K Number
K080180
Device Name
MODIFICATION TO RETINAL FUNCTION IMAGER (RFI)
Date Cleared
2008-06-11

(139 days)

Product Code
Regulation Number
886.1120
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The Retinal Functional Imager (RFI) is intended to observe, capture, display, and store images of patients' fundus (retina) under mydriatic conditions to aid in diagnosing or monitoring diseases of the eye that may be observed and photographed.
Device Description
The modified RFI, like the cleared RFI, is a mydriatic fundus imaging camera intended for taking red-free images. The modified RFI, as the cleared device, comprises of the following sub-assemblies: - An optical system for illuminating and imaging the retina. The optical imaging includes a stroboscopic light source for sequential rapid imaging of the retina. - A high resolution CCD camera. - An electronic unit for driving the light source. - A software package for operating the system, controlling the illumination, grabbing the images, data browsing and data analysis. The device is also capable of using 35 mm film or using a digital camera similar to the predicate devices. Visible light is used for observation. Alignment and focusing is manual via the fundus camera controls. Under red-free imaging, the modified RFI provides, through a series of multiple flashes, the ability to observe and register the blood flow velocity and path of motion.
More Information

Not Found

No
The summary describes a standard fundus camera with software for image acquisition, browsing, and analysis, but there is no mention of AI or ML capabilities for image processing, diagnosis, or any other function. The analysis described is based on measuring blood flow velocity, which appears to be a direct measurement from the sequential images rather than an AI/ML-driven interpretation.

No
The device is used for imaging and measurement purposes to aid in diagnosis or monitoring, not to provide therapy.

Yes

The device is intended to "aid in diagnosing or monitoring diseases of the eye." This explicitly states its role in the diagnostic process.

No

The device description explicitly lists hardware components such as an optical system, a CCD camera, and an electronic unit, in addition to the software package.

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

Here's why:

  • IVD Definition: In vitro diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections. They are used outside of the body.
  • Device Function: The Retinal Functional Imager (RFI) is a medical device that directly images the retina within the patient's eye. It does not analyze samples taken from the body.
  • Intended Use: The intended use is to "observe, capture, display, and store images of patients' fundus (retina) under mydriatic conditions to aid in diagnosing or monitoring diseases of the eye." This is a direct imaging and diagnostic aid function, not an in vitro test.
  • Device Description: The description details an optical system, camera, and software for imaging the retina. There is no mention of handling or analyzing biological samples.

Therefore, the RFI falls under the category of an in vivo diagnostic imaging device, not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

The modified RFI, as the cleared device, is intended to observe, capture, display, and store images of patients' fundus (retina) under mydriatic conditions to aid in diagnosing or monitoring diseascs of the eye that may be observed and photographed.

The modified RFI, as the cleared device, provides information of blood flow (vclocity) and path of flow in retinal vessels, but repeatability and trueness of the retinal blood flow velocity measurement has not been established clinically.

Product codes

HKI, HLI

Device Description

'l'he modified RFI, like the cleared RFI, is a mydriatic fundus imaging camera intended for taking red-free images. The modified RFI, as the cleared device, comprises of the following sub-assemblies:

  • An optical system for illuminating and imaging the retina. The . optical imaging includes a stroboscopic light source for sequential rapid imaging of the retina.
  • A high resolution CCD camera. .
  • An electronic unit for driving the light source. .
  • A software package for operating the system, controlling the . illumination, grabbing the images, data browsing and data analysis.

The device is also capable of using 35 mm film or using a digital camera similar to the predicate devices. Visible light is used for observation. Alignment and focusing is manual via the fundus camera controls.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Optical imaging with a stroboscopic light source

Anatomical Site

fundus (retina)

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

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

Bench testing were conducted on model RFI using a model eye simulation by fixed flow rates of human blood through a pipette of diameter 80 micron inner diameter.
Bench repeatability (standard deviation of repeated measurements under identical conditions) and accuracy (measured versus calculated results) of the retinal blood flow velocity (RBFV) measurements were evaluated based on model eve simulation using fixed flow rates of human blood through a pipcttc of diameter 80 micron inner diameter. Repeated (6-8) RFI retinal blood flow velocity measurements were obtained at each of six flow rates yielding calculated velocities ranging from 0.61 to 9.06 mm/sec. Bench variability increased as velocity increased, ranging from 0.13 mm/sec at mean RFI velocity 0.68 mm/sec to 1.22 mm/sec at mean RFI velocity 9.65 mm/sec. Mean differences between the RFI mcasured vclocity and calculated velocity (RFI minus calculated) werc all positive and ranged from 0.04 mm/sec at calculated velocity 1.21 mm/sec to 0.59 mm/sec at calculated velocity 9.06 mm/sec.
The average ratio between the expected and measured velocity is 1.07 and data obtained suggest that the velocity determined by the RFI is slightly higher (6.5%) than the actual but highly correlated. The linear regression fit is Y=1.07X+0.064 and the square of the corrclation coefficient is 0.99.

Key Metrics

Bench Repeatability (Standard Deviation):

  • 1.22 at mean RFI Velocity 9.65 mm/sec (12.6% CV)
  • 0.72 at mean RFI Velocity 6.57 mm/sec (11.0% CV)
  • 0.29 at mean RFI Velocity 3.49 mm/sec (8.3% CV)
  • 0.23 at mean RFI Velocity 2.53 mm/sec (9.1% CV)
  • 0.16 at mean RFI Velocity 1.25 mm/sec (12.8% CV)
  • 0.13 at mean RFI Velocity 0.68 mm/sec (19.1% CV)

Bench Accuracy (Difference = RFI minus calculated; % Difference):

  • 0.59 (6.5%) for calculated velocity 9.06 mm/sec
  • 0.50 (8.2%) for calculated velocity 6.07 mm/sec
  • 0.45 (14.8%) for calculated velocity 3.04 mm/sec
  • 0.20 (8.6%) for calculated velocity 2.33 mm/sec
  • 0.04 (3.3%) for calculated velocity 1.21 mm/sec
  • 0.07 (11.5%) for calculated velocity 0.61 mm/sec

Linear regression fit: Y=1.07X+0.064
Square of the correlation coefficient: 0.99

Predicate Device(s)

K062416

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 886.1120 Ophthalmic camera.

(a)
Identification. An ophthalmic camera is an AC-powered device intended to take photographs of the eye and the surrounding area.(b)
Classification. Class II (special controls). The device, when it is a photorefractor or a general-use ophthalmic camera, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 886.9.

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Optical Imaging Ltd.

JUN 11 2008

K080180

510(k) Summary

Retinal Functional Imager 3000 (RFI 3000)

Date: June 4, 2008

Submitter's Name:

Optical Imaging Ltd. Openheimer St., Unit 41 Rabin Industrial Park, Rehovot Israel 76701 Tel: (972)-8-9463259 Fax: (972)-8-9463261

Establishment Registration Number: 3005503792

Contact Person:

Yoav Sella Director of QA and Regulatory Affairs Tel: (972)-8-9463259 Mobile: (972)-54-4414198 e-mail: yoav(@opt-imaging.com

Trade Name:

Retinal Functional Imager (RFI)

Classification Name:

Camera, Ophthalmic, AC Powered

Classification:

ClassificationPrimarySecondary
Product Code:HKIHLI
Class:IIII
Regulation Number21 CFR 886.112021 CFR 886.1570
Regulation NameOphthalmic CameraOphthalmoscope

Section 5

Page 1 of 5

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stical Imaging Ltd.

FDA Special 510(k)

Predicate device:

Retinal Functional Imager (RFI) - cleared under 510(k) no. K062416

Description of Modification

The Retinal Functional Imager (RFI), cleared under 510(k) number K062416, was based on the RC-XV3 Fundus Camera manufactured by KOWA, Japan.

The modified RFI is based on the TRC-50DX Fundus Camera, manufactured by Topcon, Japan. The modification was introduced for commercial reasons only.

This user manual was revised to incorporate this modification (see attachment 4.1)

Substantial Equivalence:

The modified RFI is considered to be substantially equivalent to its predicate device, Retinal Functional Imager (RFI), cleared under K062416, without raising new safety and/or effectiveness issues.

Both devices are ophthalmic imaging management systems intended to capture, display, and store images of the retina to aid in diagnosing or monitoring diseases of the retina that may be observed and photographed.

Device Description:

'l'he modified RFI, like the cleared RFI, is a mydriatic fundus imaging camera intended for taking red-free images. The modified RFI, as the cleared device, comprises of the following sub-assemblies:

  • An optical system for illuminating and imaging the retina. The . optical imaging includes a stroboscopic light source for sequential rapid imaging of the retina.
  • A high resolution CCD camera. .
  • An electronic unit for driving the light source. .
  • A software package for operating the system, controlling the . illumination, grabbing the images, data browsing and data analysis.

The device is also capable of using 35 mm film or using a digital camera similar to the predicate devices. Visible light is used for observation. Alignment and focusing is manual via the fundus camera controls.

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Optical Imaging Ltd.

Under red-free imaging, the modified RFI provides, through a series of multiple flashes, the ability to obscrve and register the blood flow velocity and path of motion.

Intended Use

The modified RFI, as the cleared device, is intended to observe, capture, display, and store images of patients' fundus (retina) under mydriatic conditions to aid in diagnosing or monitoring diseascs of the eye that may be observed and photographed.

The modified RFI, as the cleared device, provides information of blood flow (vclocity) and path of flow in retinal vessels, but repeatability and trueness of the retinal blood flow velocity measurement has not been established clinically

The Retinal Functional Imager Technology

No changes were introduced in the device technology.

The Retinal Functional Imager (RFI) is a mydriatic fundus camera designed to take retinal images using a standard high resolution digital camera mounted on a conventional fundus camera and a stroboscopic light source. The images can be taken at high frame rates. To facilitate this imaging frame rate, the flash illumination system of the fundus camera has been modified to permit the delivery of strobe flashes at the camera's full frame rate in a fixed train of discharges. This extension of normal fundus camera capabilities allows new information to be obtained from the retina by extracting reflectance changes due to the motion of red blood cells through the blood circulation of the retina between images. The software is able to map the blood flow through blood vessels in the eye and determine the velocity of the flow by tracking the motion of the blood cells, taking into account various control factors.

The fundus camera has a manufacturer-rated magnification specification different for each available magnification setting. The digital camera demagnification power and sensor size give a calibration of digital camera pixels to actual microns on the retina and is used in the determination of blood flow velocity.

RFI Software - The software for the RFI is comprised of a Grab and Browse module. The Grab module is responsible for acquiring and saving raw image data to a disk. The Browse module provides a user interface for entering patient data and selecting the mode in which Grab will operate; it also allows the operator to review the acquired data before continuing with data grab operations. Additional embedded software provides the Grab module with hardware state control and monitoring scrvices.

Section 5

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Image /page/3/Picture/0 description: The image shows the logo for Optical Imaging Ltd. The logo includes a stylized image of a lens system to the left of the text. The text "Optical Imaging Ltd." is written in a cursive font. The logo is simple and professional.

Performance Testing

A Risk Analysis was used to assess the impact of the modification on the device and its components as well as the results of the analysis;

Based on the Risk Analysis for the modified RFI device (see attachment 5.1), we have identified a need to verify the potential hazard associated with the radiation level of the modificd device.

The modified device was found to have lower radiation level, due to the use of a narrower band-pass filter, and to meet the requirement of ISO 15004-2:2007. regarding exposure threshold limits (see attachment 5.2).

Bench testing were conducted on model RFI using a model eye simulation by fixed flow rates of human blood through a pipette of diameter 80 micron inner diameter.

Bench repeatability (standard deviation of repeated measurements under identical conditions) and accuracy (measured versus calculated results) of the retinal blood flow velocity (RBFV) measurements were evaluated based on model eve simulation using fixed flow rates of human blood through a pipcttc of diameter 80 micron inner diameter. Repeated (6-8) RFI retinal blood flow velocity measurements were obtained at each of six flow rates yielding calculated velocities ranging from 0.61 to 9.06 mm/sec. Bench variability increased as velocity increased, ranging from 0.13 mm/sec at mean RFI velocity 0.68 mm/sec to 1.22 mm/sec at mean RFI velocity 9.65 mm/sec. Mean differences between the RFI mcasured vclocity and calculated velocity (RFI minus calculated) werc all positive and ranged from 0.04 mm/sec at calculated velocity 1.21 mm/sec to 0.59 mm/sec at calculated velocity 9.06 mm/sec.

The average ratio between the expected and measured velocity is 1.07 and data obtained suggest that the velocity determined by the RFI is slightly higher (6.5%) than the actual but highly correlated. The linear regression fit is Y=1.07X+0.064 and the square of the corrclation coefficient is 0.99.

The results of the bench repeatability and trueness study are provided below:

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Optical Imaging Ltd.

Table 1 - Bench Repeatability of Velocity Measurements

| Number of repeated
measurements | Mean RFI Velocity
(mm/sec) | Standard Deviation
(SD) | %CV (SD/mean) |
|------------------------------------|-------------------------------|----------------------------|---------------|
| 6 | 9.65 | 1.22 | 12.6% |
| 6 | 6.57 | 0.72 | 11.0% |
| 7 | 3.49 | 0.29 | 8.3% |
| 6 | 2.53 | 0.23 | 9.1% |
| 8 | 1.25 | 0.16 | 12.8% |
| 8 | 0.68 | 0.13 | 19.1% |

Table 2 - Bench Accuracy: Calculated Velocity versus RFI Velocity

| Mean Calculated
velocity | Mean RFI measured
velocity | Difference = RFI
minus calculated | % Difference =
difference/calculated |
|-----------------------------|-------------------------------|--------------------------------------|-----------------------------------------|
| 9.06 | 9.65 | 0.59 | 6.5% |
| 6.07 | 6.57 | 0.50 | 8.2% |
| 3.04 | 3.49 | 0.45 | 14.8% |
| 2.33 | 2.53 | 0.20 | 8.6% |
| 1.21 | 1.25 | 0.04 | 3.3% |
| 0.61 | 0.68 | 0.07 | 11.5% |

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Image /page/5/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle or bird-like figure with three curved lines forming its body and wings. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular pattern around the bird figure. The logo is black and white.

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

JUN 1 1 2008

Optical Imaging, Ltd. c/o Jonathan Kahan Partner Hogan & Hartson LLP 555 Thirteenth Street, NW Washington, DC 20004

Re: K080180

Trade/Device Name: Retinal Function Imager (RFI) 3000 Regulation Number: 21 CFR 886.1120 Regulation Name: Ophthalmic camera Regulatory Class: Class II Product Code: HKI Dated: June 4, 2008 Received: June 4, 2008

Dear Mr. Kahan:

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 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.

6

Page 2 -- Jonathan Kahan

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) 276-0115. 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 its toll-free number (800) 638-2041 or (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely yours,

Malvina B. Egleston, and

Malvina B. Eydelman, M.I Director Division of Ophthalmic and Ear, Nose and Throat Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Optical Imaging Ltd.

INDICATIONS FOR USE

510(k) Number:K080180
Device Name:Retinal Functional Imager (RFI)
Indications for Use:The Retinal Functional Imager (RFI) is intended to observe,
capture, display, and store images of patients' fundus (retina)
under mydriatic conditions to aid in diagnosing or monitoring

.

X Prescription Use (21 C.F.R. § 801.109 subpart D) OR

diseases of the eye that may be observed and photographed.

Over the Counter Use (21 C.F.R. § 801 subpart C)

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

6/10/2008

Division Sign-Off) Division of Ophthalmic Ear, Nose and Throat Devise 510(k) Number.

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