K Number
K110646
Device Name
BEAMMED SUNLIGHT MINIOMNI BONE SONOMETER
Manufacturer
Date Cleared
2011-10-12

(222 days)

Product Code
Regulation Number
892.1180
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Sunlight MiniOmni Ultrasound Bone Sonometer is a non-invasive device that is designed for the quantitative measurement of the signal velocity of ultrasound waves ("Speed of Sound" or "SOS" in m/sec) propagating at multiple skeletal sites (i.e., the distal one-third of the radius, the proximal third phalanx and the fifth metatarsal). SOS provides an estimate of skeletal fragility. The output is also expressed as a T-score and a Z-score, and can be used in conjunction with other clinical risk factors as an aid to the physician in the diagnosis of osteoporosis and other medical conditions leading to reduced bone strength and, ultimately, in the determination of fracture risk. Multiple skeletal site testing provided clinicians with alternatives if one site is not accessible and with additional skeletal information (i.e., from bones with different combinations of cortical and cancellous material and from weight bearing and non-weight bearing sites) that assists in diagnosing osteoporosis and risk fracture. The SOS measured by MiniOmni has a precision error low enough in comparison with the expected annual change in a patient's measurement to make it suitable for monitoring bone changes which occur in the early years following menopause (i.e., age range approximately 50-65 years).
Device Description
The Sunlight MiniOmni Ultrasound Bone Sonometer is a noninvasive device that consists of: - Main unit, which contains an ultrasound transmission / reception printed circuit board (1) (ultrasound PCB) and mechanical and electric elements for connecting the ultrasound probes - (2) User interface and algorithmic calculation software provided in installation disc - (3) Hand-held probes (choice from 3 ultrasonic probe types already PMA-approved, plus one new probe) - Medical grade AC to DC power adaptor and cable (4) - (5) USB Connection cable - System quality verification (SQV) phantom; (6) - Spring-loaded positioning gauge; (7) - (8) Cushioned hand rest - (a) User Guide - Ultrasound gel (optional accessory) - Skin marker pencil (optional accessory) - Foot pedal (optional accessory) 12) - Sterile disinfection towelettes (optional accessory) (13) - Carrying case for easy mobility (optional accessory) (14) The MiniOmni requires connection to a stand-alone computer and visual display unit provided by the user in order to operate as intended.
More Information

Sunlight Omnisense 7000 Bone Sonometer

Not Found

No
The summary describes a device that measures ultrasound signal velocity and calculates standard scores (T-score, Z-score) based on these measurements. There is no mention of AI, ML, or any learning algorithms used in the device's operation or data processing. The performance is stated to be identical to the predicate device, which also does not suggest the introduction of AI/ML.

No
The device is a diagnostic tool used to measure bone density and assess fracture risk, but it does not provide therapy or treatment.

Yes
The device measures parameters (Speed of Sound, T-score, Z-score) that are used "in conjunction with other clinical risk factors as an aid to the physician in the diagnosis of osteoporosis and other medical conditions leading to reduced bone strength and, ultimately, in the determination of fracture risk."

No

The device description explicitly lists multiple hardware components, including a main unit with an ultrasound PCB, hand-held probes, a power adaptor, cables, and accessories like a phantom and positioning gauge. While it includes software, it is not solely software.

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

Here's why:

  • IVDs analyze samples taken from the human body. The description clearly states the Sunlight MiniOmni is a non-invasive device that uses ultrasound waves to measure bone properties directly on the body (at the radius, phalanx, and metatarsal). It does not analyze blood, urine, tissue, or any other sample taken from the patient.
  • The device measures physical properties. It measures the speed of sound through bone, which is a physical characteristic, not a chemical or biological marker analyzed in a lab setting.

The device is a medical device used for diagnostic purposes (aiding in the diagnosis of osteoporosis and fracture risk), but it falls under the category of in vivo diagnostic devices (those that perform measurements or tests directly on the living body), not in vitro diagnostics.

N/A

Intended Use / Indications for Use

The Sunlight MiniOmni Ultrasound Bone Sonometer is a non-invasive device that is designed for the quantitative measurement of the signal velocity of ultrasound waves ("Speed of Sound" or "SOS" in m/sec) propagating at multiple skeletal sites (i.e., the distal one-third of the radius, the proximal third phalanx and the fifth metatarsal). SOS provides an estimate of skeletal fragility.

The output is also expressed as a T-score and a Z-score, and can be used in conjunction with other clinical risk factors as an aid to the physician in the diagnosis of osteoporosis and other medical conditions leading to reduced bone strength and, ultimately, in the determination of fracture risk.

Multiple skeletal site testing provided clinicians with alternatives if one site is not accessible and with additional skeletal information (i.e., from bones with different combinations of cortical and cancellous material and from weight bearing and non-weight bearing sites) that assists in diagnosing osteoporosis and risk fracture.

The SOS measured by MiniOmni has a precision error low enough in comparison with the expected annual change in a patient's measurement to make it suitable for monitoring bone changes which occur in the early years following menopause (i.e., age range approximately 50-65 years).

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

MUA

Device Description

The Sunlight MiniOmni Ultrasound Bone Sonometer is a noninvasive device that consists of:

  • Main unit, which contains an ultrasound transmission / reception printed circuit board (1) (ultrasound PCB) and mechanical and electric elements for connecting the ultrasound probes
  • (2) User interface and algorithmic calculation software provided in installation disc
  • (3) Hand-held probes (choice from 3 ultrasonic probe types already PMA-approved, plus one new probe)
  • Medical grade AC to DC power adaptor and cable (4)
  • (5) USB Connection cable
  • System quality verification (SQV) phantom; (6)
  • Spring-loaded positioning gauge; (7)
  • (8) Cushioned hand rest
  • (a) User Guide
  • Ultrasound gel (optional accessory)
  • Skin marker pencil (optional accessory)
  • Foot pedal (optional accessory) 12)
  • Sterile disinfection towelettes (optional accessory) (13)
  • Carrying case for easy mobility (optional accessory) (14)

The MiniOmni requires connection to a stand-alone computer and visual display unit provided by the user in order to operate as intended.

The MiniOmni has been developed from the Sunlight Omnisense 7000S device, which was originally approved for sale in the US by means of PMA P990035. In August 2008, FDA downclassified Bone Sonometers in Product Code MUA to Class II, special controls. This 510(k) submission identifies the Omnisense 7000S as the predicate device against which substantial equivalence is demonstrated.

The functionality of the MiniOmni is not significantly different from the Omnisense 7000S, although the Omnisense 7000s included an integral computer and visual display unit. The fundamental technology and operating principles are the Omnisense 7000S. The acoustic components (algorithm, analog card, and probes) of the MiniOmni are identical or functionally equivalent to those of the Omnisense 7000S.

Three ultrasound probes (codes CMB, CRB and CSB), the SQV phantom, spring-loaded positioning gauge, and cushion hand rest are identical to those included in the PMA-approved Omnisense 7000S system. A fourth, new CMC probe has a modified assembly process when compared with the standard CMB probe, in order to provide more stable operation in humid environments.

The MiniOmni has been designed to take advantage of electronic miniaturization and updated hardware components that have become available since design and development of the Omnisense 7000S. These modifications, however, have not changed the fundamental technology or operating principles used in the Omnisense 7000S.

The software of the MiniOmni includes certain minor modifications from the predicate Omnisense 7000S software in order to allow for proper hardware communication as a result of the electronic hardware updates mentioned previously. Additionally, several user convenience features have been added to the software. All of the software differences between the MiniOmni and the Omnisense 7000S were qualified through appropriate testing using standard test methods and approved protocols to demonstrate that each function was working properly in the integrated software.

the MiniOmni software is composed of three main subsystems according to the device's hardware architecture;

  • (1) The PC subsystem;
  • (2) The digital PCB Subsystem; and
  • (3) The PC-digital PCB Interface Subsystem.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Ultrasound

Anatomical Site

distal one-third of the radius, the proximal third phalanx and the fifth metatarsal

Indicated Patient Age Range

approximately 50-65 years

Intended User / Care Setting

Physician, Clinicians

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 performance of the MiniOmni is identical to that of the predicate device.

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

Measurement Precision: 0.40%-0.81% short term in- vivo precision (skeletal site dependent) 0.25%-0.50% instrumental accuracy (probe dependent)

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.

Sunlight Omnisense 7000 Bone Sonometer

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

§ 892.1180 Bone sonometer.

(a)
Identification. A bone sonometer is a device that transmits ultrasound energy into the human body to measure acoustic properties of bone that indicate overall bone health and fracture risk. The primary components of the device are a voltage generator, a transmitting transducer, a receiving transducer, and hardware and software for reception and processing of the received ultrasonic signal.(b)
Classification. Class II (special controls). The special control for this device is FDA's “Guidance for Industry and FDA Staff; Class II Special Controls Guidance Document: Bone Sonometers.” See § 892.1(e) for the availability of this guidance document.

0

Image /page/0/Picture/0 description: The image shows the logo for BeamMed. The logo is in a serif font, with the words "BeamMed" in a larger font than the tagline. The tagline reads "Focused On Bone Health" and is located directly below the company name. The logo is black and white.

Device Name:

K110646

BeamMed MiniOmni Bone Sonometer

BeamMed Ltd. 8 Ha-Lapid Street OCT 1 2 2011 Petah Tikva 49170 lsrael

Appendix B

510(k) Summary in accordance with 21 CFR 807.92(c)

Type of 510(k) submission: Abbreviated Date of Submission: 24 February 2011 Manufacturer: BeamMed Ltd. 8 Halapid Street Petach Tikva ISRAEL 49170 FDA Establishment Registration Number: 3006701790 510(k) Owner: BeamMed Ltd. 8 Halapid Street Petach Tikva ISRAEL 49170 Trade Name: BeamMed Sunlight MiniOmni Bone Sonometer Common Name: Bone Sonometer Class: Class II Product Codes: MUA Classification Regulation: 892.1180 Predicate Device: Sunlight Omnisense 7000 Bone Sonometer Predicate Device Manufacturer: BeamMed Ltd. 8 Halapid Street Petach Tikva ISRAEL 49170

Device Description:

The Sunlight MiniOmni Ultrasound Bone Sonometer is a noninvasive device that consists of:

  • Main unit, which contains an ultrasound transmission / reception printed circuit board (1) (ultrasound PCB) and mechanical and electric elements for connecting the ultrasound probes
  • (2) User interface and algorithmic calculation software provided in installation disc
  • (3) Hand-held probes (choice from 3 ultrasonic probe types already PMA-approved, plus one new probe)
  • Medical grade AC to DC power adaptor and cable (4)
  • (5) USB Connection cable
  • System quality verification (SQV) phantom; (6)
  • Spring-loaded positioning gauge; (7)
  • (8) Cushioned hand rest
  • (a) User Guide

Page 1 of 7

1

K110646

Image /page/1/Picture/1 description: The image shows the logo for BeamMed. The logo is in a stylized font, with the words "BeamMed" in large, bold letters. Below the company name is the tagline "Focused On Bone Health" in a smaller, less bold font. The logo is simple and professional, and it conveys the company's focus on bone health.

BeamMed Ltd. 8 Ha-Lapid Street Petah Tikva 49170 lsrael

  • Ultrasound gel (optional accessory)
  • Skin marker pencil (optional accessory)
  • Foot pedal (optional accessory) 12)
  • Sterile disinfection towelettes (optional accessory) (13)
  • Carrying case for easy mobility (optional accessory) (14)

The MiniOmni requires connection to a stand-alone computer and visual display unit provided by the user in order to operate as intended.

The MiniOmni has been developed from the Sunlight Omnisense 7000S device, which was originally approved for sale in the US by means of PMA P990035. In August 2008, FDA downclassified Bone Sonometers in Product Code MUA to Class II, special controls. This 510(k) submission identifies the Omnisense 7000S as the predicate device against which substantial equivalence is demonstrated.

The functionality of the MiniOmni is not significantly different from the Omnisense 7000S, although the Omnisense 7000s included an integral computer and visual display unit. The fundamental technology and operating principles are the Omnisense 7000S. The acoustic components (algorithm, analog card, and probes) of the MiniOmni are identical or functionally equivalent to those of the Omnisense 7000S.

Three ultrasound probes (codes CMB, CRB and CSB), the SQV phantom, spring-loaded positioning gauge, and cushion hand rest are identical to those included in the PMA-approved Omnisense 7000S system. A fourth, new CMC probe has a modified assembly process when compared with the standard CMB probe, in order to provide more stable operation in humid environments.

The MiniOmni has been designed to take advantage of electronic miniaturization and updated hardware components that have become available since design and development of the Omnisense 7000S. These modifications, however, have not changed the fundamental technology or operating principles used in the Omnisense 7000S.

The software of the MiniOmni includes certain minor modifications from the predicate Omnisense 7000S software in order to allow for proper hardware communication as a result of the electronic hardware updates mentioned previously. Additionally, several user convenience features have been added to the software. All of the software differences between the MiniOmni and the Omnisense 7000S were qualified through appropriate testing using standard test methods and approved protocols to demonstrate that each function was working properly in the integrated software.

the MiniOmni software is composed of three main subsystems according to the device's hardware architecture;

  • (1) The PC subsystem;
  • (2) The digital PCB Subsystem; and
  • (3) The PC-digital PCB Interface Subsystem.

Indications for Use:

The Sunlight MiniOmni Ultrasound Bone Sonometer is a non-invasive device that is designed for the quantitative measurement of the signal velocity of ultrasound waves ("Speed of Sound" or "SOS" in m/sec) propagating at multiple skeletal sites (i.e., the distal one-third of the radius, the proximal third phalanx and the fifth metatarsal). SOS provides an estimate of skeletal fragility.

The output is also expressed as a T-score and a Z-score, and can be used in conjunction with other clinical risk factors as an aid to the physician in the diagnosis of osteoporosis and other

Page 2 of 7

2

Image /page/2/Picture/0 description: The image shows the logo for BeamMed. The logo consists of the word "BeamMed" in a stylized font, with the words "Focused On Bone Health" underneath in a smaller font. The logo is black and white.

K 110646

BeamMed Ltd. 8 Ha-Lapid Street Petah Tikva 49170 israel

medical conditions leading to reduced bone strength and, ultimately, in the determination of fracture risk.

Multiple skeletal site testing provided clinicians with alternatives if one site is not accessible and with additional skeletal information (i.e., from bones with different combinations of cortical and cancellous material and from weight bearing and non-weight bearing sites) that assists in diagnosing osteoporosis and risk fracture.

The SOS measured by MiniOmni has a precision error low enough in comparison with the expected annual change in a patient's measurement to make it suitable for monitoring bone changes which occur in the early years following menopause (i.e., age range approximately 50-65 years).

3

Image /page/3/Picture/0 description: The image shows the logo for BeamMed. The logo is in a serif font and is black. Below the logo is the tagline "Focused On Bone Health".

11/11/14/10

BeamMed Ltd. 8 Ha-Lapid Street Petah Tikva 49170 lsrael

Technological Characteristics:

The MiniOmni employs a hand-held probe designed to measure SOS values. The probe is connected by a cable to the MiniOmni Main Unit. During measurement, the probe is applied directly to the skin.

High frequency acoustic waves, at a center frequency of 1.25MHz, are produced by two transducers in the probe. The ultrasound waves are conducted along the patient's bone and detected by two different transducers in the same probe. The SOS of the bone is measured by the device.

The device software compares the SOS result with the SOS of a young healthy population, as well as an age-matched population, using an embedded reference database, and reports the comparison in the form of a T-score and a Z-score.

The user interfaces with the MiniOmni by means of items that are not supplied with the device, including PC (or laptop computer), keyboard, optional foot-pedal and printer. The operator uses these items mainly to inout patient into the PC and also for entering other administrative input required in order to operate the system.

Performance Data:

The performance of the MiniOmni is identical to that of the predicate device.

Comparison with predicate device:

The predicate device is the Sunlight 7000S Omnisense Bone Sonometer, which was the subject of PMA P990035, approved 20 January 2000.

4

K110646

BeamMed Ltd. 8 Ha-Lapid Street
Petah Tikva 49170 lsrael

ItemOmnisense 7000S (predicate)MiniOmni (subject device)
Indications for useThe Sunlight Omnisense 7000S Ultrasound Bone
Sonometer is a non-invasive device that is
designed for the quantitative measurement of the
signal velocity of ultrasound waves ("Speed of
Sound" or "SOS" in m/sec) propagating at multiple
skeletal sites (i.e., the distal one-third of the
radius, the proximal third phalanx and the fifth
metatarsal). SOS provides an estimate of skeletal
fragility.
The output is also expressed as a T-score and a
Z-score, and can be used in conjunction with
other clinical risk factors as an aid to the
physician in the diagnosis of osteoporosis and
other medical conditions leading to reduced bone
strength and, ultimately, in the determination of
fracture risk.
Multiple skeletal site testing provided clinicians
with alternatives if one site is not accessible and
with additional skeletal information (i.e., from
bones with different combinations of cortical and
cancellous material and from weight bearing and
non-weight bearing sites) that assists in
diagnosing osteoporosis and risk fracture.
The SOS measured by MiniOmni has a precision
error low enough in comparison with the expected
annual change in a patient's measurement to
make it suitable for monitoring bone changes
which occur in the early years following
menopause (i.e., age range approximately 50-65
years).Same
Measurement
ModeSpeed of Sound (SOS)Same
Measurement
Precision0.40%-0.81% short term in- vivo precision (skeletal
site dependent) 0.25%-0.50% instrumental
accuracy (probe dependent)Same
Measurement TimeApproximately 1 to 1½ minutes (3 to 5
measurement cycles of approximately 20 seconds
each)Same
Probe compatibilityThree proprietary multi-transducer probes; Centre
frequency = 1.25 MHz.Four proprietary multi-
transducer probes; Centre
frequency = 1.25 MHz.
Operating SystemMS Windows 95MS Windows XP, Windows 7
User InterfaceMouse and keyboard driven GUI (Windows 95) and
foot pedalMouse, keyboard and foot
pedal
AlgorithmsAs described in PMA 990035Same
CalibrationCalibration free; Daily System Quality Verification
(SQV) with Phantom is requiredSame
System portabilityBench mountedPortable
Screen sizeSVGA 14" Monitor (CRT) or flat-panel (LCD)Any size (software installed on
user's computer)
PrintersStandard PC printers (not supplied)
Supported Printers: HP DeskJet 690 Series, 710C
and 815C; Epson 440; Lexmark 5700; and Cannon
BJC 4400 Series.Any printer compatible with
MS Windows XP / Windows 7
and as specified in section
4.6.2 of the User Guide

Page 5 of 7

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5

Image /page/5/Picture/0 description: The image shows the logo for BeamMed. The logo is in a serif font, with the word "BeamMed" in large letters. Below the word "BeamMed" is the phrase "Focused On Bone Health" in smaller letters. The logo is black and white.

K110646

BeamMed Ltd. 8 Ha-Lapid Street Petah Tikva 49170 lsrael

ItemOmnisense 7000S (predicate)MiniOmni (subject device)
Power100-240 VAC (per specified order), 50Hz to 60 HzSame
Power
consumptionApproximately 85 VARated steady state input
consumption: 3 W
Dimensions
(w x h x d)390 mm x 130 mm x 330 mm + Video Display
monitor140 mm x 223 mm x 140 mm
WeightApproximately 7 kgApproximately 1 kg
Electrical safetyComplies with IEC 60601-1:1988, including
Amendments 1 and 2Complies with IEC 60601-1:
1988 including Amendments 1
and 2; IEC 60601-2-37: 2001
including Amendments 1 and
2; and IEC 60601-1: 2005
Electromagnetic
compatibilityComplies with IEC 60601-1-2:1993Complies with IEC 60601-1-2:
2007
Power supplyMedical grade power supplySame
Operating
EnvironmentTemperature: +10°C to +35 °C
Humidity: 30% to 75%RH, non-condensing
Atmospheric Pressure: 700 to 1060 PcSame
Storage
EnvironmentTemperature: +0 °C to 50°C
Humidity: 10% to 90% RH, non-condensingSame
Backup PlatformStandard 3.5 inch drive (1.44 MB) Zip ™ drive (100
MB)Local PC/ USB device/
network storage
Acoustic ModuleAlgorithm, analog card and probesSame

On the basis of the above comparison, the only differences between the MiniOmni device and the Omnisense 7000 device are in the following areas:

    1. The PMA-approved Omnisense 7000S device consisted of: a desktop personal computer Main Unit; a video display monitor; a keyboard; a set of earphones; ultrasound probes; SQV phantom; foot pedal; one spring- loaded positioning gauge; and a cushion hand support.
      The MiniOmni has eliminated the personal computer Main Unit, the video display monitor, a keyboard and the earphones. The MiniOmni has a separate main unit with a single 'Measure' button on top connected to the user's computer / laptop, as specified by the User Guide.
    1. The PMA-approved Omnisense 7000S device analog and digital functions are performed by two separate PCBs connected to the PC motherboard through a PCI. The MiniOmni uses a single PCB containing both the analog and digital components connected to the PC via USB.
    1. The PMA-approved Omnisense 7000S device uses three slots for connection of the different probes. The MiniOmni has one slot suitable for all probe types.

The above differences between the MiniOmni and the Omnisense 7000S do not have any effect on the safety and efficacy of the device.

Conclusion:

Based on the information contained within this submission, it is concluded that the BeamMed Sunlight MiniOmni Bone Sonometer is substantially equivalent to the identified predicate device already in interstate commerce within the USA.

Page 6 of 7

6

Image /page/6/Picture/0 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" arranged around the perimeter. Inside the circle is a stylized symbol featuring three curved lines that resemble a human figure.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Room - WO66-G609 Silver Spring, MD 20993-0002

OCT 1 2011

Ms. Rita Koremblum QA/RA Manager Beam-Med LTD 8 Halapid Str., P.O. Box 7520 Petach Tikva. 49170 ISRAEL

Re: K110646

Trade/Device Name: Sunlight MiniOmni Ultrasound Bone Sonometer Regulation Number: 21 CFR 892.1180 Regulation Name: Bone sonometer Regulatory Class: II Product Code: MUA Dated: September 11, 2011 Received: September 13, 2011

Dear Mr. Koremblum:

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 ffor the indications for usc 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 (sec above) into class II (Special Controls), it may be subject to such additional controls. Existing major regulations affecting your device can be found in Title 21, Code of Federal Regulations (CFR), Parts 800 to 895. 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 Parts 801 and 809); medical device reporting (reporting of

7

medical device-related adverse events) (21 CFR 803); and good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820). 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 Parts 801 and 1 809), please contact the Office of In Vitro Diagnostic Device Evaluation and Safety at (301) 796-5450. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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/McdicalDevices/Safety/ReportaProblem/default.htm 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 (301) 796-7100 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely Yours,

Mary Patel

Mary S. Pastel, Sc.D. Director Division of Radiological Devices Office of In Vitro Diagnostic Device Evaluation and Safety Center for Devices and Radiological Health

Enclosure

8

K110646
P. 1 of 1

Indications for Use Statement

510(k) Number (if known): Not known

Device Name: Sunlight MiniOmni Ultrasound Bone Sonometer

Indications for Use: The Sunlight MiniOmni Ultrasound Bone Sonometer is a non-invasive device that is designed for the quantitative measurement of the signal velocity of ultrasound waves ("Speed of Sound" or "SOS" in m/sec) propagating at multiple skeletal siles (i.e., the distal one-third of the radius, the proximal third phalanx and the fifth metatarsal). SOS provides an estimate of skeletal fragility.

The output is also expressed as a T-score and a Z-score, and can be used in conjunction with other clinical risk factors as an aid to the physician in the diagnosis of osteoporosis and other medical conditions leading to reduced bone strength and, ultimately, in the determination of fracture risk.

Multiple skeletal site testing provided clinicians with alternatives if one site is not accessible and with additional skeletal information (i.e., from bones with different combinations of cortical and cancellous material and from weight bearing and non-weight bearing sites) that assists in diagnosing osteoporosis and risk fracture.

The SOS measured by MiniOmni has a precision error low enough in comparison with the expected annual change in a patient's measurement to make it suitable for monitoring bone changes which occur in the early years following menopause (i.e., age range approximately 50-65 years).

Prescription Use (Part 21 CFR 801 Subpart D)

AND/OR -

X

Over-The-Counter Use (21 CFR 801 Subpart C)

ਕਿ

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

W
(Division Sign-Off)
Division of Radiological Devices
Office of In Vitro Diagnostic Device Evaluation and Safety
510K K110646