K Number
K140353
Device Name
STARBAND AND STARLIGHT
Date Cleared
2014-06-06

(114 days)

Product Code
Regulation Number
882.5970
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The STARband and STARlight are intended for medical purposes for use on infants from 3 to 18 months of age, with moderate-to-severe non-synostotic positional plagiocephaly, including infants with plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads by applying mild pressure to prominent regions of the infant's cranium in order to improve cranial symmetry and/or shape. The devices are also indicated for adjunctive use for infants from 3 to 18 months of age whose synostosis has been surgically corrected, but who still have moderate-to-severe cranial deformities including plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads.
Device Description
The STARband and STARlight redirects the head growth to improve proportion and symmetry. The practitioner takes a plaster impression or 3-dimensional captured image of the infant's head to acquire the existing shape. The mold is sealed and filled with plaster or the 3-dimensional image is carved from a rigid polyurethane foam blank to create a positive model of the head shape. The positive model is modified to obtain greater symmetry and space in the areas of flattening. The STARband and STARlight provides total contact over the prominent or bossed areas of the baby's head to discourage growth there. Over the course of treatment, the inside of the band is further modified by the practitioner to provide space for growth to occur in the flat or depressed areas. The shape of the STARband and STARlight directs growth into the areas of least resistance and creates a precise pathway for the head shape to improve in symmetry and proportion. The STARband Side Opening design and STARband Bi-Valve design is made with an outer shell of 5/32" polyethylenepolypropylene copolymer plastic with an inner liner made of 1/2" pelite polyethylene foam or 1/2" Aliplast foam (closed cell polyethylene). The STARlight Side Opening design and the STARlight Bi-Valve design are made of a plastic shell of 5/32" - 1/4" clear Surlyn or 1/8" - 7/32" Clear Co-Polyester. The STARlight PRO (Post-operative Remolding Orthosis) design is made of 1/4" to 3/8" clear Surlyn. Optional Aliplast (closed cell polyethylene) padding is available for the clear plastic bands and in addition, optional Reston (polyurethane - 3M Medical Product) foam is available for the STARlight PRO design. The STARband Side Opening design and the STARlight Side Opening design has a top opening and a side opening. The band is held in place by a Velcro® strap (1 ½' for STARband Side Opening and 1" for STARlight Side Opening) across the side opening. The STARlight PRO has two side openings, no top opening, and is held in place by a Velcro strap across each side opening. The STARlight Bi-Valve design and the STARband Bi-Valve design consist of two plastic shells that overlap with a superior sliding mechanism. The right and left overlap tabs are connected via a Velcro strap with chafe and loop. The proposed device modification is the addition of three new systems to use for 3dimensional shape capture, specifically, the 3dMDhead™ System, the 3dMDcranial™ System and the 3dMDflex™ System all distributed by 3dMD, Inc. These systems use a non-coherent (i.e. non-laser light) structured light source and triangulated cameras to capture shape data.
More Information

Not Found

No
The description focuses on the physical design of the cranial orthosis and the method of capturing the infant's head shape using structured light and cameras. There is no mention of AI or ML being used in the device's function, design process, or data analysis.

Yes.
The device is intended to improve cranial symmetry and/or shape in infants and is also indicated for adjunctive use for infants whose synostosis has been surgically corrected, but who still have moderate-to-severe cranial deformities. These descriptions align with the definition of a therapeutic device as it is treating or ameliorating a condition.

No

The device is a cranial orthosis intended to improve cranial symmetry and shape, not to diagnose a medical condition.

No

The device description clearly outlines physical components (plastic shells, foam liners, Velcro straps) that are integral to the device's function of applying pressure to the infant's cranium. While it utilizes 3D imaging software for capturing head shape, the core therapeutic component is a physical orthosis.

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.
  • Device Function: The STARband and STARlight are external devices applied to the infant's head to physically reshape the skull. They do not analyze biological samples or provide diagnostic information based on such analysis.
  • Intended Use: The intended use is to treat moderate-to-severe non-synostotic positional plagiocephaly and adjunctive use after surgical correction of synostosis by applying pressure to the cranium. This is a therapeutic intervention, not a diagnostic one.
  • Device Description: The description details the physical construction of the bands and the process of creating a custom orthosis based on the head shape. It does not involve any in vitro testing.

The device is a medical device, specifically a cranial orthosis, used for treatment rather than diagnosis.

N/A

Intended Use / Indications for Use

The STARband and STARlight are intended for medical purposes for use on infants from 3 to 18 months of age, with moderate-to-severe non-synostotic positional plagiocephaly, including infants with plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads by applying mild pressure to prominent regions of the infant's cranium in order to improve cranial symmetry and/or shape. The devices are also indicated for adjunctive use for infants from 3 to 18 months of age whose synostosis has been surgically corrected, but who still have moderate-to-severe cranial deformities including plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads.

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

MVA, OAN

Device Description

The STARband and STARlight redirects the head growth to improve proportion and symmetry. The practitioner takes a plaster impression or 3-dimensional captured image of the infant's head to acquire the existing shape. The mold is sealed and filled with plaster or the 3-dimensional image is carved from a rigid polyurethane foam blank to create a positive model of the head shape. The positive model is modified to obtain greater symmetry and space in the areas of flattening. The STARband and STARlight provides total contact over the prominent or bossed areas of the baby's head to discourage growth there. Over the course of treatment, the inside of the band is further modified by the practitioner to provide space for growth to occur in the flat or depressed areas. The shape of the STARband and STARlight directs growth into the areas of least resistance and creates a precise pathway for the head shape to improve in symmetry and proportion.

The STARband and STARlight product families as it was released in K124023 and K133250 are essentially still the same devices. The STARband Side Opening design and STARband Bi-Valve design is made with an outer shell of 5/32" polyethylenepolypropylene copolymer plastic with an inner liner made of 1/2" pelite polyethylene foam or 1/2" Aliplast foam (closed cell polyethylene). The STARlight Side Opening design and the STARlight Bi-Valve design are made of a plastic shell of 5/32" - 1/4" clear Surlyn or 1/8" - 7/32" Clear Co-Polyester. The STARlight PRO (Post-operative Remolding Orthosis) design is made of 1/4" to 3/8" clear Surlyn. Optional Aliplast (closed cell polyethylene) padding is available for the clear plastic bands and in addition, optional Reston (polyurethane - 3M Medical Product) foam is available for the STARlight PRO design.

The STARband Side Opening design and the STARlight Side Opening design has a top opening and a side opening. The band is held in place by a Velcro® strap (1 ½' for STARband Side Opening and 1" for STARlight Side Opening) across the side opening. The STARlight PRO has two side openings, no top opening, and is held in place by a Velcro strap across each side opening. The STARlight Bi-Valve design and the STARband Bi-Valve design consist of two plastic shells that overlap with a superior sliding mechanism. The right and left overlap tabs are connected via a Velcro strap with chafe and loop.

The proposed device modification is the addition of three new systems to use for 3dimensional shape capture, specifically, the 3dMDhead™ System, the 3dMDcranial™ System and the 3dMDflex™ System all distributed by 3dMD, Inc. These systems use a non-coherent (i.e. non-laser light) structured light source and triangulated cameras to capture shape data. Because these scanners utilize a non-coherent light source, they are safe to use on infant patients under all circumstances (equivalent to a Class 1 laser).

Mentions image processing

Yes

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

structured light source and triangulated cameras

Anatomical Site

Cranium/Head

Indicated Patient Age Range

3 to 18 months of age

Intended User / Care Setting

Prescription Only; implied medical practitioner/orthotist

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)

Repeatability and Reproducibility (R&R) Analysis:

  • Utilized uniform shapes with known dimensions that represent various sizes of pediatric patients between ages 3 to 18 months of age.
  • Compared proposed device to cast and predicate device.
  • Associated parameters include A-P and M-L.
  • Conclusion: Proposed device is substantially equivalent to predicate device.

Cranial Shape Capture Accuracy Study:

  • Utilized a representative cranial shape that possesses a predefined shape with known dimensions.
  • Compared proposed device to cast and predicate device.
  • Associated Coordinate Planes (A-P; M-L; P-D and various Radius Parameters; Squareness; Flatness).
  • Conclusion: Proposed device is substantially equivalent to predicate device.

Material Biocompatibility Testing:

  • Cytotoxicity - Agar Diffusion
  • Closed Patch Sensitization
  • Results are provided in Table 2, stating conclusions such as "Not a Sensitizer," "Negligible Dermal Response," and "Non-cytotoxic" for Surlyn, Copolymer with Pelite Foam, and Copolymer with Aliplast Foam.

Specifically, for the 3dMD Systems:

  • The 3dMDhead™ System, the 3dMDcranialTM System and the 3dMDflex™ System were all evaluated for safety and efficacy.
  • The scanner uses a quick flash of structured white light, equivalent to a consumer grade camera flash, and is shown to be safe for infants without extra eye protection.
  • Shape capture repeatability and reproducibility was evaluated and determined to be acceptable.
  • An additional Cranial Shape Capture Accuracy Study was performed.
  • Conclusion: The 3dMD Systems yield a safe and effective product that is substantially equivalent to the predicate device, with sufficient accuracy and no safety concerns for scanning infants for STARband and STARlight Cranial Orthosis.

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

Not Found

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.

K124023, K133250, K014012

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

§ 882.5970 Cranial orthosis.

(a)
Identification. A cranial orthosis is a device that is intended for medical purposes to apply pressure to prominent regions of an infant's cranium in order to improve cranial symmetry and/or shape in infants from 3 to 18 months of age, with moderate to severe nonsynostotic positional plagiocephaly, including infants with plagiocephalic-, brachycephalic-, and scaphocephalic-shaped heads.(b)
Classification. Class II (special controls) (prescription use in accordance with § 801.109 of this chapter, biocompatibility testing, and labeling (contraindications, warnings, precautions, adverse events, instructions for physicians and parents)).

0

510(k) Summary

K140353 JUN 0 6 2014

I. Applicant Information

Name:Orthomerica Products, Inc.
Address:6333 North Orange Blossom Trail
Orlando, FL 32810
Telephone:(407) 290-6592
Facsimile:(407) 290-2419

FDA Establishment Registration Number

1058152

Contact Information

Contact Person:David Hooper, Manufacturing Engineer
Address:6333 North Orange Blossom Trail
Orlando, FL 32810
Telephone:(407) 290-6592
Facsimile:(407) 290-2419
Email:dhooper@orthomerica.com
Date Prepared:February 7, 2014

II. Submission Information

Type:Traditional 510(k) Submission
Proprietary Name:STARband® and STARlight®
Common Name:Cranial Orthosis
Classification:Class II (special controls); OAN; MVA; 21 CFR 882.5970
Classification Name:Cranial Orthosis

III. Manufacturer Site

Name:Orthomerica Products, Inc.
Address:6333 North Orange Blossom Trail
Orlando, FL 32810
Telephone:(407) 290-6592
Facsimile:(407) 290-2419
FDA Establishment Registration Number:1058152

1

Description of Device/Modification IV.

The STARband and STARlight redirects the head growth to improve proportion and symmetry. The practitioner takes a plaster impression or 3-dimensional captured image of the infant's head to acquire the existing shape. The mold is sealed and filled with plaster or the 3-dimensional image is carved from a rigid polyurethane foam blank to create a positive model of the head shape. The positive model is modified to obtain greater symmetry and space in the areas of flattening. The STARband and STARlight provides total contact over the prominent or bossed areas of the baby's head to discourage growth there. Over the course of treatment, the inside of the band is further modified by the practitioner to provide space for growth to occur in the flat or depressed areas. The shape of the STARband and STARlight directs growth into the areas of least resistance and creates a precise pathway for the head shape to improve in symmetry and proportion.

The STARband and STARlight product families as it was released in K124023 and K133250 are essentially still the same devices. The STARband Side Opening design and STARband Bi-Valve design is made with an outer shell of 5/32" polyethylenepolypropylene copolymer plastic with an inner liner made of 1/2" pelite polyethylene foam or 1/2" Aliplast foam (closed cell polyethylene). The STARlight Side Opening design and the STARlight Bi-Valve design are made of a plastic shell of 5/32" - 1/4" clear Surlyn or 1/8" - 7/32" Clear Co-Polyester. The STARlight PRO (Post-operative Remolding Orthosis) design is made of 1/4" to 3/8" clear Surlyn. Optional Aliplast (closed cell polyethylene) padding is available for the clear plastic bands and in addition, optional Reston (polyurethane - 3M Medical Product) foam is available for the STARlight PRO design.

The STARband Side Opening design and the STARlight Side Opening design has a top opening and a side opening. The band is held in place by a Velcro® strap (1 ½' for STARband Side Opening and 1" for STARlight Side Opening) across the side opening. The STARlight PRO has two side openings, no top opening, and is held in place by a Velcro strap across each side opening. The STARlight Bi-Valve design and the STARband Bi-Valve design consist of two plastic shells that overlap with a superior sliding mechanism. The right and left overlap tabs are connected via a Velcro strap with chafe and loop.

The proposed device modification is the addition of three new systems to use for 3dimensional shape capture, specifically, the 3dMDhead™ System, the 3dMDcranial™ System and the 3dMDflex™ System all distributed by 3dMD, Inc. These systems use a non-coherent (i.e. non-laser light) structured light source and triangulated cameras to

2

capture shape data. Because these scanners utilize a non-coherent light source, they are safe to use on infant patients under all circumstances (equivalent to a Class 1 laser).

V. Statement of Indications and Intended Use

Statement of Indications:

The STARband and STARlight are intended for medical purposes for use on infants from 3 to 18 months of age, with moderate-to-severe non-synostotic positional plagiocephaly, including infants with plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads by applying mild pressure to prominent regions of the infant's cranium in order to improve cranial symmetry and/or shape. The devices are also indicated for adjunctive use for infants from 3 to 18 months of age whose synostosis has been surgically corrected, but who still have moderate-to-severe cranial deformities including plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads.

Intended Use:

The STARband and STARlight are designed to treat infants with abnormal head shapes from age 3 to 18 months and is available by prescription only. Since growth is the driving factor in head shape correction, the infants wear the STARband or STARlight for . approximately 23 hours per day. The most common head deformities are positional plagiocephaly, brachycephaly, and scaphocephaly. The STARband and STARlight have also been cleared to treat unresolved head deformities in patients who have undergone surgery to correct craniosynostosis. The same principles of cranial remolding apply to positional deformities and post-operative patients.

VI. Predicate Devices

Summary of Technological Characteristics VI.

The 3dMD Systems proposed in this 510(k) are additional methods to capture the infant's head shape for the fabrication of the STARband and STARlight Cranial Orthosis. The technological characteristics and the underlying principles of operation of the STARband and STARlight Cranial Orthosis shall remain exactly the same. The inclusion of the 3dMD Systems is the focus of this submission and that change is indicated in Table 1 under the Approved 3-Dimensional Imaging Devices section.

3

STARband® and STARIight® Cranial Orthosis

·

| | of Predicate Devices cleared in K124023 and K133250 to the Proposed Device
From K124023 (STARband) | From K133250 (STARlight) | Proposed Device (STARband and STARlight) |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Maintains total contact over areas of
bossing or protrusion and creates voids
over areas of depression or flattening to
redirect cranial growth toward greater
symmetry. | Maintains total contact over areas of
bossing or protrusion and creates voids
over areas of depression or flattening to
redirect cranial growth toward greater
symmetry. | Maintains total contact over areas of
bossing or protrusion and creates voids
over areas of depression or flattening to
redirect cranial growth toward greater
symmetry. | |
| Outer shell of 5/32 copoly plastic | Material for STARlight Side Opening
design and STARlight Bi-Valve design
5/32" - 1/4" clear Surlyn or 1/8" -
7/32" Clear Co-Polyester plastic
shell | Material for STARband Side Opening
design and STARband Bi-Valve design
Outer shell of 5/32" copolymer
plastic | Material for STARband Side Opening
design and STARband Bi-Valve design
Outer shell of 5/32" copolymer
plastic |
| An inner liner of ½" Pelite
polyethylene foam or ½" Aliplast
foam | Material for STARlight PRO design
1/4"-3/8" clear Surlyn | An inner liner of 1/2" pelite
polyethylene foam or 1/2"
Aliplast foam | An inner liner of 1/2" Pelite
polyethylene foam or 1/2"
Aliplast foam |
| A strap of 1 ½" Dacron | Material for STARband Bivalve design
Outer shell of 5/32" copolymer
plastic | Material for STARlight Side Opening
design and STARlight Bi-Valve design
5/32" - 1/4" clear Surlyn or 1/8" -
7/32" Clear Co-Polyester plastic
shell | Material for STARlight Side Opening
design and STARlight Bi-Valve design
5/32" - 1/4" clear Surlyn or 1/8" -
7/32" Clear Co-Polyester plastic
shell |
| A 1 ½" chafe buckle | An inner liner of 1/2" pelite
polyethylene foam or 1/2"
Aliplast foam | Material for STARlight PRO design
1/4"-3/8" clear Surlyn | Material for STARlight PRO design
1/4"-3/8" clear Surlyn |
| Large Flange, Blind Rivet | Closure for Bivalve design
Sliding/Overlap closure system
Chicago screw (or similar) for top
sliding mechanism | Closure for Bivalve design
Sliding/Overlap closure system
Chicago screw (or similar) for top
sliding mechanism | Closure for Bivalve design
Sliding/Overlap closure system
Chicago screw (or similar) for top
sliding mechanism |
| A Gap Block made from ½" firm
pelite polyethylene foam | 1" Velcro strap
1" chafe buckle
Speedy rivets | 1" Velcro strap
1" chafe buckle
Speedy rivets | 1" Velcro strap
1" chafe buckle
Speedy rivets |
| A nylon washer | Closure for Side Opening design and the
PRO design: | Closure for STARband Side Opening
design | Closure for STARband Side Opening
design |
| | 1" Velcro Strap
1" chafe buckle | 1" Velcro Strap | 1" Velcro Strap |
| Feature | From K124023 (STARband) | From K133250 (STARlight) | Proposed Device (STARband and STARlight) |
| Product Design | Custom made cranial orthosis, approximately 6oz. in weight | Optional tamper resistant strap (qty 2 for the STARlight PRO design)
Custom made cranial orthosis, approximately 7 to 10oz in weight. STARlight PRO weighs 12.5 to 18.5 oz. | 1 ½" chafe buckle
A Gap Block made from ½" firm Pelite polyethylene foam
Large Flange, Blind Rivet
Closure for STARlight Side Opening design and the STARlight PRO design:
1" Velcro Strap.
1" chafe buckle
Optional tamper resistant strap (qty 2 for the STARlight PRO design)
Custom made cranial orthosis, approximately 6 to 10oz in weight.
STARlight PRO weighs 12.5 to 18.5 oz. |
| Production | Form orthosis from a positive mold of infant's head
Positive mold is formed based upon measurements of the infant's head taken by an approved 3-dimensional imaging device from which a 3- dimensional image is made or from a traditional plaster cast | Form orthosis from a positive mold of infant's head
Positive mold is formed based upon measurements of the infant's head taken by an approved 3-dimensional imaging device from which a 3- dimensional image is made or from a traditional plaster cast | Form orthosis from a positive mold of infant's head
Positive mold is formed based upon measurements of the infant's head taken by an approved 3-dimensional imaging device from which a 3- dimensional image is made or from a traditional plaster cast |
| Approved 3- Dimensional Imaging Devices | The 3-dimensional image is used to produce a positive mold using a 5-axis routing machine
STARscanner I
STARscanner II
Omega Scanner
scanGogh-II | The 3-dimensional image is used to produce a positive mold using a 5-axis routing machine
STARscanner I
STARscanner II
Omega Scanner
scanGogh-II | The 3-dimensional image is used to produce a positive mold using a 5-axis routing machine
STARscanner I
STARscanner II
Omega Scanner
scanGogh-II
3dMDhead System |
| Feature | From K124023 (STARband) | From K133250 (STARlight) | Proposed Device (STARband and
STARlight) |
| Testing | Repeatability and Reproducibility (R&R)
Analysis
Utilized uniform shapes with
known dimensions that represent
various sizes of pediatric patients
between ages 3 to 18 months of
age
Compared proposed device to
cast and predicate device
Associated parameters includes
A-P and M-L
Proposed device is substantially
equivalent to predicate device | Repeatability and Reproducibility (R&R)
Analysis
Utilized uniform shapes with
known dimensions that represent
various sizes of pediatric patients
between ages 3 to 18 months of
age
Compared proposed device to
cast and predicate device
Associated parameters includes
A-P and M-L
Proposed device is substantially
equivalent to predicate device | 3dMDcranial System
3dMDflex System
Repeatability and Reproducibility (R&R)
Analysis
Utilized uniform shapes with
known dimensions that represent
various sizes of pediatric patients
between ages 3 to 18 months of
age
Compared proposed device to
cast and predicate device
Associated parameters includes
A-P and M-L
Proposed device is substantially
equivalent to predicate device |
| | Cranial Shape Capture Accuracy Study
Utilized a representative cranial
shape that possesses a predefined
shape with known dimensions
Compared proposed device to
cast and predicate device
Associated Coordinate Planes (A-
P; M-L; P-D and various Radius
Parameters; Squareness; Flatness)
Proposed device is substantially
equivalent to predicate device | Cranial Shape Capture Accuracy Study
Utilized a representative cranial
shape that possesses a predefined
shape with known dimensions
Compared proposed device to
cast and predicate device
Associated Coordinate Planes (A-
P; M-L; P-D and various Radius
Parameters; Squareness; Flatness)
Proposed device is substantially
equivalent to predicate device | Cranial Shape Capture Accuracy Study
Utilized a representative cranial
shape that possesses a predefined
shape with known dimensions
Compared proposed device to
cast and predicate device
Associated Coordinate Planes (A-
P; M-L; P-D and various Radius
Parameters; Squareness; Flatness)
Proposed device is substantially
equivalent to predicate device |
| | Material Biocompatibility Testing
Cytotoxicity-Agar Diffusion
Closed Patch Sensitization | Material Biocompatibility Testing
Cytotoxicity -Agar Diffusion
Closed Patch Sensitization | Material Biocompatibility Testing
Cytotoxicity-Agar Diffusion
Closed Patch Sensitization |

Comparison of Predicate Devices cleared in K124023 and K133250 to the Proposed Devi Table 1 -

7-14

4

STARband® and STARlight® Cranial Orthosi

.

.

·

.

.

7-15

5

STARband® and STARlight® Cranial Orthosis

·

:

·

.

ﺮ ﻣ

7-16

, .

.

.

6

The use of a non-coherent structured light and triangulated cameras for a shape capture system for manufacturing Cranial Orthosis received FDA 510(k) clearance under K014012 (Cranial Technologies, Inc.). The STARband and STARlight Cranial Orthosis have similar indications for use as the predicate Cranial Orthosis (K014012) and the proposed shape capture device also has the same technological characteristics as the predicate shape capture device. Therefore, the STARband and STARlight Cranial Orthosis are substantially equivalent to the predicate Cranial Orthosis.

The STARband and STARlight are essentially the same Cranial Orthosis. The main difference between the STARband and STARlight are the materials used to produce them. The STARband and STARlight materials have been biocompatibility tested, and the results of the tests are listed below in Table 2.

MaterialTestResultsConclusion
SurlynClosed Patch
SensitizationA score of 0.00/0.00 (Test/Control) was given for both Incidence and Severity in the 24 hour and 48 hour scoring interval.Not a Sensitizer
No Erythema or
Edema Formation
SurlynPrimary Dermal
IrritationPrimary Irritation Index: 0.00Negligible Dermal
Response
SurlynCytotoxicity -
Agar DiffusionCell culture treated with test sample exhibited no reactivity (Grade 0).Non-cytotoxic
Copolymer with
Pelite FoamClosed Patch
SensitizationA score of 0.00/0.00 (Test/Control) was given for both Incidence and Severity in the 24 hour and 48 hour scoring interval.Not a Sensitizer
No Erythema or
Edema Formation
Copolymer with
Pelite FoamPrimary Dermal
IrritationPrimary Irritation Index: 0.06Negligible Dermal
Response
Copolymer with
Pelite FoamCytotoxicity -
Agar DiffusionCell culture treated with test sample exhibited no reactivity (Grade 0).Non-cytotoxic
Copolymer with
Aliplast FoamClosed Patch
SensitizationA score of 0.00/0.00 (Test/Control) was given for both Incidence and Severity in the 24 hour and 48 hour scoring interval.Not a Sensitizer
No Erythema or
Edema Formation
Copolymer with
Aliplast FoamPrimary Dermal
IrritationPrimary Irritation Index: 0.00Negligible Dermal
Response
Copolymer with
Aliplast FoamCytotoxicity -
Agar DiffusionCell culture treated with test sample exhibited slight reactivity (Grade 1).Non-cytotoxic

Table 2 - Biocompatibility Testing Summary for STARband and STARlight Cranial Orthosis

7

Summary and Conclusions of Non-Clinical Performance Data VII.

The 3dMDhead™ System, the 3dMDcranialTM System and the 3dMDflex™ System were all evaluated for safety and efficacy. The scanner uses a quick flash of structured white light which is equivalent to the flash from a consumer grade camera and shown that is safe to use on infants without any extra eye protection. The shape capture repeatability and reproducibility was evaluated and determined to be acceptable. An additional, Cranial Shape Capture Accuracy Study was performed concluding that the 3dMD Systems yield a safe and effective product that is substantially equivalent to the predicate device. With sufficient accuracy and no concerns with the safety of the scanner, the 3dMD Systems were determined safe and effective for scanning infants for STARband and STARlight Cranial Orthosis.

8

DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/8/Picture/1 description: The image shows the logo for the Department of Health & Human Services - USA. The logo is circular and contains the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. In the center of the circle is an abstract symbol that resembles an eagle or bird-like figure.

June 6, 2014

Public Health Service

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

Orthomerica Products, Inc. Mr. David Hooper Manufacturing Engineer 6333 North Orange Blossom Trail Orlando, Florida 32810

Re: K140353

Trade/Device Name: STARband and STARlight Regulation Number: 21 CFR 882.5970 Regulation Name: Cranial Orthosis Regulatory Class: Class II Product Code: MVA, OAN Dated: May 5, 2014 Received: May 6, 2014

Dear Mr. Hooper:

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 With an the required (21 CFR Part 801); medical device reporting of medical devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in

9

Page 2 - Mr. David Hooper

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/ResourcesforYou/Industry/default.htm. 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/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,

Carlos L. Pena -S

Carlos L. Peña, PhD, MS Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

10

Indications for Use

510(k) Number (if known) K140353

Device Name

STARband and STARlight cranial orthosis

Indications for Use (Describe)

The STARband and STARlight is intended for medical purposes for use on infants from 3 to 18 months of age, with moderate-to-severe non-synostotic positional plagiocephaly, including infants with plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads by applying mild pressure to prominent regions of the infant's cranium in order to improve cranial symmetry and/or shape. The device is also indicated for infants from 3 to 18 months of age whose synostosis has been surgically corrected, but who still have moderate-to-severe cranial deformities including plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads.

Type of Use (Select one or both, as applicable)

2 Prescription Use (Part 21 CFR 801 Subpart D)

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

PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.

FOR FDA USE ONLY

Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)

Carlos L. Pena -S

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."