outside of a medical facility under direct supervision of a medical professional.
Device Story
Software-only module for EEG-1200A series electroencephalograph; processes raw EEG data to generate trends; displays waveforms, FFT power, burst suppression parameters (interval/bursts per minute), and asymmetry trends (DSA/FFT Power). Used in medical facilities, clinics, or nursing homes by trained medical practitioners. Output provides visual trends to assist clinicians in monitoring brain state and analyzing EEG patterns; does not provide diagnostic conclusions. Clinicians use displayed information to exercise professional judgment in patient management.
Clinical Evidence
No clinical data required. Safety and performance established via verification and validation testing, including comparison testing of trend calculations against predicate devices.
Technological Characteristics
Software-only EEG trend analysis module; operates on EEG-1200A series hardware. Features include Density Spectral Array (DSA), Spectral Edge Frequency, aEEG, Burst Suppression Ratio, Inter-burst Interval, Burst Per Minute, FFT Power, and Asymmetry trends. Supports up to 64 EEG and 8 DC channels. Non-patient contacting.
Indications for Use
Indicated for use by qualified medical practitioners trained in Electroencephalography to record, calculate, and display EEG data from the EEG-1200A system for monitoring brain state, analyzing waveforms via FFT, and identifying burst-suppression patterns. No specific patient age or disease state contraindications provided.
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.
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K120485
## 510(K) SUMMARY
・・・
. .
Name and Address of Applicant
Nihon Kohden America. Inc. 90 Icon Street Foothill Ranch, CA 92610
Contact: Steve Geerdes Director, Regulatory Affairs (949) 580-1555 ex. 3325 Fax: (949) 580-1550
Date: 2/14/2012
Trade/Device Name: Nihon Kohden QP-160AK EEG Trend Program
Common or usual Name: Electroencephalograph (EEG)
#### Legally Marketed Predicate:
Nihon Kohden QP-160AK EEG Trend Program (K092573)
Applied Neuroscience NeuroGuide Analysis System (K041263)
Brain Scope Zoom-100DC (K082886)
#### Intended Use:
The OP-160AK Trend program is a software-only device intended to be installed on the EEG-1200A series electroencephalograph to record, calculate, and display EEG data obtained from the EEG-1200A system. This device is intended to be used by qualified medical practitioners, trained in Electroencephalography, who will exercise professional judgment when using the information.
The intended use for each of the software's outputs is as follows:
- The EEG and aEEG wayeforms are intended to help the user monitor the state of the . brain.
- The user-defined Fast Fourier Transform (FFT) parameters of this software (FFT power) . are intended to help the user analyze the EEG waveform.
- The burst suppression parameters of this software (interval and bursts per . minute) are intended to aid in the identification and characterization of areas of burstsuppression pattern in the EEG.
This device does not provide any diagnostic conclusion about the patient's condition to the user.
The device is intended for use by medical personnel in any location within a medical facility, laboratory, clinic or nursing home or outside of a medical facility under direct supervision of a medical professional.
MAR 1 6 2012
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A summary of the technological characteristics of the device compared to the predicate device:
The QP-160AK EEG Trend program is the same as the previous version of QP-160AK cleared under 510k but has two new trends available (DSA Asymmetry trend and FFT Power Asymmetry trend).
The QP-160AK EEG Trend program's two new trends (DSA Asymmetry trend and FFT Power Asymmetry trend) are available in the BrainScope Zoom 100 DC (K082886) and the Applied Neuroscience Neuroguide Analysis System (K041263).
# Functional Comparision
| Nihon Kohden<br>160 Trend program under<br>review | Nihon Kohden<br>QP -160 Trend<br>Program Cleared<br>K092573 | BrainScope Zoom-<br>100DC cleared<br>K082886 | Applied<br>Neuroscience<br>NeuroGuide<br>Analysis System<br>Cleared K041263 |
|---------------------------------------------------------------------------------------|-------------------------------------------------------------|----------------------------------------------|-----------------------------------------------------------------------------|
| Function | | | |
| Number of EEG Channels<br>(Dependant on Amplifier)<br>Up to 32/64 EEG Channels | Same | N/A | N/A |
| Number of DC Channels<br>(Dependant on Amplifier)<br>Up to 8 DC Channels | Same | N/A | N/A |
| Density Spectral Array (DSA) Trend | Same | N/A | N/A |
| Density Spectral Array (DSA)<br>asymmetry Trend | None | Same | Same |
| Spectral Edge Frequency Trend | Same | N/A | N/A |
| Amplitude Integrated EEG (aEEG)<br>Trend | Same | N/A | N/A |
| Burst Suppression Ratio (BSR)<br>Trend | Same | N/A | N/A |
| Inter-burst Interval (IBI) Trend | Same | N/A | N/A |
| Burst Per Minute (BPM) Trend | Same | N/A | N/A |
| FFT Power Trend | Same | N/A | N/A |
| FFT Power Asymmetry Trend | None | Same | Same |
| FFT Power Ratio (e.g. Alpha /Delta,<br>Alpha/Beta) | Same | N/A | N/A |
| External input (DC input) display | Same | N/A | N/A |
| Number of trends<br>More than 16 | Same | N/A | N/A |
| User Selectable Trend Groups<br>(Panel) | Same | N/A | N/A |
| Time interval of trends<br>1 minute/page to 24 hours /page<br>1 cm/hour to 60 cm/hour | Same | N/A | N/A |
| User Selectable Trends Time Scale | Same | N/A | N/A |
| Annotation list | Same | N/A | N/A |
| Raw EEG data display | | N/A | N/A |
| Look-Back while recording<br>Synchronized Video | Same | | |
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# Testing (Non Clinical & Clinical) -
- To date no special controls or performance standards are known or established for this . device as required by sections 513(b) and 514 of the Food, Drug and Cosmetic Act as implemented by 21 CFR Part 861.
- The device is not sterile. .
- The device does not directly contact patients. Therefore, good laboratory practice studies . were not required per 21 CFR Part 58.
- The QP-160AK EEG Trend Program was subjected to safety and performance testing . procedures. The QP-160AK EEG Trend Program has undergone validation and verification testing to ensure conformance to all design requirements. Additionally, the system has undergone comparison testing to ensure the substantial equivalence of the calculation and display of EEG trends. These tests verified that the device performed within specifications.
- No Clinical testing was required .
# Conclusion of Substantial Equivalence:
- The comparison of technological characteristics and performance testing of the QP-. 160AK EEG Trend Program demonstrate that its safety, effectiveness, and performance are equivalent to the specified predicate devices.
- This software device is exactly the same as the predicate QP-160AK (K092573) except . for the addition of the two trends (DSA Asymmetry trend and FFT Power Asymmetry trend) that were added to the new QP-160AK. The Brainscope-100DC and the Applied Neuroscience Neuroguide Analysis System (K041263) provide the same DSA Asymmetry trend and FFT Power Asymmetry trend as the new QP-160AK. Therefore, Nihon Kohden believes that the device is substantially equivalent to the stated predicate devices.
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# DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
MAR 1 6 2012
Nihon Kohden America, Inc. c/o Steve Geerdes Director, Regulatory Affairs 90 Icon Street Foothill Ranch, CA 92610
Re: K120485
Trade/Device Name: Nihon Kohden QP-160AK EEG Trend Program Regulation Number: 21 CFR 882.1400 Regulation Name: Amplitude-integrated electroencephalograph Regulatory Class: Class II Product Code: OMA, OLT, ORT Dated: February 14, 2012 Received: February 17, 2012
Dear Mr. Geerdes:
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.
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 of any I vath all the Act's requirements, including, but not limited to: registration and listing (21
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## Page 2 - Steve Geerdes
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.htm 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.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/Resourcesfor You/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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# Indications for Use Form
510(k) Number (if known): _ K120485
Nihon Kohden QP-160AK Trend Program with the addition of DSA Asymmetry trend Device Name: and FFT Power Asymmetry trend
Indications for Use:
The QP-160AK Trend program is a software-only device intended to be installed on the EEG-1200A series electroencephalograph to record, calculate, and display EEG data obtained from the EEG-1200A system. This device is intended to be used by qualified medical practitioners, trained in Electroencephalography, who will exercise professional judgment when using the information.
The intended use for each of the software's outputs is as follows:
- The EEG and aEEG waveforms are intended to help the user monitor the state of the brain. .
- The user-defined Fast Fourier Transform (FFT) parameters of this software (FFT power) are . intended to help the user analyze the EEG waveform.
- The burst suppression parameters of this software (interval and bursts per minute) are . intended to aid in the identification and characterization of areas of burst-suppression pattern in the EEG.
This device does not provide any diagnostic conclusion about the patient's condition to the user.
The device is intended for use by medical personnel in any location within a medical facility, laboratory, clinic or nursing home or outside of a medical facility under direct supervision of a medical professional.
Prescription Use (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 IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Kim
(Division Sign-Off) Division of Ophthalmic, Neurological and Ear, Nose and Throat Devices
Page 1 of
510(k) Number K120485
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.