K Number
K160523
Device Name
BrightMatter Guide with BrightMatter Pointer
Date Cleared
2016-06-24

(120 days)

Product Code
Regulation Number
882.4560
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
BrightMatter Guide is intended as a planning and intraoperative guidance system to enable open and percutaneous computer assisted surgery. The system is indicated for medical conditions requiring neurosurgical cranial procedures where the use of computer assisted planning and surgery may be appropriate. The system can be used for intraoperative guidance where a reference to a rigid anatomical structure can be identified. The user should consult the "Accuracy Characterization" section of the User Manual to assess if the accuracy of the system is suitable for their needs. The BrightMatter Pointer is intended to be used for anatomy palpation and as a pointing tool to enable spatial localization and identification by BrightMatter Guide navigational systems.
Device Description
BrightMatter Guide is a planning and image guided surgical system that enables computer assisted surgery where use of stereotactic image guidance may be considered appropriate. The BrightMatter Pointer is a handheld passive instrument which can be used for anatomy palpation using its tip. This tool can be tracked using passive reflective markers in order for BrightMatter Guide to identify and spatially track its location. There are rigid features on the subject device where the markers (passive spheres) that reflect infrared (IR) signals can be attached. The markers are arranged in a unique pattern on the device so that the BrightMatter Guide can differentiate it from other instruments. The Pointer portion of the device is provided non sterile and requires steam sterilization before use. The passive reflective markers are single-use. The BrightMatter Pointer is made of either titanium alloy conforming to ASTM F136, Standard Specification for Wrought Titanium-6 Aluminum-4 Vanadium ELI (Extra Low Interstitial) Alloy for Surgical Implant Applications (UNS R56401) or 17-4 stainless steel conforming to ASTM A564 Standard Specification for Hot-Rolled and Cold-Finished Age-Hardening Stainless Steel Bars and Shapes.
More Information

Not Found

No
The summary describes a planning and image-guided surgical system using passive reflective markers for spatial tracking. There is no mention of AI or ML in the intended use, device description, or performance studies. The "Mentions AI, DNN, or ML" section explicitly states "Not Found".

No
The device is described as a planning and intraoperative guidance system that enables computer-assisted surgery, and a pointer for anatomy palpation and spatial localization. It does not directly treat or prevent a disease or condition, but rather aids in surgical procedures.

No

The device is described as a "planning and intraoperative guidance system" and is primarily used for navigation and spatial localization during surgery, not for diagnosing a medical condition.

No

The device description explicitly mentions the "BrightMatter Pointer," which is a handheld passive instrument made of titanium alloy or stainless steel. This is a physical hardware component, not solely software.

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

Here's why:

  • Intended Use: The intended use clearly states it's a "planning and intraoperative guidance system to enable open and percutaneous computer assisted surgery" for "neurosurgical cranial procedures." This describes a surgical navigation system used during a procedure, not a device used to examine specimens in vitro (outside the body) to provide diagnostic information.
  • Device Description: The description details a "planning and image guided surgical system" and a "handheld passive instrument" used for "anatomy palpation" and "spatial localization and identification." This aligns with surgical tools and navigation, not diagnostic testing of biological samples.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples (blood, tissue, etc.), detecting analytes, or providing diagnostic information based on such analysis.

Therefore, the BrightMatter Guide and BrightMatter Pointer are surgical navigation and guidance tools, not In Vitro Diagnostic devices.

N/A

Intended Use / Indications for Use

BrightMatter Guide is intended as a planning and intraoperative guidance system to enable open and percutaneous computer assisted surgery. The system is indicated for medical conditions requiring neurosurgical cranial procedures where the use of computer assisted planning and surgery may be appropriate. The system can be used for intraoperative guidance where a reference to a rigid anatomical structure can be identified. The user should consult the "Accuracy Characterization" section of the User Manual to assess if the accuracy of the system is suitable for their needs.

The BrightMatter Pointer is intended to be used for anatomy palpation and as a pointing tool to enable spatial localization and identification by BrightMatter Guide navigational systems.

The system should be operated only by trained personnel such as surgeons and other clinic staff.

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

HAW

Device Description

BrightMatter Guide is a planning and image guided surgical system that enables computer assisted surgery where use of stereotactic image guidance may be considered appropriate. The BrightMatter Pointer is a handheld passive instrument which can be used for anatomy palpation using its tip. This tool can be tracked using passive reflective markers in order for BrightMatter Guide to identify and spatially track its location. There are rigid features on the subject device where the markers (passive spheres) that reflect infrared (IR) signals can be attached. The markers are arranged in a unique pattern on the device so that the BrightMatter Guide can differentiate it from other instruments. The Pointer portion of the device is provided non sterile and requires steam sterilization before use. The passive reflective markers are single-use.

The BrightMatter Pointer is made of either titanium alloy conforming to ASTM F136, Standard Specification for Wrought Titanium-6 Aluminum-4 Vanadium ELI (Extra Low Interstitial) Alloy for Surgical Implant Applications (UNS R56401) or 17-4 stainless steel conforming to ASTM A564 Standard Specification for Hot-Rolled and Cold-Finished Age-Hardening Stainless Steel Bars and Shapes.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

cranial

Indicated Patient Age Range

Not Found

Intended User / Care Setting

trained personnel such as surgeons and other clinic staff.

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)

No FDA performance standards have been established for the BrightMatter Guide with BrightMatter Pointer. The following tests were performed to demonstrate substantial equivalence between the subject and predicate devices.

Test: Dimensional analysis
Purpose: Comparison of measured dimensions to ensure tolerances are within acceptable limits.
Results: Measurements found within acceptable tolerances. If outside tolerance, navigational accuracy testing was performed.

Test: Navigational accuracy
Purpose: Accuracy of navigational components evaluated to ensure performance of the system.
Results: Accuracy testing demonstrated the subject device was as accurate as the predicate device.

Test: Cytotoxicity
Purpose: Cytotoxicity of the device evaluated to demonstrate biocompatibility.
Results: Testing demonstrated the device is not cytotoxic.

Test: Sensitization
Purpose: Sensitization of the device evaluated to demonstrate biocompatibility.
Results: Testing demonstrated the device is not sensitizing.

Test: Irritation
Purpose: Irritation of the device evaluated to demonstrate biocompatibility.
Results: Testing demonstrated the device is not an irritant.

Test: Pyrogenicity
Purpose: Material mediated pyrogenicity evaluated to demonstrate the absence of a febrile response in an in vivo model.
Results: Testing demonstrated the device is non-pyrogenic.

Test: Endotoxin (LAL test)
Purpose: Amount of gram negative bacteria evaluated to demonstrate endotoxin units are within acceptable limits.
Results: Endotoxin units were found to be

§ 882.4560 Stereotaxic instrument.

(a)
Identification. A stereotaxic instrument is a device consisting of a rigid frame with a calibrated guide mechanism for precisely positioning probes or other devices within a patient's brain, spinal cord, or other part of the nervous system.(b)
Classification. Class II (performance standards).

0

Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo features a stylized caduceus, which is a symbol of medicine, with three figures intertwined to represent people. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular pattern around the caduceus. The logo is black and white.

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

June 24, 2016

Synaptive Medical Inc. % Allison Komiyama, PhD, RAC Principal Consultant AcKnowledge Regulatory Strategies 2834 Hawthorn Street San Diego. California 92104

Re: K160523

Trade/Device Name: BrightMatter Guide with BrightMatter Pointer Regulation Number: 21 CFR 882.4560 Regulation Name: Stereotaxic Instrument Regulatory Class: Class II Product Code: HAW Dated: May 26, 2016 Received: May 27, 2016

Dear Dr. Allison Komiyama:

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. Isting 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 devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in

1

the quality systems (OS) 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 Industry and Consumer Education 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. 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 Industry and Consumer Education 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,

Carlos L. Pena -$ D/A

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

Enclosure

2

Indications for Use

510(k) Number (if known) K160523

Device Name BrightMatter Guide with BrightMatter Pointer

Indications for Use (Describe)

BrightMatter Guide is intended as a planning and intraoperative guidance system to enable open and percutaneous computer assisted surgery. The system is indicated for medical conditions requiring neurosurgical cranial procedures where the use of computer assisted planning and surgery may be appropriate. The system can be used for intraoperative guidance where a reference to a rigid anatomical structure can be identified. The user should consult the "Accuracy Characterization" section of the User Manual to assess if the accuracy of the system is suitable for their needs.

The BrightMatter Pointer is intended to be used for anatomy palpation and as a pointing tool to enable spatial localization and identification by BrightMatter Guide navigational systems.

The system should be operated only by trained personnel such as surgeons and other clinic staff.

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)

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."

3

510(k) Summary K160523

DATE PREPARED

June 23, 2016

MANUFACTURER AND 510(k) OWNER

Synaptive Medical, Inc. 101 College Street, Suite 200, Toronto, Ontario M5G 1L7, Canada Telephone: (416) 673-6679 Fax: (888) 650-5230 Official Contact: Cameron Piron, President

REPRESENTATIVE/CONSULTANT

Allison C. Komiyama, Ph.D., R.A.C. AcKnowledge Regulatory Strategies Telephone: akomiyama@acknowledge-rs.com Email:

PROPRIETARY NAME OF SUBJECT DEVICE

BrightMatter Guide with BrightMatter Pointer

COMMON NAME

Neurological stereotaxic instrument

DEVICE CLASSIFICATION

Stereotaxic instrument (21 CFR 882.4560, Product Code HAW, Class II)

PREMARKET REVIEW

ODE/DNPMD/NNDB Neurology Panel

PURPOSE OF SUBMISSION

The purpose of this submission is to introduce a titanium version of the Pointer tool.

INDICATIONS FOR USE

BrightMatter Guide is intended as a planning and intraoperative guidance system to enable open and percutaneous computer assisted surgery. The system is indicated for medical conditions requiring neurosurgical cranial procedures where the use of computer assisted planning and surgery may be appropriate. The system can be used for intraoperative guidance where a reference to a rigid anatomical structure can be identified. The user should consult the

4

"Accuracy Characterization" section of the User Manual to assess if the accuracy of the system is suitable for their needs.

The BrightMatter Pointer is intended to be used for anatomy palpation and as a pointing tool to enable spatial localization and identification by BrightMatter Guide navigational systems.

The system should be operated only by trained personnel such as surgeons and other clinic staff.

DEVICE DESCRIPTION

BrightMatter Guide is a planning and image guided surgical system that enables computer assisted surgery where use of stereotactic image guidance may be considered appropriate. The BrightMatter Pointer is a handheld passive instrument which can be used for anatomy palpation using its tip. This tool can be tracked using passive reflective markers in order for BrightMatter Guide to identify and spatially track its location. There are rigid features on the subject device where the markers (passive spheres) that reflect infrared (IR) signals can be attached. The markers are arranged in a unique pattern on the device so that the BrightMatter Guide can differentiate it from other instruments. The Pointer portion of the device is provided non sterile and requires steam sterilization before use. The passive reflective markers are single-use.

The BrightMatter Pointer is made of either titanium alloy conforming to ASTM F136, Standard Specification for Wrought Titanium-6 Aluminum-4 Vanadium ELI (Extra Low Interstitial) Alloy for Surgical Implant Applications (UNS R56401) or 17-4 stainless steel conforming to ASTM A564 Standard Specification for Hot-Rolled and Cold-Finished Age-Hardening Stainless Steel Bars and Shapes.

The BrightMatter Pointer is substantially equivalent to the following predicates:
510(k)
NumberPredicate Device Name / ManufacturerPrimary
Predicate
K142024BrightMatter Navigation System v1.0 / Synaptive, Inc.
K153281BrightMatter Guide with Surface Trace Registration /
Synaptive, Inc.
K142344Disposable Passive Accessory for Medtronic StealthStation
System / IZI Medical Products LLC
K080450Stryker Power Tool Navigator / Stryker Instruments

PREDICATE DEVICE IDENTIFICATION

The BrightMatter Pointer is substantially equivalent to the following predicates:

5

SUMMARY OF NON-CLINICAL TESTING

No FDA performance standards have been established for the BrightMatter Guide with BrightMatter Pointer. The following tests were performed to demonstrate substantial equivalence between the subject and predicate devices.

TestPurposeResults
Dimensional
analysisComparison of measured dimensions to
ensure tolerances are within acceptable
limits.Measurements found within
acceptable tolerances. If outside
tolerance, navigational accuracy
testing was performed.
Navigational
accuracyAccuracy of navigational components
evaluated to ensure performance of the
system.Accuracy testing demonstrated
the subject device was as accurate
as the predicate device.
CytotoxicityCytotoxicity of the device evaluated to
demonstrate biocompatibility.Testing demonstrated the device
is not cytotoxic.
SensitizationSensitization of the device evaluated to
demonstrate biocompatibility.Testing demonstrated the device
is not sensitizing.
IrritationIrritation of the device evaluated to
demonstrate biocompatibility.Testing demonstrated the device
is not an irritant.
PyrogenicityMaterial mediated pyrogenicity
evaluated to demonstrate the absence
of a febrile response in an in vivo model.Testing demonstrated the device
is non-pyrogenic.
Endotoxin
(LAL test)Amount of gram negative bacteria
evaluated to demonstrate endotoxin
units are within acceptable limits.Endotoxin units were found to be