(385 days)
The Boston Keratoprosthesis is indicated to provide a transparent optical pathway through an opacified cornea in an eye that is not a reasonable candidate for any form of corneal transplant, including penetrating keratoplasty.
The Boston Keratoprosthesis is an artificial corneal device that can be used in patients with severe corneal opacity. The Boston Keratoprosthesis is used after standard corneal transplant has failed or when such a transplant would be unlikely to succeed. Thus, keratoprosthesis implantation is a procedure designed to help patients whose conditions are the most difficult to treat. This 510(k) seeks to modify the back plate material from PMMA to titanium. In doing so, the modified implant eliminates the need for a titanium retaining ring which was employed in the predecessors to hold the PMMA back plate in position following implantation. This also simplifies the assembly. It is available in two types. The Type I keratoprosthesis is implanted through and fixed only to the cornea and is used for corneal blindness when the eyelids, blink mechanism and tear film are intact. The Type II keratoprosthesis has an anterior extension to enable implantation through an opening in the closed eyelids. The Type II device is used in eyes with severe dry eye, mucosal keratinization and obliteration of the normal conjunctival fornices, such as after severe chemical injuries or Stevens Johnson syndrome or mucous membrane pemphigoid. Both devices are identical in terms of assembly.
Here's a breakdown of the acceptance criteria and study information for the Boston Keratoprosthesis, based on the provided document:
1. Table of Acceptance Criteria and Reported Device Performance
The document doesn't explicitly state quantitative acceptance criteria in terms of specific performance metrics (e.g., visual acuity targets, failure rates, etc.). Instead, the primary acceptance criterion is substantial equivalence in safety and effectiveness compared to the predicate device.
| Acceptance Criterion (Implicit) | Reported Device Performance (Titanium Back Plate) |
|---|---|
| Safety: The modified device (titanium back plate) is as safe as the predicate device (PMMA back plate), with no new issues of safety raised. This is assessed through biocompatibility and a comparison of adverse events/complications. | Clinical data shows the titanium back plate is "as safe" as the predicate PMMA back plate. Non-clinical testing demonstrates the titanium version is biocompatible. |
| Effectiveness: The modified device is as effective as the predicate device, providing a transparent optical pathway in the intended patient population. This is assessed by comparing outcomes. | Clinical data shows the titanium back plate is "as effective" as the predicate PMMA back plate. The device fulfills prospectively defined performance criteria, and the modified system meets user needs. |
| Biocompatibility: The new material (titanium) is biocompatible. | Non-clinical testing demonstrates that the titanium version is biocompatible. |
| Similar Assembly Strength Profiles: The change in material does not negatively impact the structural integrity of the device. | Non-clinical testing demonstrates the titanium version possesses similar assembly strength profiles to the PMMA version. |
| Manufacturability/Sterility/Shelf Life: The manufacturing process, sterilization, and shelf life are acceptable. | Validation activities included Sterility Validation, Bioburden, LAL, MRI Compatibility, and Shelf Life Testing. (Presumed successful, as equivalence was affirmed). |
| No new issues of safety and effectiveness: The design differences do not introduce unforeseen problems. | All data collected confirms that the differences in the design of the Boston Keratoprosthesis with titanium back plate do not raise any new issues of safety and effectiveness when compared to the predicate design. |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size (Clinical Performance Data):
- Modified Titanium Back Plate Device: 86 eyes in 86 subjects
- Predicate PMMA Device: 55 eyes in 50 subjects
- Data Provenance: The document does not explicitly state the country of origin. Given the sponsor is "Massachusetts Eye & Ear Infirmary," it is highly probable the data is from the United States. The study is described as having a "mean follow-up of 14.8 months with a maximum follow-up of 38 months," indicating a prospective collection of follow-up data post-implantation for these cohorts, although the specific start date relative to the device modification isn't given.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Their Qualifications
The document does not mention experts being used to establish "ground truth" in the way one would for an AI diagnostic device (e.g., image interpretation). This device is a surgical implant; its performance is assessed through clinical outcomes and physical properties. Therefore, there's no "ground truth" derived from expert image interpretation in this context.
4. Adjudication Method for the Test Set
Not applicable. As this is not an AI diagnostic device and there's no expert "ground truth" to adjudicate for a test set of data points, there is no mention of an adjudication method. Clinical outcomes would typically be recorded by treating physicians.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No. This is not an AI diagnostic device, so an MRMC study comparing human readers with and without AI assistance is not relevant or reported.
6. Standalone (Algorithm Only) Performance Study
No. This is not an AI algorithm. It's a physical medical device (an implant). Therefore, a standalone performance study in the context of an algorithm is not applicable.
7. Type of Ground Truth Used
The "ground truth" for this device's performance is established through clinical outcomes data (e.g., safety profiles, effectiveness in providing a transparent optical pathway, long-term follow-up results) and non-clinical engineering testing (e.g., biocompatibility, assembly strength, sterility, shelf life). The key is demonstrating that the modified device's performance is "as safe and effective" as the predicate device.
8. Sample Size for the Training Set
Not applicable. This is not an AI algorithm, so there is no "training set."
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no training set.
{0}------------------------------------------------
MAY 1 0 2013
510(k) Summary (per 21 CFR 807.92) Boston Keratoprosthesis
1. Sponsor
Massachusetts Eye & Ear Infirmary, d/b/a Boston Keratoprosthesis 243 Charles Street Boston, MA 02114
Contact Person: Larisa Gelfand Position: Manager of Boston Keratoprosthesis Program Telephone: 617-573-4463
2. CONSULTANT/CONTACT
Aptiv Solutions 43 Plain Street North Attleboro, MA 02760
Primary Contact: Brian J. Edwards Position: Senior Regulatory Staff Consultant Telephone: 651-542-1413
3. DEVICE NAME
| Proprietary Name: | Boston Keratoprosthesis, Type I or Type II |
|---|---|
| Common/Usual Name: | Keratoprosthesis |
| Classification Name: | Keratoprosthesis, Permanent Implant |
| Product Code: | HQM |
| Regulation Number: | 21 CFR 886.3400 |
4. PREDICATE DEVICES
- · Massachusetts Eye & Ear Infirmary's Keratoprosthesis previously cleared on January 21, 1992 under Premarket Notification Number K915062.
5. DEVICE DESCRIPTION
The Boston Keratoprosthesis is an artificial corneal device that can be used in patients with severe corneal opacity.
The Boston Keratoprosthesis is used after standard corneal transplant has failed or when such a transplant would be unlikely to succeed. Thus, keratoprosthesis implantation is a procedure designed to help patients whose conditions are the most difficult to treat.
{1}------------------------------------------------
This 510(k) seeks to modify the back plate material from PMMA to titanium. In doing so, the modified implant eliminates the need for a titanium retaining ring which was employed in the predecessors to hold the PMMA back plate in position following implantation. This also simplifies the assembly.
It is available in two types. The Type I keratoprosthesis is implanted through and fixed only to the cornea and is used for corneal blindness when the eyelids, blink mechanism and tear film are intact. The Type II keratoprosthesis has an anterior extension to enable implantation through an opening in the closed eyelids. The Type II device is used in eyes with severe dry eye, mucosal keratinization and obliteration of the normal conjunctival fornices, such as after severe chemical injuries or Stevens Johnson syndrome or mucous membrane pemphigoid.
Both devices are identical in terms of assembly.
6. INTENDED USE
The Boston Keratoprosthesis is indicated to provide a transparent optical pathway through an opacified cornea in an eye that is not a reasonable candidate for any form of corneal transplant, including penetrating keratoplasty.
7. TECHNOLOGICAL CHARACTERISTICS AND SUBSTANTIAL EQUIVALENCE
The subject of this 510(k) is a modification of the Boston Keratoprosthesis that was previously cleared on January 21, 1992 under Premarket Notification Number K915062. The subject of this 510(k) is the change in material of the back plate from the original poly(methy) methacrylate) (PMMA) to titanium, with elimination of the necessity for the titanium locking ring. The new titanium back plate combines back plate and locking ring functions.
8. PERFORMANCE TESTING
Validation activities to support the use of the Boston Keratoprosthesis device consisted of the following elements:
- Sterility Validation
- Bioburden ●
- LAL .
- MRI Compatibility .
- Shelf Life Testing
Testing of the Boston Keratoprosthesis has demonstrated that the material change from PMMA to titanium does not modify product performance and the product fulfills prospectively defined performance criteria and that the modified system meets user needs.
9. CLINICAL TESTING
{2}------------------------------------------------
The clinical performance data included 86 eyes in 86 subjects implanted with the modified titanium back plate device and 55 eyes in 50 subjects with the predicate polymethyl methacrylate (PMMA) device. For implanted eyes, mean follow-up was 14.8 months with a maximum follow-up of 38 months.
The clinical data shows that the titanium back plate is as safe and effective as the predicate PMMA back plate for use in the Boston Keratoprosthesis.
10. CONCLUSIONS DRAWN FROM NON-CLINICAL AND CLINICAL TESTS
The Boston Keratoprosthesis with titanium back plate has the same intended use and similar technological characteristics as the Boston Keratoprosthesis with PMMA back plate predicate device. Non-clinical testing demonstrates that the titanium version is biocompatible and possesses similar assembly strength profiles to the PMMA version.
All the data collected confirms that the differences in the design of the Boston Keratoprosthesis with titanium back plate does not raise any new issues of safety and effectiveness when compared to the predicate design with a PMMA back plate.
{3}------------------------------------------------
Image /page/3/Picture/0 description: The image shows the text "DEPARTMENT OF HEALTH & HUMAN SERVICES" in a bold, sans-serif font. The text is all capitalized and arranged on a single line. The words are evenly spaced, and the overall appearance is clean and professional.
Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized caduceus symbol, which is a staff with two snakes coiled around it, and the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged in a circular fashion around the symbol. The caduceus is depicted with three overlapping, stylized figures, and the text is in all caps.
May 10, 2013
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
Massachusetts Eye & Ear Infirmary % Mr. Brian J. Edwards Senior Regulatory Staff Consultant 62 Forest Street, Suite 300 Marlborough, MA 01752
Re: K121203
Trade/Device Name: Boston Keratoprosthesis, Type I and Type II Regulation Number: 21 CFR 886.3400 Regulation Name: Keratoprosthesis Regulatory Class: Class II Product Code: HQM Dated: April 25, 2013 Received: April 26, 2013
Dear Mr. Edwards:
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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
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 device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set
{4}------------------------------------------------
Page 2 - Mr. Brian J. Edwards
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 contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. 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/MedicalDevices/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/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours,
Kesia YFAlexander -S
for 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
{5}------------------------------------------------
Indications for Use
510(k) Number (if known): 121203
Device Name: Boston Keratoprosthesis
Indications for Use:
The Boston Keratoprosthesis is indicated to provide a transparent optical pathway through an opacified cornea in an eye that is not a reasonable candidate for any form of corneal transplant, including penetrating keratoplasty.
Prescription Use X (Part 21 CFR 801 Subpart D) AND/OR
Over-the-Counter Use (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED) Concurrence of CDRH, Office of Device Evaluation (ODE)
TieuviH.Nguyen
2013.05.09 16:34:40 '04'00'
(Division Sign-Off) Division of Ophthalmic and Ear, Nose and Throat Devices 510(k) Number: K121203
§ 886.3400 Keratoprosthesis.
(a)
Identification. A keratoprosthesis is a device intended to provide a transparent optical pathway through an opacified cornea, either intraoperatively or permanently, in an eye that is not a reasonable candidate for a corneal transplant.(b)
Classification. Class II. The special controls for this device are FDA's:(1) “Use of International Standard ISO 10993 ‘Biological Evaluation of Medical Devices—Part I: Evaluation and Testing,’ ”
(2) “510(k) Sterility Review Guidance of 2/12/90 (K90-1),” and
(3) “Guidance on 510(k) Submissions for Keratoprostheses.”