K Number
K083208
Device Name
SATURN ACTIVE LASER SYSTEM
Date Cleared
2009-08-25

(298 days)

Product Code
Regulation Number
884.6200
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Saturn Active is a Laser System is to be used to drill a small tangential hole in, or to thin, the zona pellucida of the embryo in selected in vitro fertilization (IVF) patients with otherwise poor prognosis for successful pregnancy outcome such as: Advanced maternal age Prior failed IVF Cryopreserved embryos Abnormal zona pellucida morphology
Device Description
The Saturn Active Laser System is a device that images, targets, and controls the power and pulse duration of a laser beam to ablate a small tangential hole in, or thin, the Zona pellucida of an embryo for assisted hatching or other assisted reproduction procedures.
More Information

Not Found

No
The summary describes a laser system for assisted reproduction procedures and does not mention any AI or ML components or capabilities.

Yes
The device is identified as a therapeutic device because its intended use is to alter the zona pellucida of an embryo to improve the prognosis for successful pregnancy outcome in IVF patients, which constitutes a treatment or intervention.

No

The device description clearly states its purpose is to "drill a small tangential hole in, or to thin, the zona pellucida of the embryo" for assisted hatching or other assisted reproduction procedures. This is a therapeutic or procedural action, not a diagnostic one.

No

The device description explicitly states it is a "Laser System" and describes hardware components like a laser beam and controls for power and pulse duration, indicating it is a physical device, not software-only.

Based on the provided information, the Saturn Active Laser System is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • IVD devices are used to examine specimens derived from the human body. The Saturn Active Laser System directly interacts with an embryo, which is a living entity, not a specimen derived from the body for examination.
  • The intended use is a procedure performed on the embryo itself. The laser is used to modify the zona pellucida, not to analyze a sample from the embryo or the patient.
  • The device description focuses on the physical action of the laser. It describes imaging, targeting, and controlling the laser beam to ablate or thin the zona pellucida. This is a therapeutic or procedural action, not a diagnostic one.

While the procedure is related to in vitro fertilization (IVF), which involves handling biological materials outside the body, the device's function is to perform a physical modification on the embryo, not to diagnose a condition or provide information about a patient's health status based on analyzing a specimen.

N/A

Intended Use / Indications for Use

The Saturn Active Laser System is to be used to drill a small tangential hole in, or to thin, the zona pellucida of the embryo in selected in vitro fertilization (IVF) patients with otherwise poor prognosis for successful pregnancy outcome, such as: Advanced maternal age, Prior failed IVF, Cryopreserved embryos, Abnormal zona pellucida morphology.

Product codes

MRX

Device Description

The Saturn Active Laser System is a device that images, targets, and controls the power and pulse duration of a laser beam to ablate a small tangential hole in, or thin, the Zona pellucida of an embryo for assisted hatching or other assisted reproduction procedures.

Mentions image processing

The Saturn Active Laser System is a device that images, targets, and controls the power and pulse duration of a laser beam to ablate a small tangential hole in, or thin, the Zona pellucida of an embryo for assisted hatching or other assisted reproduction procedures.

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

embryo zona pellucida

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 (study type, sample size, AUC, MRMC, standalone performance, key results)

Non-clinical Testing: Measurement of laser power and pulse lengths demonstrates that the Saturn 3 delivers pulse energies comparable to the predicate. With the alignment procedure correctly performed the co-alignment of the target and the ablated hole is within 1um, this is also comparable to the predicate.
Clinical Testing: To our knowledge no clinical trials have been performed with Saturn Active.

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

Not Found

Predicate Device(s)

K060764

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 884.6200 Assisted reproduction laser system.

(a)
Identification. The assisted reproduction laser system is a device that images, targets, and controls the power and pulse duration of a laser beam used to ablate a small tangential hole in, or to thin, the zona pellucida of an embryo for assisted hatching or other assisted reproduction procedures.(b)
Classification. Class II (special controls). The special control is FDA's guidance document entitled “Class II Special Controls Guidance Document: Assisted Reproduction Laser Systems.” See § 884.1(e) for the availability of this guidance document.

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Image /page/0/Picture/1 description: The image shows a logo with the letters 'RI' in a stylized font. The letters are large and bold, with a slightly distressed texture. A curved line runs beneath the letters, adding a sense of movement or flow to the design. The overall impression is classic and elegant.

Bickland Industrial Park, Falmouth, Cornwall, ' Tel: 01326 372753 [International +44 1326 372 7 Fax: 01326 378783 [International +44 1326 378 783 e-mail: design@research-instruments.com Website: http://www.research-instruments.com/

  1. 510(k) Summary

struments.com
h-instruments.com/
XC083208.

AUG 2 5 2009

Date prepared [21CFR807.92(a)(1)]

October 22nd, 2008

Submitter's information [21CFR807.92(a)(1)]

Company Name: Research Instruments Ltd. Registration Number: 9617095 Address: Bickland Water Industrial Park Falmouth, Cornwall TR11 4TA United Kingdom Telephone: +44 (0) 1326 372 753 +44 (0) 1326 378 783 Fax: Contact person: David Lansdowne Contact Title: Technical Director Contact email: david@research-instruments.com

Trade Name, Common Name, Classification [21CFR807.92(A)(2)]

Trade Name: Saturn Active Laser System Common Name: Assisted Reproduction Laser System Device Class: 11 Regulation Number: 21CFR884.6200 Product code: MRX

Identification of Predicate Device [21CFR807.92(a)(3)

Substantial Equivalence to Research Instruments Ltd. Saturn 3 Laser System Predicate 510(k) No. K060764

Description of the device [21CFR807.92(a)(4]

The Saturn Active Laser System is a device that images, targets, and controls the power and pulse duration of a laser beam to ablate a small tangential hole in, or thin, the Zona pellucida of an embryo for assisted hatching or other assisted reproduction procedures.

Intended Use [21CFR807.92(a)(5)]

The Saturn Active Laser System is to be used to drill a small tangential hole in, or to thin, the zona pellucida of the embryo in selected in vitro fertilization (IVF) patients with otherwise poor prognosis for successful pregnancy outcome, such as: Advanced maternal age, Prior failed IVF, Cryopreserved embryos, Abnormal zona pellucida morphology.

Company Registered in England, Number: 341 9143 Registered Address: Bickland Industrial Park. Falmouth, Cornwall TR11 4TA VAT Number: 750 4247 49

Page_1_of_1

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Image /page/1/Picture/1 description: The image shows a logo with the letters 'RI' in a bold, serif typeface. A curved line underlines the letters, adding a sense of motion or emphasis to the design. The logo is simple, yet the bold font and curved line give it a distinctive and memorable appearance. The letters and line are solid black against a white background.

Bickland Industrial Park, Falmouth, Cornwall, TR11 4 Tel: 01326 372753 [International +44 1326 372 753] Fax: 01326 378783 [International +44 1326 378 783] e-mail: design@research-instruments.com Website: http://www.research-instruments.com/

Technological Characteristics [21CFR807.92(a)(5]

Features Compared and found equivalent

Laser Wavelength Laser Power Pulse time range Laser Classification Number of preset pulse times Presets user definable Pilot laser for alignment checking Pilot Laser power Pilot laser classification Custom objective to focus infrared parfocal to visible Objective magnification Objective Numerical Aperture Computer generated target Hole size indicator Still image recording Video image recording Measurement tools Report generation

Features Compared and not found equivalent

Motor module to position laser

Non-clinical Testing [21CFR807.92(b)(1)]

Measurement of laser power and pulse lengths demonstrates that the Saturn 3 delivers pulse energies comparable to the predicate. With the alignment procedure correctly performed the co-alignment of the target and the ablated hole is within 1um, this is also comparable to the predicate.

Clinical Testing [21CFR807.92(b)(2)]

To our knowledge no clinical trials have been performed with Saturn Active.

Conclusions [21CFR807.92(b)(3)]

The Research Instruments Saturn Active Laser System is substantially equivalent to the Research-Instruments Saturn 3 Laser System based on the following:

The two systems share the majority of components. The control unit, laser sources, fibre optics, collimation lens, dichroic mirror and objective are the same. The only significant difference between the two systems is the addition of a motorised beam steering module in Saturn Active.

Company Registered in England, Number: 341 9143 Registered Address: Bickland Industrial Park, Falmouth, Cornwall TR11 4TA VAT Number: 750 4247 49

Page 2 of 2

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Image /page/2/Picture/1 description: The image shows a logo with the letters 'RJ' in a stylized, bold font. A curved line underlines the letters, adding a decorative element to the design. The logo is presented in black against a white background, creating a high contrast and making the letters stand out.

Bickland Industrial Park, Falmouth, Cornwall, TR11 4TA Tel: 01326 372753 [International +44 1326 372 753] Fax: 01326 378783 [International +44 1326 378 783] e-mail: design@research-instruments.com Website: http://www.research-instruments.com/

The pulse energies delivered by the two systems are the same, and create the same sized holes in the embryo zona pellucida.

Both systems are operated in a similar way by the user.

The additional components and software have been validated by non-clinical testing.

The Research Instruments Saturn Active Laser System has the same intended use as the predicate, and has performance and method of operation substantially equivalent to the predicate.

Page 3 of 3

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Image /page/3/Picture/0 description: The image shows the seal of the Department of Health & Human Services - USA. The seal is circular and contains the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. In the center of the seal is an abstract image of a bird-like figure with three curved lines representing the wings and a stylized base. The image is in black and white.

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

Mr. David Lansdowne Technical Director Research Instruments Limited Bickland Industrial Park Falmouth, Cornwall TR114TA UNITED KINGDOM

AUG 2 5 2009

Re: K083208

Trade/Device Name: Saturn Active Laser System Regulation Number: 21 CFR §884.6200 Regulation Name: Assisted reproduction laser system Regulatory Class: II Product Code: MRX Dated: August 10, 2009 Received: August 12, 2009

Dear Mr. Lansdowne:

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 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); medical device reporting (reporting of medical

4

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/CDRHQffices/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/cdrh/indr/ 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 (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely yours,

Samur M. Mouk

Janine M. Morris Acting Director, Division of Reproductive, Abdominal, and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

5

Image /page/5/Picture/1 description: The image shows a logo with the letters "RJ" in a stylized, bold font. A curved line underlines the letters, adding a sense of elegance or emphasis to the design. The overall impression is one of a classic or established brand identity.

Bickland Industrial Park, Falmouth, Cornwall, TR11 4T/ Tel: 01326 372753 {International +44 1326 372 753] Fax: 01326 378783 {International +44 1326 378 783] e-mail: design@research-instruments.com Website: http://www.research-instruments.com/

4 Indications for Use

083208 510(k) Number (if known):

Device Name: Saturn Active Laser System

Indications for Use:

Saturn Active is a Laser System is to be used to drill a small tangential hole in, or to thin, the zona pellucida of the embryo in selected in vitro fertilization (IVF) patients with otherwise poor prognosis for successful pregnancy outcome such as:

Advanced maternal age Prior failed IVF Cryopreserved embryos Abnormal zona pellucida morphology

Prescription Use YES (Part 21 CFR 801 Subpart D) AND/OR

Over-The Counter Use NO (Part 21 CFR 801 Subpart C)

Concurrence of CDRH, Office of Device Evaluation (ODE)

Aon Khan

(Division Sign-Off) Division of Reproductive, Abdominal, and Radiological Device 510(k) Number

Page 1 of 1

Registered Address: Bickland Industrial Park, Falmouth, Comwall TR11 4TA VAT Number: 750 4247 49