K Number
K021594
Device Name
COPC BAND
Date Cleared
2003-11-13

(547 days)

Product Code
Regulation Number
882.5970
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The COPC Band is intended for medical purposes to passively hold prominent cranial regions of an infant's skull in order to improve cranial symmetry and/or shape in infants initiating treatment from three to 14 months of age, with nonsynostotic positional plagiocephaly, including infants with plagiocephalic, brachycephalic, and scaphocephalic patterned head shapes.
Device Description
The COPC Band is a cranial orthosis used to treat abnormally shaped craniums in infants three to 14 months of age. This condition is clinically known as positional or Deformational Plagiocephaly. The orthosis contains the protruding aspects of the cranium in a static equilibrium while guiding the growth of the flattened areas of the skull into the created spaces. The COPC Band is only available through a prescription issued by a physician. The orthosis is custom designed for each patient from a modified model and measurements of the infant's head. The mold is prepared for fabrication using advanced plaster modification techniques. Each orthosis is composed of an outer shell of thermoformable plastic, an inner lining of hypoallergenic foam, and a strap for securing Optimum fit and alignment is insured and monitored by the clinical the orthosis. practitioner.
More Information

Not Found

No
The device description and performance studies focus on the physical design, materials, and mechanical function of the cranial orthosis. There is no mention of AI, ML, image processing, or data sets for training or testing algorithms.

Yes

The device description explicitly states that the COPC Band is used to "treat abnormally shaped craniums in infants" and "guiding the growth of the flattened areas of the skull into the created spaces." The "Intended Use" section also specifies its purpose is "to improve cranial symmetry and/or shape." These functions align with the definition of a therapeutic device, as it is designed to treat a medical condition and promote healing or correction.

No

The device is a cranial orthosis used to treat abnormally shaped craniums in infants, not to diagnose a condition.

No

The device description clearly states it is a cranial orthosis composed of physical materials (thermoformable plastic, hypoallergenic foam, strap) and is custom designed and fabricated, indicating it is a physical medical device, not software-only.

Based on the provided information, the COPC Band is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • IVD Definition: In Vitro Diagnostic devices are used to examine specimens taken from the human body, such as blood, urine, or tissue, to provide information about a person's health.
  • COPC Band Function: The COPC Band is a physical orthosis applied externally to the infant's head. It works by physically guiding the growth of the skull. It does not analyze any biological samples.
  • Intended Use: The intended use clearly states it's for "passively hold[ing] prominent cranial regions... to improve cranial symmetry and/or shape." This is a mechanical/physical intervention, not a diagnostic test.

Therefore, the COPC Band falls under the category of a medical device, specifically a cranial orthosis, but not an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

The COPC Band is intended for medical purposes to passively hold prominent cranial regions of an infant's skull in order to improve cranial symmetry and/or shape in infants initiating treatment from three to 14 months of age, with nonsynostotic positional plagiocephaly, including infants with plagiocephalic, brachycephalic, and scaphocephalic patterned head shapes.

Product codes (comma separated list FDA assigned to the subject device)

MVA

Device Description

The COPC Band is a cranial orthosis used to treat abnormally shaped craniums in infants three to 14 months of age. This condition is clinically known as positional or Deformational Plagiocephaly. The orthosis contains the protruding aspects of the cranium in a static equilibrium while guiding the growth of the flattened areas of the skull into the created spaces. The COPC Band is only available through a prescription issued by a physician.

The orthosis is custom designed for each patient from a modified model and measurements of the infant's head. The mold is prepared for fabrication using advanced plaster modification techniques. Each orthosis is composed of an outer shell of thermoformable plastic, an inner lining of hypoallergenic foam, and a strap for securing Optimum fit and alignment is insured and monitored by the clinical the orthosis. practitioner.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

cranium, skull, head

Indicated Patient Age Range

three to 14 months of age

Intended User / Care Setting

physician, clinical practitioner

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

The safety of the COPC Band is established under standard biocompatibility assessments for each material used. These assessments reveal that the device and the materials used are not expected to adversely affect the infants under the intended conditions of wear, which are analogous to those for the DOC Band. The materials are not reported to cause skin irritation or any toxic effects. Further, the product is designed to avoid improper migration or harmful levels of pressure. The interior of the device is smooth and poses no significant threat to the child during application within the normal scope of its intended use. The COPC Band has incorporated within its clamshell design a natural corrugated stop, which prevents overtightening and harmful pressure upon the infant's skull. This safety feature heightens the COPC Band's safety above that of the predicate device in that the predicate device has no such inherent safeguard. The COPC Band's performance has been demonstrated and compared to the predicate device through an analysis of pressure exerted by the device upon the child's skull. Pressure sensors applied to a cranial model with a COPC Band applied, demonstrates quantifiably that intimate contact exists between the regions of cranial prominences, while no pressure exists in the regions of the cranial depressions as they are positioned over the corrective voids. This data and device performance is directly analogous with the regions of contact between the predicate device and the patient using the device.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K964992

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 882.5970 Cranial orthosis.

(a)
Identification. A cranial orthosis is a device that is intended for medical purposes to apply pressure to prominent regions of an infant's cranium in order to improve cranial symmetry and/or shape in infants from 3 to 18 months of age, with moderate to severe nonsynostotic positional plagiocephaly, including infants with plagiocephalic-, brachycephalic-, and scaphocephalic-shaped heads.(b)
Classification. Class II (special controls) (prescription use in accordance with § 801.109 of this chapter, biocompatibility testing, and labeling (contraindications, warnings, precautions, adverse events, instructions for physicians and parents)).

0

NOV 1 3 2003

The following summary is provided in pursuant to Section 513(I)(3)(A) of the Federal Food. Drug, and Cosmetic Act.

Applicant Information A.

  • Submitter: Center for Orthotic and Prosthetic Care of KY, LLC. 1010 Clarks Lane, Louisville, KY 40217. Phone: (812) 941-0966, Fax: (812) 941-0958, Email: copc@bluegrass.net
  • Contact: Keith Senn, Bob Havens, Center for Orthotic and Prosthetic Care of K Y, LLC 1010 Clarks Lane, Louisville, KY 40217. Email: copc(@bluegrass.net, Phone: (812) 941-0966
    • . Summary Date: October 15, 2003

Device Name and Classification (K021594) B.

  • Proprietary Name: COPC Band
  • Common Name: Cranial Orthosis ●
  • Classification Name: Cranial Orthosis ●
  • Predicate Device: DOC™ Band, Cranial Orthosis, K964992, classified ● under 21 CFR § 882.5970

. . . : "

C. Device Description

The COPC Band is a cranial orthosis used to treat abnormally shaped craniums in infants three to 14 months of age. This condition is clinically known as positional or Deformational Plagiocephaly. The orthosis contains the protruding aspects of the cranium in a static equilibrium while guiding the growth of the flattened areas of the skull into the created spaces. The COPC Band is only available through a prescription issued by a physician.

The orthosis is custom designed for each patient from a modified model and measurements of the infant's head. The mold is prepared for fabrication using advanced plaster modification techniques. Each orthosis is composed of an outer shell of thermoformable plastic, an inner lining of hypoallergenic foam, and a strap for securing Optimum fit and alignment is insured and monitored by the clinical the orthosis. practitioner.

1

Intended Use D.

The COPC Band is intended for medical purposes to passively hold prominent cranial regions of an infant's skull in order to improve cranial symmetry and/or shape in infants initiating treatment from three to 14 months of age, with nonsynostotic positional plagiocephaly, including infants with plagiocephalic, brachycephalic, and scaphocephalic patterned head shapes.

Comparison to Predicate Device E.

The COPC Band and the predicate device are very similar with respect to production, instructions for use, materials, safety and effectiveness, and special controls. The COPC Band combines an outer shell of thermo-formable polymer and hypoallergenic foam lining in an analogous fashion as the predicate device fits the child in a similar fashion as the predicate device, with trim lines terminating over the same points. The primary difference between the proposed and predicate devices is the side closure strap of the orthosis, where the COPC Band incorporates two straps and the DOC Band utilizes a single strap. The COPC Band utilizes modified polyethylene and aliplast as the composite materials, and the DOC Band utilizes copolymer and aliplast as its composite materials. MSDS sheets for these materials confirm that they are safe, non-hazardous, and non-reactive with human skin under normal contact conditions and environments. The material is handled in an identical manner to the polymer used in the predicate device, incorporating all of the safety and standards of practice. The proposed indications of use are analogous to those presented by the predicate device, and biocompatibility, function, and effectiveness further parallel those of the predicate device.

F. Performance Data

The safety of the COPC Band is established under standard biocompatibility assessments for each material used. These assessments reveal that the device and the materials used are not expected to adversely affect the infants under the intended conditions of wear, which are analogous to those for the DOC Band. The materials are not reported to cause skin irritation or any toxic effects. Further, the product is designed to avoid improper migration or harmful levels of pressure. The interior of the device is smooth and poses no significant threat to the child during application within the normal scope of its intended use. The COPC Band has incorporated within its clamshell design a natural corrugated stop, which prevents overtightening and harmful pressure upon the infant's skull. This safety feature heightens the COPC Band's safety above that of the predicate device in that the predicate device has no such inherent safeguard. The COPC Band's performance has been demonstrated and compared to the predicate device through an analysis of pressure exerted by the device upon the child's skull. Pressure sensors applied to a cranial model with a COPC Band applied, demonstrates quantifiably that intimate contact exists between the regions of cranial prominences, while no pressure exists in the regions of the cranial depressions as they are positioned over the corrective voids. This data and device performance is directly analogous with the regions of contact between the predicate device and the patient using the device.

2

G. Summary

The safety and effectiveness data submitted to the FDA establishes that the COPC Band is safe and effective for its intended use and is substantially equivalent to applicable predicate devices.

3

Image /page/3/Picture/1 description: The image is a black and white logo for the U.S. Department of Health & Human Services. The logo features a stylized eagle with three lines forming its body and head. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular pattern around the eagle.

Public Health Service

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

NOV 1 3 2003

Center for Orthotic and Prosthetic Care, LLC C/O Joseph Terpenning, CO 2525 North Tenth St., #804 Arlington, Virginia 22201

Re: K021594

Trade/Device Name: COPC Band Regulation Number: 21 CFR 882.5970 Regulation Name: Cranial Orthosis Regulatory Class: Class II Product Code: MV A Dated: undated Received: October 31, 2003

Dear Mr. Terpenning:

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.

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 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); good manufacturing practice requirements as set

4

Page 2 - Mr. Joseph Terpenning, CO

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. 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 and additionally 21 CFR Part 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4659. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled. "Misbranding by reference to premarket notification" (21CFR Part 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.qov/cdrh/dsma/dsmamain.html

Sincerely vours.

Mark M Millerson

Celia M. Witten, Ph.D., M.D. Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

5

510(k) Number (if known);

Device Name: COPC Band

Indications for Use:

Indications for Use Statement:

The COPC Band is intended for medical purposes to passively hold prominent cranial regions of an infant's cranium in order to improve cranial symmetry and/or shape in infants initiating treatment from three to 14 months of age, with nonsynostotic positional plagiocephaly, including infants with plagiocephalic, brachycephalic, and scaphocephalic patterned head shapes.

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED) ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

Concurrence of CDRH, Office of Device Evaluation (ODE)

Prescription Use

(Per 21 CFR 801.109) (Optional Format 1-2-96)

OR

Over the Counter Use

R. Mark A. Milken

(Division Sign-Off) Division of General. Restorative and Neurological Devices

510(k) Number K021544