K080914 · Rochester Electro Medical, Inc. · IKT · Jul 15, 2008 · Physical Medicine
Device Facts
Record ID
K080914
Device Name
ULTRASHARP CONCENTRIC NEEDLES
Applicant
Rochester Electro Medical, Inc.
Product Code
IKT · Physical Medicine
Decision Date
Jul 15, 2008
Decision
SESE
Submission Type
Abbreviated
Regulation
21 CFR 890.1385
Device Class
Class 2
Indications for Use
Recording muscle activity for Electromyography (EMG) applications. For Single Patient Use only. Patient population: Adults.
Device Story
Ultra Sharp Concentric Needles are disposable, bi-polar/multi-polar electrodes used for recording muscle activity during electromyography (EMG). The device consists of a stainless steel hypodermic outer shell with a centered platinum/iridium inner recording core, featuring a trocar sharpened tip. An electrically insulated molded handle provides contact points for connection to an external EMG machine via a detachable cable (sold separately). The device is intended for use in hospitals or physician offices by trained, certified physicians or under their order. By providing a stable electrical interface with muscles and associated nerves, the needle allows clinicians to capture physiological signals, aiding in the diagnosis of neuromuscular conditions. The device is for single-patient use to prevent cross-contamination.
Clinical Evidence
Bench testing only. No clinical data provided. Verification included microscopic visual examination of bevel convergence, burrs, and point; foam testing for sharpness; electrical continuity and pole isolation testing using an ohmmeter; and examination of needle straightness and length. Risk management and design controls were completed.
Technological Characteristics
Stainless steel hypodermic outer shell; platinum/iridium inner recording core; molded plastic handle. Dimensions vary by model (25mm-75mm length; 23-27 gauge). Passive electrode; no internal energy source. Sterilized via Gamma Irradiation. Standards met: ISO 13485, ISO 14971, ISO 10993-1, AAMI/ANSI/ISO 11137, ISO 14644, ISO 9626, ISO 7864.
Indications for Use
Indicated for recording muscle activity for Electromyography (EMG) applications in adults. For single patient use only.
Regulatory Classification
Identification
A diagnostic electromyograph needle electrode is a monopolar or bipolar needle intended to be inserted into muscle or nerve tissue to sense bioelectrical signals. The device is intended for medical purposes for use in connection with electromyography (recording the intrinsic electrical properties of skeletal muscle).
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KOROGIY
Image /page/0/Picture/1 description: The image is a circular emblem with the word "ROCHESTER" at the top. A stylized image of a pencil is in the center of the emblem. The phrase "Education for the Deaf Program" is at the bottom of the emblem. The emblem is black and white.
## 510(k) Summary
JUL 1 5 2008
#### Contact Details
Applicant Name: Rochester Electro-Medical, Inc.
4212 Cypress Gulch Dr. Lutz, FL 33559 U.S.A. 1-813-963-2933 1-813-960-4563 (FAX)
Charles C. Berkins, C.E.O. cberkins@rochesterelectromed.com
Date Prepared: July 3, 2008
#### Device Name
Trade Name: Ultra Sharp Concentric Needles
Common Name: EMG Needles, Concentric Needles, Bi-polar Needles
Classification Name: Electrode, needle, diagnostic, electromyograph; Diagnostic electromyography needle electrode; IKT
| | Legally Marketed Predicate Device(s) | |
|---|--------------------------------------|--|
| 1 | | |
| 510(k) Number | Product Code | Trade Name | Manufacturer |
|---------------|--------------|------------------------------------------------------------|-------------------------------|
| K895460 | IKT | CONCENTRIC<br>ELECTRODE TYPE<br>#13R01, 13R02 | DANTEC<br>ELECTRONICS, INC. |
| 931966 | IKT | DANTEC DISPOSABLE<br>CONCENTRIC NEEDLE | DANTEC MEDICAL, INC. |
| K924521 | IKT | DISPOSABLE<br>CONCENTRIC NEEDLE<br>ELECTRODE | CHALGREN<br>ENTERPRISES, INC. |
| K896370 | GXZ | DISP. CONCENTRIC<br>NEEDLE ELECTRODE<br>(DCP-30, DCP-45 | CHALGREN<br>ENTERPRISES, INC. |
| K933795 | GXZ | CONCENTRIC EMG<br>NEEDLE ELECTRODE | CADWELL<br>LABORATORIES, INC. |
| K973529 | IKT | NEUROLINE,<br>DISPOSABLE<br>CONCENTRIC NEEDLE<br>ELECTRODE | MEDICOTEST A/S. |
| K960591 | IKT | RE-USABLE BIPOLAR<br>CONCENTRIC<br>NEEDLE(237-XXX-24,23 | CHALGREN<br>ENTERPRISES, INC. |
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### Device Description
Bi-polar/multi-polar disposable concentric needles for recording muscle activity. The needles consist of a stainless steel hypodermic outer shell with a centered platinum/iridium inner recording core with a trocar sharpencd tip. An electrically insulated molded handle incorporates the contact points allowing electrical continuity through the connecting cable, which is sold separately.
#### Intended Use/Indications for use
Recording muscle activity for Electromyography (EMG) applications. For Single Patient Use only. Patient population: Adults.
| Characteristic | Predicate Devices | Rochester Device |
|----------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Indications for Use | Recording muscle activity for<br>Electromyography (EMG)<br>applications. For Single Patient<br>Use only. | Recording muscle activity for<br>Electromyography (EMG)<br>applications. For Single Patient<br>Use only. |
| Target Population | Adults | Adults |
| Design | Outer Hypodermic shell with<br>insulated inner recording core.<br>Recording connections through a<br>molded handle to a detachable<br>connecting cable. | Outer Hypodermic shell with<br>insulated inner recording core.<br>Recording connections through a<br>molded handle to a detachable<br>connecting cable. |
| Materials | Stainless Steel cannula, platinum<br>Or silver core, Molded plastic handle | Stainless Steel cannula, platinum<br>core, Molded plastic handle |
| Performance | Unknown | Testing data: Core Centering & Size;<br>Microscopic visual examination;<br>Sharpening; Microscopic visual<br>examination with special<br>attention to bevel convergence, burrs<br>and point; Electrical continuity of all<br>poles; Electrical isolation of all poles;<br>Needle hypodermic shell examined for<br>straightness and stated length. |
| Sterility | Gamma Irradiation, E-Beam | Gamma Irradiation |
| Biocompatibility | Stainless Steel, Platinum & Silver | Stainless Steel & Platinum |
| Mechanical Safety | Packaged needle covered with a<br>needle cover. | Packaged needle covered with a<br>needle cover. |
| Chemical Safety | Not Applicable | Not Applicable |
| Anatomical Sites | Muscles and associated Nerves | Muscles and associated Nerves |
| Human Factors | Must be used by a trained, certified<br>physician or by order of a physician | Must be used by a trained, certified<br>physician or by order of a physician |
| Energy Used/Delivered | Not Applicable | Not Applicable |
| Compatibility with Other Devices | Compatibility is achieved through the<br>connecting cable to EMG machines or<br>similar physiological recording devices. | Compatibility is achieved through the<br>connecting cable to EMG machines or<br>similar physiological recording devices. |
| Where Used | Physician's office or Hospitals. | Physician's office or Hospitals. |
| Risk Analysis | Unknown | Risk Management completed 1-30-<br>08 as part of the Design Control<br>Process |
| Design Control | Unknown | Design Control Completed 1-30-08 |
| Electrical Safety | Unknown | Controlled & accounted for with<br>Risk Management. |
#### Substantial Equivalence Comparison
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| Design Control | Unknown | Design Control Completed 1-30-08 | |
|-------------------|----------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Electrical Safety | Unknown | Controlled & accounted for with<br>Risk Management. | |
| Options Offered | 25 mm., 30 ga.<br>30 mm., 28 ga.<br>38 mm., 26 ga.<br>75 mm., 23 ga. | 25 mm., 26 ga.<br>37 mm., 26 ga.<br>50 mm., 26 ga. | 25 mm., 30 ga.<br>25 mm., 28 ga.<br>25 mm., 27 ga.<br>37 mm., 27 ga.<br>50 mm., 27 ga.<br>25 mm., 26 ga.<br>50 mm., 26 ga.<br>37 mm., 26 ga.<br>65 mm., 25 ga.<br>75 mm., 23 ga. |
| Standards Met | Unknown | ISO 13485:2003-07-15<br>ISO 14971:2007-02-01<br>ISO 10993-1:2003<br>AAMI/ANSI/ISO 11137-1:2006<br>AAMI/ANSI/ISO 11137-2:2006<br>AAMI/ANSI/ISO 11137-3:2006<br>ISO 14644-1:1999-05-01<br>ISO 14644-2:2000-09-15<br>ISO 14644-4:2001-04-01<br>ISO/TR 16142:2006-01-15<br>BS EN 980:1996 + A1:1999 + A2:2001<br>ISO 9626:1991 + A1:2001<br>ISO 7864:1993 | |
#### Non-clinical Testing
Bench Testing consisted of the following:
- 1. Process Control Used to Control the processes used in manufacturing. The methods used for verifying processes will vary depending on the process to be tested and the type of product the process is used to produce. Process Control Forms used:
- Concentric Needle Sharpening visual examination under microscope and foam test Concentric Core Insertion - visual examination under microscope
- Concentric Needle Continuity audible ohmmeter
- Concentric Needle Pole Isolation audible ohm meter
- Concentric Needle Handle Mold Design Visual and audible ohm meter Concentric Needle Connector Interface - Visual and audible ohm meter
- 2. Process Verification Process verification is done according to the control process
- established in Process Control Forms above. Process Verification Forms used:
- Concentric Needle Sharpening
- Concentric Core Insertion
- Concentric Needle Continuity
- Concentric Needle Pole Isolation
- Concentric Needle Handle Mold Design
- Concentric Needle Connector Interface
- 3. Design Verification after Process Verification has been approved, verification is performed using samples from the first production run. The methods used for the Concentric Needle Design are identical to those used in the Process Approval phase above since the process and design output parameters are the same. Design Verification Forms used:
- Concentric Needle Sharpening- visual examination under microscope and foam test Concentric Core Insertion - visual examination under microscope
- Concentric Needle Continuity audible ohmmeter
- Concentric Needle Pole Isolation audible ohmmeter
- Concentric Needle Handle Mold Design Visual and audible ohm meter
- Concentric Needle Connector Interface Visual and audible ohm meter
- 4. Standards used see comparison chart above.
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Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of two main elements: the department's seal and the symbol. The seal is a circular emblem with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - U.S.A." arranged around the perimeter. The symbol is a stylized representation of a caduceus, featuring a staff with a serpent entwined around it.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Rochester Electro-Medical, Inc. % Mr. Charles C. Berkins CEO 4212 Cypress Gulch Drive Lutz, Florida 33559
JUL 1 5 2008
Re: K080914 Trade/Device Name: Ultrasharp Concentric Needles Regulation Number: 21 CFR 890.1385 Regulation Name: Diagnostic electromyograph needle electrode Regulatory Class: Class II Product Code: IKT Dated: May 8, 2008 Received: May 21, 2008
Dear Mr. Berkins:
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 for answer 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). and coometre fore, market the device, subject to the general controls provisions of the Act. The r ou may are see your in as of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such 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 I that FDA has made a determination that your device complies with other requirements of the Act that I Dri has intace a and regulations administered by other Federal agencies. You must or any I with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); good manufacturing practice requirements as set CI K Fat 607), idoomig (DI CFR Part 820); and if applicable, the electronic forul in the quality by neally (Sections 531-542 of the Act); 21 CFR 1000-1050.
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Page 2 - Mr. Charles C. Berkins
This letter will allow you to begin marketing your device as described in your Section 510/k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Center for Devices and Radiological Health's (CDRH's) Office of Compliance at (240) 276-0120. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding postmarket surveillance. please contact CDRH's Office of Surveillance and Biometric's (OSB's) Division of Postmarket Surveillance at (240) 276-3474. For questions regarding the reporting of device adverse events (Medical Device Reporting (MDR)), please contact the Division of Surveillance Systems at (240) 276-3464. You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at toll-free number (800) 638-2041or (240) 276-3150 or the Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely yours,
Mark M. Milliman
Mark N. Melkerson Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known):
Device Name: _________________________________________________________________________________________________________________________________________________________________
Indications for Use:
Recording muscle activity for Electromyography (EMG) applications. For single patient use only. Patient population: Adults.
| Prescription Use<br>(Part 21 CFR 801 Subpart D) | X |
|-------------------------------------------------|---|
| AND/OR | |
| Over-The-Counter Use<br>(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)
(Division Sign-Off)
Division of General, Restorative, and Neurological Devices
| 510(k) Number | k080914 |
|---------------|---------|
|---------------|---------|
Page 1 of 1
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.