K Number
K143086
Device Name
VX120 Ophthalmic Diagnostic Device
Manufacturer
Date Cleared
2015-06-01

(217 days)

Product Code
Regulation Number
886.1930
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The VX120 is a multi-function diagnostic device combining wavefront aberometer, corneal topographer, retro-illuminator, tonometer and pachymeter, indicated for: Measuring the refraction of the eye giving both lower and higher order aberrations Measuring the shape of the comea Retro-illumination imaging of the eye Measuring the intraocular pressure without contacting the eye for glaucoma evaluation Photographing the eye and taking images of the eye to evaluate the thickness of the cornea.
Device Description
The VX120 is a multifunctional ophthalmic diagnostic device. The VX120 combined wavefront aberrometer, corneal topographer, retro illumination device, Scheimpflug pachymeter, and non-contact tonometer is a single platform that contains five different measurement units. The wavefront aberrometer works on the Shack-Hartmann principle and is used as an advanced autorefractometer that measures both lower and higher order aberrations of the refraction of the eye. Retro illumination is used to image ocular opacities. The corneal topographer uses a Placido disk to measure keratometry and the detailed shape of the cornea. The Scheimpflug pachymeter measures the thickness of the central cornea by illuminating it with a slit of light and photographing it using the Scheimpflug technique. An air puff non-contact tonometer is included for measurement of the intraocular pressure. The device is fully automated and a number of different measurements can be performed by a single command including alignment and focusing.
More Information

Not Found

No
The summary describes a multi-functional ophthalmic diagnostic device using established optical and mechanical principles (Shack-Hartmann, Placido disk, Scheimpflug, air puff tonometry). There is no mention of AI, ML, deep learning, or any related concepts in the device description, intended use, or performance studies. The automation mentioned refers to alignment and focusing, not AI-driven analysis.

No
The device is described as a "multi-function diagnostic device" and its intended uses are focused on "measuring," "imaging," and "photographing" various aspects of the eye for evaluation, not for treating conditions.

Yes

The "Intended Use / Indications for Use" section explicitly states, "The VX120 is a multi-function diagnostic device..." and the "Device Description" also refers to it as "a multifunctional ophthalmic diagnostic device."

No

The device description clearly outlines multiple hardware components and measurement units (wavefront aberrometer, corneal topographer, retro-illuminator, tonometer, pachymeter) that are integral to its function.

Based on the provided information, the VX120 is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • IVD Definition: In Vitro Diagnostic devices are used to examine specimens derived from the human body (like blood, urine, tissue) to provide information for diagnosis, monitoring, or screening.
  • VX120 Function: The VX120 directly measures physical properties of the eye (refraction, shape, pressure, thickness) using optical and air-based methods. It does not analyze biological samples taken from the body.

The VX120 is a diagnostic device, but it falls under the category of in vivo diagnostic devices, as it performs measurements directly on the living patient's eye.

N/A

Intended Use / Indications for Use

The VX120 is a multi-function diagnostic device combining wavefront aberometer, corneal topographer, retro-illuminator, tonometer and pachymeter, indicated for:

Measuring the refraction of the eye giving both lower and higher order aberrations
Measuring the shape of the comea
Retro-illumination imaging of the eye
Measuring the intraocular pressure without contacting the eye for glaucoma evaluation
Photographing the eye and taking images of the eye to evaluate the thickness of the cornea.

Product codes

HKX

Device Description

The VX120 is a multifunctional ophthalmic diagnostic device.

The VX120 combined wavefront aberrometer, corneal topographer, retro illumination device, Scheimpflug pachymeter, and non-contact tonometer is a single platform that contains five different measurement units.

The wavefront aberrometer works on the Shack-Hartmann principle and is used as an advanced autorefractometer that measures both lower and higher order aberrations of the refraction of the eye.

Retro illumination is used to image ocular opacities.

The corneal topographer uses a Placido disk to measure keratometry and the detailed shape of the cornea.

The Scheimpflug pachymeter measures the thickness of the central cornea by illuminating it with a slit of light and photographing it using the Scheimpflug technique. An air puff non-contact tonometer is included for measurement of the intraocular pressure.

The device is fully automated and a number of different measurements can be performed by a single command including alignment and focusing.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

eye

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)

The following performance data were provided in support of the substantial equivalence determination:

  1. Electrical safety and EMC testing were conducted on the VX120. The device complies with IEC60601-1:2006, and the IEC60601-1-2 for EMC.
  2. Software verification and validation testing was done according to IEC62304.
  3. Risk management: VX120 was evaluated according to ISO14971: 2009. All risks have been reduced to safe levels thus there is no conflict between risk and benefit.
  4. Tests for ophthalmic products: VX120 was evaluated in accordance with ISO15004-1:2009 and ISO15004-2:2007 standards and was found to meet all requirements of the standards. For optical hazards, VX120 was evaluated in accordance with IEC60825-1: 2008: the result is VX120 is laser class 1.
  5. Tests for tonometers:
    a. Bench testing: Accuracy and repetability tests have been performed ; the accuracy is equivalent to ±2mmHg or better and the standard deviation is ±1.2 mmHg or better.
    b. Clinical evaluation: VX120 was evaluated in accordance with ISO8612:2010 and ANSI Z80.10-2009 and was found to meet all requirements of the standards if eyes with astigmatism >3mm are excluded.
  6. Tests for pachymetry: A comparison study of Central Corneal Thickness measurements done with VX120 and Pentacam shows that there was no significant statistical difference between measurements of CCT with VX120 and the Pentacam.

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

Accuracy and repetability tests have been performed ; the accuracy is equivalent to ±2mmHg or better and the standard deviation is ±1.2 mmHg or better.

Predicate Device(s)

K093298, K030719

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 886.1930 Tonometer and accessories.

(a)
Identification. A tonometer and accessories is a manual device intended to measure intraocular pressure by applying a known force on the globe of the eye and measuring the amount of indentation produced (Schiotz type) or to measure intraocular tension by applanation (applying a small flat disk to the cornea). Accessories for the device may include a tonometer calibrator or a tonograph recording system. The device is intended for use in the diagnosis of glaucoma.(b)
Classification. Class II.

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Image /page/0/Picture/1 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 graphic of three overlapping human profiles facing to the right, representing the department's focus on people and health.

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

June 1, 2015

LUNEAU SAS Ms. Isabelle Durand Quality/RA Manager 1 avenue de Malaguet CS 9001 Prunay le Gillon 28360 Gellainville Cedex France

Re: K143086

Trade/Device Name: VX120 Ophthalmic Diagnostic Device Regulation Number: 21 CFR 886.1930 Regulation Name: Ophthalmic Diagnostic Device Regulatory Class: Class II Product Code: HKX Dated: April 30, 2015 Received: May 1, 2015

Dear Ms. Durand:

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

1

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 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/ResourcesforYou/Industry/default.htm.

Sincerely yours,

Kesia Y. Alexander -A

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

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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

510(k) Number (if known) K143086

Device Name VX120

Indications for Use (Describe)

The VX120 is a multi-function diagnostic device combining wavefront aberometer, corneal topographer, retro-illuminator, tonometer and pachymeter, indicated for:

Measuring the refraction of the eye giving both lower and higher order aberrations

Measuring the shape of the comea

Retro-illumination imaging of the eye

Measuring the intraocular pressure without contacting the eye for glaucoma evaluation

Photographing the eye and taking images of the eye to evaluate the thickness of the cornea.

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

Prescription Use (Part 21 CFR 801 Subpart D)

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

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510(k) Summary

VX120 ophthalmic diagnostic device

May 19th, 2015

l. SUBMITTER

LUNEAU SAS 1 avenue de Malaguet 28360 Prunay le Gillon France Phone : +33 (0)2 37 25 25 25 Fax: +33(0)2 37 25 75 99

Contact person: Isabelle Durand

II. DEVICE

Name of Device: VX120 Common name: Ophthalmic diagnostic device Classification: tonometer , AC powered Requlatory class: II Product code: HKX Regulation number: 886.1930

III. PREDICATE DEVICES

The VX120 is claimed to be substantially equivalent to the following currently marketed devices: Keeler Pulsair Desktop Tonometer Manufacturer: Keeler Ltd . FDA K093298 issued Dec 10, 2010. Product code: HKX

Pentacam, Scheimplug camera Manufacturer: Oculus Optikgeraete GmbH, Germany FDA K030719 issued Sept 16, 2003. Product code: MXK

The VX120 is equivalent for other functions not subject to 510(k) to the following device: VX110: combined wave front aberrometer, corneal topographer and retroillumination device.

Manufacturer: Luneau SAS 510(k) exempt, regulation number 886.1760 Product code: HKO

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IV. DEVICE DESCRIPTION

The VX120 is a multifunctional ophthalmic diagnostic device.

The VX120 combined wavefront aberrometer, corneal topographer, retro illumination device, Scheimpflug pachymeter, and non-contact tonometer is a single platform that contains five different measurement units.

The wavefront aberrometer works on the Shack-Hartmann principle and is used as an advanced autorefractometer that measures both lower and higher order aberrations of the refraction of the eye.

Retro illumination is used to image ocular opacities.

The corneal topographer uses a Placido disk to measure keratometry and the detailed shape of the cornea.

The Scheimpflug pachymeter measures the thickness of the central cornea by illuminating it with a slit of light and photographing it using the Scheimpflug technique. An air puff non-contact tonometer is included for measurement of the intraocular pressure.

The device is fully automated and a number of different measurements can be performed by a single command including alignment and focusing.

V. INDICATIONS FOR USE

The VX120 is a multi-function diagnostic device combining wavefront aberometer, corneal topographer, retro-illuminator, tonometer and pachymeter, indicated for:

Measuring the refraction of the eye giving both lower and higher order aberrations Measuring the shape of the cornea

Retro-illumination imaging of the eye

Measuring the intraocular pressure without contacting the eye for glaucoma evaluation. Photographing the eye and taking images of the eye to evaluate the thickness of the cornea.

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VI. COMPARISON OF INTENDED USE AND TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICES

    1. The Tonometer function of the VX120 is claimed to be substantially equivalent to the following currently marketed device: Keeler Pulsair Desktop Tonometer,Keeler Ltd . UK, K093298
      The tonometer function of VX120 and the Pulsair Desktop Tonometer have the same intended use, they are indicated to be used to aid with the glaucoma evaluation. They measure intraocular pressure without contact with the eye by applying an air puff to the eye. VX120, is not indicated in patients with less than 3 diopters of corneal astigmatism. The maximum IOP that can be measured with this device is 44 mmHg.
Comparison of non-contact tonometer Technological characteristics
Pulsair tonometerVx120
TypeAir Puff Non Contact
TonometerAir Puff Non Contact Tonometer
Illumination720nm 1W LED720nm 1W LED
Measurement Range5 to 50mmHg7 to 44mmHg
Displayed ScaleDirect in mmHgDirect in mmHg
Air Puff GenerationVacuum Diaphragm Pump
(Type: NPK04)Vacuum Diaphragm Pump
(Type: NPK04)
Accuracy±2 mmHg±2 mmHg
Pressure of Air Expelled
from Tonometer30mmHg & 70mmHg30mmHg & 70mmHg
Power Supply100-240 V AC, 50/60 Hz, 400 W100-240 V AC, 50/60 Hz, 400 W
Measurement MethodOpto ElectronicOpto Electronic
User InterfaceFactory Set / User ChangeableFactory Set / User Changeable
PrinterBuilt inBuilt in
Data DisplaySingle line 16 characters LCDFull Colour LCD
Data storage capabilityResults and patient information
Mounting OptionsDesk mountedDesk mounted
Dimensions (W×L×H)450mmx435mmx245mm312mm × 530mm × 570mm
Weight16 kg25 kg
Software Level of ConcernModerateModerate
Reliance on StandardsISO8612:2001Full clinical trial conducted in
2014 to ISO18612:2010
    1. The pachymeter function of the VX120 is claimed to be substantially equivalent to the following currently marketed device: Pentacam Scheimpflug Camera, OCULUS Optikgeraete GmbH, Germany; K 030719
      The pachymeter function of the VX120 has the same intended use than Pentacam for photographing the eye and taking images of the anterior segment of the eye to evaluate the thickness of the cornea.

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The Pentacam and the VX120 systems are based on the Scheimpflug Principle for slit image photography. The measurement systems use blue light (UV-free) through a slit to illuminate the eye, and a Camera for photography. The devices take a series of images of the anterior segment of the eye and analyse the images, selected by the software.

Comparison of pachymeter technological characteristics
PentacamVX120
ManufacturerOculus Optigerate GmbHLuneau
Measurement principleScheimpflug principle for
slit image photographyScheimpflug principle for
slit image photography
Observation illuminationInfrared LED 800nm for
pupil illuminationInfrared LED 880nm for
pupil and corneal
illumination
Flash output illuminationBlue LED light (UV free)
475nm, max 2.5W power
inputBlue LED light (UV free)
455nm, max 1.2W power
input
CameraCCD cameraCMOS camera
DisplayData digital, displayed on
a CPUData digital, displayed on
LCD screen
Image resolution800 × 600 pixels1600 × 1000 pixels
Measuring points500 per image300 per surface (2
surfaces per image)
Image size5.6x 4.5 mm3.5 x 2.2 mm
Photographic range0° to 360°Fixed slit position 180°
Photographic series1 to 50 images5 images
Exposure controlFixed during calibration,
max 2.5Wsec power inputFixed during calibration,
max 50mW for 300 mS
(0.015Wsec) power input
Slit length14mm fixed8mm fixed
Power supplyExternal 110/220 VAC,
50/60Hz100-240 VAC, 50/60Hz
Power consumption50VA400W
Power requirement25VDC, 2A / 5VDC, 2A
Weight9 kg25 kg

The systems contain

  • . similar optical systems,
  • . a similar source of illumination for observation and photography,
  • a camera as a photographic medium, . Both systems use the same device features like a
  • . head stabilizing device
  • fixation target ●
  • alignment control mechanism. ●

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VII. PERFORMANCE DATA

The following performance data were provided in support of the substantial equivalence determination:

    1. Electrical safety and EMC testing were conducted on the VX120. The device complies with IEC60601-1:2006, and the IEC60601-1-2 for EMC.
    1. Software verification and validation testing was done according to IEC62304.
    1. Risk management: VX120 was evaluated according to ISO14971: 2009. All risks have been reduced to safe levels thus there is no conflict between risk and benefit.
    1. Tests for ophthalmic products: VX120 was evaluated in accordance with ISO15004-1:2009 and ISO15004-2:2007 standards and was found to meet all requirements of the standards. For optical hazards, VX120 was evaluated in accordance with IEC60825-1: 2008: the result is VX120 is laser class 1.
    1. Tests for tonometers:
    • a. Bench testing:

Accuracy and repetability tests have been performed ; the accuracy is equivalent to ±2mmHg or better and the standard deviation is ±1.2 mmHg or better.

  • b. Clinical evaluation: VX120 was evaluated in accordance with ISO8612:2010 and ANSI Z80.10-2009 and was found to meet all requirements of the standards if eyes with astigmatism >3mm are excluded.
    1. Tests for pachymetry:

A comparison study of Central Corneal Thickness measurements done with VX120 and Pentacam shows that there was no significant statistical difference between measurements of CCT with VX120 and the Pentacam.

VIII. CONCLUSIONS

The VX120 is substantially equivalent to the predicate devices for its tonometry and pachymetry functions. The VX120 has the same intended use, technological characteristics, and principles of operation as its predicate devices.

The VX120 other functions are equivalent to VX110

The technological differences between the VX120 and its predicates raise no new issues of safety and effectiveness. Performance data demonstrates that the VX120 is as safe and effective as the predicate devices for tonometry and pachymetry functions.