(81 days)
Laser trabeculoplasty to reduce intraocular pressure in patients with poorly controlled intraocular pressure on maximally tolerated medical therapy or prior failed laser trabeculoplasty
The SOLX 790 Titanium Sapphire system is a flashlamp-pumped laser intended for use in performing laser trabeculoplasty. The laser operates at a wavelength of 790 nanometers (nm), and delivers user-selectable pulse energies of 30-80 millijoules (mJ), with nominal pulse duration of 8 microseconds (7+2usec) and a nominal spot size of 200 microns (um). A footswitch activates the laser to deliver pulses of laser energy through an optical fiber to a slit lamp. A trained physician then directs the laser pulses exiting the slit lamp to the desired regions of the trabecular meshwork inside the eye using a Goldman goniolens. A low power, visible aiming beam allows the physician to direct the treatment laser pulses.
The SOLX 790 Titanium Sapphire Laser is a medical device intended for laser trabeculoplasty to reduce intraocular pressure in patients with poorly controlled intraocular pressure on maximally tolerated medical therapy or prior failed laser trabeculoplasty. The device's performance was assessed through preclinical and clinical investigations to demonstrate substantial equivalence to a legally marketed predicate device, the COHERENT (LUMENIS) Ultima 2000 Argon Laser (K913127).
1. Table of Acceptance Criteria & Reported Device Performance
The acceptance criteria for the SOLX 790 Titanium Sapphire Laser are based on demonstrating substantial equivalence to the predicate device, K913127, in terms of intended use, safety, and effectiveness. The table below compares the key features and performance parameters of the SOLX 790 with the predicate device. The "Reported Device Performance" column reflects the specifications of the SOLX 790, which are deemed acceptable by showing equivalence or demonstrating that differences do not raise new questions of safety or effectiveness.
| Feature / Performance Parameter | Predicate Device (Coherent Ultima 2000) Performance/Specification | Acceptance Criteria (Implied by Predicate Equivalence) | SOLX 790 Titanium Sapphire Laser Performance |
|---|---|---|---|
| Indications for Use | Treatment of ocular pathology including trabeculoplasty in open-angle glaucoma | Equivalent/Same Indications for Use | Laser trabeculoplasty to reduce intraocular pressure in patients with poorly controlled intraocular pressure on maximally tolerated medical therapy or prior failed laser trabeculoplasty |
| Clinical Treatment Power/Energy | 50-1750 mW | Safe and effective range for trabeculoplasty | 30-80 mJ |
| Pulse Duration | 0.01-1.0 sec | Safe and effective for trabeculoplasty | 7 +/- 2 microseconds |
| Laser Media | Argon | Different media is acceptable if demonstrated safe and effective | Titanium Sapphire |
| Wavelength | 488/514 nm (blue-green) | Different wavelength is acceptable if demonstrated safe and effective | 790 nm +/- 5 nm |
| Mode of Operation | CW (Continuous Wave) | Different mode is acceptable if demonstrated safe and effective | Pulsed |
| Spot Size | 50-1000 µm | Safe and effective range for trabeculoplasty | 200 um |
| Aiming Beam | Diode, variable intensity from barely visible to 1.5 mW | Visible and safe for eye targeting | Diode, variable intensity to < 5 mW |
| Laser Actuation | Footswitch | Standard and safe actuation method | Footswitch |
| Slit Lamp/Adapters | Laser compatible slit lamps | Compatible with standard ophthalmic equipment | Laser compatible slit lamp |
| Cooling System | Air cooled | Safe and effective cooling | Internal water cooled |
| Dimensions | 47 cm x 20 cm x 60 cm (h x w x d) (18.5" x 8" x 24") | Practical and manageable size | Height: 38" (96 cm), Width: 16" (40 cm), Depth: 27" (68 cm) including cord wrap |
| Weight | 30 kg (65 lbs) | Manageable weight | 140 lbs (81 kg) |
| Electrical Requirements | 100-120 VAC; 15-20 A, 220-240 VAC; 10 A, 50/60 Hz | Standard electrical compatibility | 120 VAC/15 Amps (can also be run from 200-240 VAC service), approximately 500 Watts, 50-60 Hz |
Study Proving Device Meets Acceptance Criteria:
The submission explicitly states that "Preclinical and clinical data was provided to demonstrate that the Titanium Sapphire is safe and effective for use in trabeculoplasty to reduce intraocular pressure in patients with poorly controlled or elevated intraocular pressure or prior failed laser trabeculoplasty." The overarching study design is one of demonstrating substantial equivalence to the predicate device.
2. Sample Size Used for the Test Set and Data Provenance:
The document does not explicitly state the sample size for the test set of the clinical investigation, nor does it specify the country of origin of the data or whether the study was retrospective or prospective. It only broadly refers to "clinical investigations."
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:
The document does not provide details on the number of experts, their qualifications, or their role in establishing ground truth for the clinical investigation mentioned.
4. Adjudication Method:
The document does not describe any specific adjudication method (e.g., 2+1, 3+1, none) for establishing ground truth within the clinical investigation.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
The provided information does not mention a Multi-Reader Multi-Case (MRMC) comparative effectiveness study. The comparison is primarily between the new device's specifications and the predicate device's specifications, along with general statements about clinical data demonstrating safety and efficacy without a direct human reader comparison in the context of AI.
6. Standalone (Algorithm Only) Performance Study:
This device is a physical laser system, not an AI algorithm. Therefore, a standalone (algorithm only) performance study is not applicable. The performance is of the laser system itself, operated by a physician.
7. Type of Ground Truth Used:
The ground truth for demonstrating the safety and effectiveness of the SOLX 790 Titanium Sapphire Laser would be based on clinical outcomes data related to intraocular pressure reduction and safety profiles in patients undergoing laser trabeculoplasty. This means the actual physiological changes and patient responses observed in the clinical investigation.
8. Sample Size for the Training Set:
This device is a hardware system, not an AI algorithm that requires a "training set" in the conventional machine learning sense. Therefore, the concept of a training set sample size is not applicable.
9. How the Ground Truth for the Training Set Was Established:
As explained above, the concept of a "training set" and associated ground truth establishment is not relevant to this type of medical device submission.
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Revised August 11, 2008
SEP 1 2 2008
510(k) Summary of safety and effectiveness
| APPLICANT | SOLX, Inc. |
|---|---|
| TRADE NAME: | SOLX 790 Titanium Sapphire Laser |
| COMMON NAME: | Ophthalmic Laser |
| CLASSIFICATION NAME: | Ophthalmic lasers for use in laser trabeculoplasty |
| DEVICE CLASSIFICATION: | Class II |
| PRODUCT CODE | CFR 886.4390 Product code HQF (laser, ophthalmic) andCFR 878.4810 Product code GEX (laser surgicalinstrument). |
| PREDICATE DEVICE: | ULTIMA 2000 ARGON LASER K913127 |
USER FEE PAYMENT ID:
SUBSTANTIALLY EQUIVALENT TO:
| COHERENT (LUMENIS) | Ultima 2000 Argon Laser | K913127 |
|---|---|---|
| -------------------- | ------------------------- | --------- |
The SOLX 790 Titanium Sapphire Laser is substantially equivalent in intended of action to the Coherent/Lumenis Ultima 2000 Argon Laser approved under K913127.
5.1 DESCRIPTION OF THE DEVICE SUBJECT TO PREMARKET NOTIFICATION:
The SOLX 790 Titanium Sapphire system is a flashlamp-pumped laser intended for use in performing laser trabeculoplasty. The laser operates at a wavelength of 790 nanometers (nm), and delivers user-selectable pulse energies of 30-80 millijoules (mJ), with nominal pulse duration of 8 microseconds (7+2usec) and a nominal spot size of 200 microns (um). A footswitch activates the laser to deliver pulses of laser energy through an optical fiber to a slit lamp. A trained physician then directs the laser pulses exiting the slit lamp to the desired regions of the trabecular meshwork inside the eye using a Goldman goniolens. A low power, visible aiming beam allows the physician to direct the treatment laser pulses.
PRODUCT INFORMATION
The laser is comprised of the following functional components:
- Electronics Module .
- Laser Optical Head
- Control Panel .
- Slit Lamp/Slit Lamp Table ●
- Covered Footswitch .
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Table A Comparison of SOLX 790 Titanium Sapphire Laser and Predicate Device
| SOLX | Coherent Ultima 2000 | |
|---|---|---|
| 790 Titanium | Argon Ophthalmic Laser | |
| Sapphire | K913127 | |
| Ophthalmic Laser | ||
| Indications for Use | Laser trabeculoplasty toreduce intraocular pressure inpatients with poorlycontrolled intraocularpressure on maximallytolerated medical therapy orprior failed lasertrabeculoplasty | *Indicated for use in thetreatment of ocularpathology includingtrabeculoplasty in open-angle glaucoma |
| Clinical TreatmentPower/Energy | 30-80mJ | 50-1750 mW |
| Pulse duration | 7±2 microseconds | 0.01-1.0 sec |
| Laser Media | Titanium Sapphire | Argon |
| Wavelength | 790 nm ± 5 nm | *488/514 nm (blue-green) |
| Mode of Operation | pulsed | CW |
| Spot Size | 200 um | *50-1000 µm |
| Aiming Beam | Diode, variableintensity to < 5 mW | Diode, variable intensity frombarely visible to 1.5 mW |
| Laser Actuation | Footswitch | Footswitch |
| Slit Lamp/Slit LampAdapters | Laser compatibleslit lamp | Laser compatible slitlamps |
| Cooling System | Internal watercooled | Air cooled |
| Dimensions | Height: 38" (96 cm)Width: 16" (40 cm)Depth: 27" (68 cm),including cord wrap | 47 cm x 20 cm x 60 cm(18.5" x 8" x 24")(h x w x d) |
| Weight | Weight: 140 lbs(81 kg) | 30 kg (65 lbs) |
| ElectricalRequirements | 120 VAC/ 15 Amps- It can also be runfrom 200-240 VACservice.The system drawsapproximately 500Watts.50-60 Hz | 100-120 VAC; 15-20 A220-240 VAC; 10 A50/60 Hz |
5.2 INDICATION FOR USE: SOLX 790 TITANIUM
Laser trabeculoplasty to reduce intraocular pressure in patients with poorly controlled intraocular pressure on maximally tolerated medical therapy or prior failed laser trabeculoplasty.
5.3 RATIONALE FOR SUBSTANTIAL EQUIVALENCE
The Titanium Sapphire Laser shares the same indications for use and similar design features (treatment area, aiming beam, delivery system, similar cooling system, and control system) as the predicate device. The Titanium Sapphire Laser has different functional features from the predicate device, including energy delivered and spot size. The effects of the new functional
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features in performing trabeculoplasty have been assessed through preclinical and clinical investigations. The data obtained from these investigations demonstrate that the Titanium Sapphire Laser is substantially equivalent to the predicate laser system.
5.4 SAFETY AND EFFECTIVENESS INFORMATION
Preclinical and clinical data was provided to demonstrate that the Titanium Sapphire is safe and effective for use in trabeculoplasty to reduce intraocular pressure in patients with poorly controlled or elevated intraocular pressure or prior failed laser trabeculoplasty.
In addition, hazard analysis information was provided.
5.5 CONCLUSION
The Titanium Sapphire Laser is substantially equivalent to currently marketed predicate laser device. The device shares the same intended use/indications for use and other basic system characteristics as the predicate laser system. Preclinical study results demonstrate the substantial equivalence as well as the safety and effectiveness of the Titanium Sapphire Laser for use in trabeculoplasty.
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Public Health Service
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
SEP 1 2 2008
SOLX, Inc. c/o Mr. Doug Adams President SOLX, Inc. 890 Winter Street, Suite 115 Waltham, MA 02451
Re: K081774
Trade/Device Name: SOLX 790 Titanium Sapphire Laser Regulation Number: 21 CFR 886.4390 Regulation Name: Ophthalmic laser Regulatory Class: Class II Product Code: HQF, GEX Dated: June 19, 2008 Received: June 26, 2008
Dear Mr. Adams:
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.
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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. Edwards, and
Malvina B, Eydelman, M.D 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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Indications for Use Statement
510(k) Number (if known): _ 130 Ko 8/774
Device Name: SOLX 790 Titanium Sapphire Laser
Laser trabeculoplasty to reduce intraocular pressure in patients with poorly controlled intraocular pressure on maximally tolerated medical therapy or prior failed laser trabeculoplasty
Prescription Use X AND/OR (Part 21 CFR 801 Subpart D)
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)
Joe Calloway
(Division Sign-Off)
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Division of Ophthalmic Ear, Nose and Throat Devises
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510(k) Number_________________________________________________________________________________________________________________________________________________________________
§ 886.4390 Ophthalmic laser.
(a)
Identification. An ophthalmic laser is an AC-powered device intended to coagulate or cut tissue of the eye, orbit, or surrounding skin by a laser beam.(b)
Classification. Class II.