K Number
K161871
Device Name
EVA (Enhanced Visual Assessment) System
Manufacturer
Date Cleared
2016-12-19

(165 days)

Product Code
Regulation Number
884.1630
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The EVA (Enhanced Visual Assessment) System is intended to provide magnified viewing of the vagina, cervix and external genitalia in order to aid in diagnosing abnormalities and selecting areas for biopsy. The device is intended for use in hospitals, doctor's offices, and remote and rural clinics.
Device Description
The EVA (Enhanced Visual Assessment) System is a handheld device in which a smartphone is fitted and consists of a colposcope body, lens, smartphone upper and lower brackets, LED electronics, CervDx app for image capture, and online portal for image transfer and remote viewing. The device also includes the strap, carrier case, and instruction manual. During colposcopy, the operator may mount the EVA System on a tripod for hands free imaging, turn on the LED light for improved viewing, see a magnified view of the vagina and cervix on a smartphone screen resting at the back of the device, annotate and save images on the CervDx app, and upload images to the portal. The EVA System is compatible with Motorola G2 and Motorola G3 smartphones. The EVA System is capable of working for ten hours before recharging. The EVA System weighs about 0.5 kg and is light enough that the device can be operated for 10 minutes at a time without any fatiguing. The device operates at a working distance of 22.5 - 42.5 cm with an optical magnification up to 4.0x and ultimately up to 16x, with digital zoom.
More Information

Not Found

No
The description focuses on the optical and hardware components, image capture, and basic software functions (annotation, saving, uploading). There is no mention of any analytical or diagnostic capabilities beyond magnified viewing, nor any terms related to AI/ML.

No.
The device is intended for magnified viewing to aid in diagnosing abnormalities and selecting areas for biopsy, which are diagnostic purposes, not therapeutic.

Yes

The device's "Intended Use / Indications for Use" states that it is "intended to provide magnified viewing of the vagina, cervix and external genitalia in order to aid in diagnosing abnormalities." The phrase "aid in diagnosing" clearly indicates a diagnostic purpose.

No

The device description explicitly lists hardware components such as a colposcope body, lens, LED electronics, strap, carrier case, and mentions compatibility with specific smartphone models, indicating it is a physical device with integrated software, not software-only.

Based on the provided information, the EVA (Enhanced Visual Assessment) System is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • IVD Definition: In Vitro Diagnostics are medical devices intended for use in vitro for the examination of specimens, including blood, tissue, and urine, derived from the human body, solely or principally for the purpose of providing information concerning a physiological or pathological state, or concerning a congenital abnormality, or to determine the safety and compatibility with potential recipients, or to monitor therapeutic measures.
  • EVA System's Function: The EVA System is a device that provides magnified viewing of the vagina, cervix, and external genitalia. It is used to aid in diagnosing abnormalities and selecting areas for biopsy. This is a direct visual examination of the body, not an examination of specimens in vitro.
  • Lack of Specimen Analysis: The description does not mention any analysis of biological specimens. The device's function is purely observational and imaging-based.

Therefore, the EVA System falls under the category of a medical device used for direct visualization and examination of the body, not an IVD.

N/A

Intended Use / Indications for Use

The EVA (Enhanced Visual Assessment) System is intended to provide magnified viewing of the vagina, cervix and external genitalia in order to aid in diagnosing abnormalities and selecting areas for biopsy. The device is intended for use in hospitals, doctor's offices, and remote and rural clinics.

Product codes

HEX

Device Description

The EVA (Enhanced Visual Assessment) System is a handheld device in which a smartphone is fitted and consists of a colposcope body, lens, smartphone upper and lower brackets, LED electronics, CervDx app for image capture, and online portal for image transfer and remote viewing. The device also includes the strap, carrier case, and instruction manual. During colposcopy, the operator may mount the EVA System on a tripod for hands free imaging, turn on the LED light for improved viewing, see a magnified view of the vagina and cervix on a smartphone screen resting at the back of the device, annotate and save images on the CervDx app, and upload images to the portal. The EVA System is compatible with Motorola G2 and Motorola G3 smartphones.

The EVA System is capable of working for ten hours before recharging. The EVA System weighs about 0.5 kg and is light enough that the device can be operated for 10 minutes at a time without any fatiguing.

The device operates at a working distance of 22.5 - 42.5 cm with an optical magnification up to 4.0x and ultimately up to 16x, with digital zoom.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

vagina, cervix and external genitalia

Indicated Patient Age Range

Not Found

Intended User / Care Setting

hospitals, doctor's offices, and remote and rural clinics.

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

Non-clinical tests were conducted to verify that the EVA System met all design specifications and is substantially equivalent to the predicate. The test results demonstrated that the proposed device complies with the following standards:

  • AAMI/ANSI 60601-1 (2012), Medical Electrical Equipment Part 1: General Requirements For Basic Safety And Essential Performance (IEC 60601-1:2005, Mod).
  • IEC 60601-1-2 (Edition 3.0, 2007), Medical Electrical Equipment Part 1-2: General . Requirements For Basic Safety And Essential Performance - Collateral Standard: Electromagnetic Compatibility - Requirements And Tests.
  • ISO 8600-3:1997 Optics and Optical instruments - Medical endoscopes and endoscopic accessories - Part 3: Determination of field of view and direction of view of endoscopes with optics.
  • . ISO 8600-5:2005 Optics and photonics - Medical endoscopes and endotherapy devices Part 5: Determination of optical resolution of rigid endoscopes with optics.
  • The EVA System was further tested for the following:
    • Power Consumption
    • Battery Lifetime
    • Image Distortion
    • Cervical Model Image Quality
    • Image Pairs Evaluation
    • Working Distance
    • Illuminance
  • Validation of the device software was performed according to the clause 14 of IEC . 60601-1 (third edition) Software requirements, IEC 62304:2004 to IEC 62304-2006/AC 2008, Medical device, and Software life-cycle processes standards.
  • Usability testing was conducted according to the IEC 62366-1:2015 standard and FDA guidelines for Applying Human Factors and Usability Engineering to Medical Devices.

Key Metrics

Not Found

Predicate Device(s)

K122973

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 884.1630 Colposcope.

(a)
Identification. A colposcope is a device designed to permit direct viewing of the tissues of the vagina and cervix by a telescopic system located outside the vagina. It is used to diagnose abnormalities and select areas for biopsy. This generic type of device may include a light source, cables, and component parts.(b)
Classification. Class II (special controls). The device, when it is a standard colposcope (or colpomicroscope) that uses only a white light source, does not use filters other than a green filter, does not include image analysis software, and is not smartphone-based, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 884.9.

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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 is circular, with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized image of three human profiles facing to the right, stacked on top of each other.

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

December 19, 2016

MobileODT Ltd. Jen Acobas RA/QA Manager Ben Avigdor 8, 3rd Floor Tel Aviv, 6721832 Israel

Re: K161871

Trade/Device Name: EVA (Enhanced Visual Assessment) System Regulation Number: 21 CFR 884.1630 Regulation Name: Colposcope Regulatory Class: Class II Product Code: HEX Dated: November 29, 2016 Received: November 29, 2016

Dear Jen Acobas,

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

1

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 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,

Benjamin R. Fisher -S

Benjamin R. Fisher, Ph.D. Director Division of Reproductive, Gastro-Renal, and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K161871

Device Name

EVA (Enhanced Visual Assessment) System

Indications for Use (Describe)

The EVA (Enhanced Visual Assessment) System is intended to provide magnified viewing of the vagina, cervix and external genitalia in order to aid in diagnosing abnormalities and selecting areas for biopsy. The device is intended for use in hospitals, doctor's offices, and remote and rural clinics.

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

K161871

Submitter Information 1.

Manufacturer Name and Address MobileODT Ltd. Ben Avigdor 8, 3rd Floor Tel Aviv 6721832 Israel Phone: (617) 454-4687

Official Correspondent

Jennifer Acobas, VP Regulatory MobileODT Ltd. Ben Avigdor 8, 3rd Floor Tel Aviv 6721832 Israel Phone: (617) 454-4687

2. Date Prepared: December 14, 2016

3. Device Information

Proprietary Name:EVA (Enhanced Visual Assessment) System
Common Name:Colposcope
FDA Classification Name:21 CFR 884.1630; Colposcope
FDA Classification:Class II, Product Code: HEX

4. Predicate Device

The EVA System is substantially equivalent to the following device:

ManufacturerDevice510(k)Date Cleared
MedGyn Products, Inc.MedGyn Digital
Video ColposcopeK122973June 12, 2013

ട. Device Description

The EVA (Enhanced Visual Assessment) System is intended to provide magnified viewing of the vagina, cervix and external genitalia in order to aid in diagnosing abnormalities and

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selecting areas for biopsy. The EVA System is a handheld device in which a smartphone is fitted and consists of a colposcope body, lens, smartphone upper and lower brackets, LED electronics, CervDx app for image capture, and online portal for image transfer and remote viewing. The device also includes the strap, carrier case, and instruction manual. During colposcopy, the operator may mount the EVA System on a tripod for hands free imaging, turn on the LED light for improved viewing, see a magnified view of the vagina and cervix on a smartphone screen resting at the back of the device, annotate and save images on the CervDx app, and upload images to the portal. The EVA System is compatible with Motorola G2 and Motorola G3 smartphones.

The EVA System is capable of working for ten hours before recharging. The EVA System weighs about 0.5 kg and is light enough that the device can be operated for 10 minutes at a time without any fatiguing.

The device operates at a working distance of 22.5 - 42.5 cm with an optical magnification up to 4.0x and ultimately up to 16x, with digital zoom.

6. Indications for Use

The EVA (Enhanced Visual Assessment) System is intended to provide magnified viewing of the vagina, cervix and external genitalia in order to aid in diagnosing abnormalities and selecting areas for biopsy. The device is intended for use in hospitals, doctor's offices, and remote and rural clinics.

Predicate Comparison 7.

The following table compares the EVA System to the predicate device with respect to indications for use, technological characteristics, and materials:

Device & Predicate Device(s):Subject Device:Predicate Device:
EVA SystemMedGyn Digital Video Colposcope
K161871K122973
Indications for UseThe EVA (Enhanced Visual
Assessment) System is intended to
provide magnified viewing of the
vagina, cervix and external genitalia in
order to aid in diagnosing abnormalitiesMedgyn's digital video colposcope
is intended for magnified viewing
of the tissues of the vagina, cervix
and external genitalia in order to
assist doctors in diagnosing
and selecting areas for biopsy. The
device is intended for use in hospitals,
doctor's offices, and remote and rural
clinics.abnormalities such as lesions or
cancer, and selecting areas for
biopsy. The images from the digital
video colposcope are to be viewed
on a color monitor. The digital
video colposcope is intended for
use in hospitals, clinics, and
doctor's offices.
Device Characteristics
Working Distance225-425mm200-300mm
Focusing MechanismManualAutofocus, manual
Magnification225:16x
425: 15x1-40x
Digital Magnification1x-4x1-32x (model 106A: 1-40x)
Optical magnification225: 4.0x
425: 3.8x1-18x (model 106A: 1-36x)
Depth of Field17mm (at 225mm) - 34mm (at 425mm)5-120mm
Field of View45mm (at 225mm) – 100mm (at
425mm)1x: ≥60mm
32x: ≥6mm
At working distance 200mm
1x: 195mm (52°)
32x: 6.98mm (2°)
On-axis Spatial Resolution11.78 line-pairs/mm11.31 line-pairs/mm
On-axis Angular Resolution0.022°0.02534°
Distortion≤2.5%2.49%
Light Source3W 6500k star LEDDouble circular LED group
ColorDigital green filter, polarizing/glare
reducing filter3 Grade filter function
Image OutputImage capture, cloud patient recording
and image exportingS-Video
Image FreezeFull image capturing supportImage Freeze Control
Illuminance≥1000lux at working distance 425mmWhen working distance is 300mm,
≥ 1600 lx
When working distance is 200mm
$\ge$ 2000 1x
ControlsInteractive GUI mobile application
Timers – Acetic Acid Timer"Multi-function" button control
Timers- Magnification & Acetic
Acid Timer
MaterialsPU – Biresin RG53 FR
6061 Aluminum
5052 Aluminum
Stainless SteelNot Available

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The EVA System has the same intended use but different technological characteristics compared to the predicate device. The differences in technological characteristics do not raise different questions of safety and effectiveness.

8. Non-Clinical Performance Testing

Non-clinical tests were conducted to verify that the EVA System met all design specifications and is substantially equivalent to the predicate. The test results demonstrated that the proposed device complies with the following standards:

  • AAMI/ANSI 60601-1 (2012), Medical Electrical Equipment Part 1: General ● Requirements For Basic Safety And Essential Performance (IEC 60601-1:2005, Mod).
  • IEC 60601-1-2 (Edition 3.0, 2007), Medical Electrical Equipment Part 1-2: General . Requirements For Basic Safety And Essential Performance - Collateral Standard: Electromagnetic Compatibility - Requirements And Tests.
  • ISO 8600-3:1997 Optics and Optical instruments - Medical endoscopes and endoscopic accessories - Part 3: Determination of field of view and direction of view of endoscopes with optics.
  • . ISO 8600-5:2005 Optics and photonics - Medical endoscopes and endotherapy devices Part 5: Determination of optical resolution of rigid endoscopes with optics.
  • The EVA System was further tested for the following:
    • Power Consumption O
    • Battery Lifetime O
    • Image Distortion o
    • Cervical Model Image Quality O
    • Image Pairs Evaluation O
    • Working Distance о

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  • o Illuminance
  • Validation of the device software was performed according to the clause 14 of IEC . 60601-1 (third edition) Software requirements, IEC 62304:2004 to IEC 62304-2006/AC 2008, Medical device, and Software life-cycle processes standards.
  • Usability testing was conducted according to the IEC 62366-1:2015 standard and FDA ● guidelines for Applying Human Factors and Usability Engineering to Medical Devices.

Clinical Performance Data 9.

Not Applicable

10. Conclusion

Based on the comparison and analysis above, the EVA System is substantially equivalent to the predicate device.