K Number
K162265
Device Name
CushionCast Moldable Cushions
Date Cleared
2016-11-15

(96 days)

Product Code
Regulation Number
892.5050
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The CushionCast™ Moldable Cushion is to be used by trained medical professionals for stable support and positioning of patients undergoing radiation therapy or other treatment in a clinic or hospital setting.
Device Description
The CushionCast™ is moldable stabilization cushions for radiation therapy patients. This product targets customers who require stabilization cushions for patients who are undergoing radiation therapy. The CushionCast™ is needed in order to mold to the shape of the patient's head to immobilize any movement during radiation therapy. The cushion is constructed with a biocompatible and water resistant fabric and internal components, which include low viscosity casting resins that are sealed in pouches and polystyrene beads as filler material. To activate the cushion, the pouches are popped, and the internal components are mixed for 2 minutes. The plug inserted in the vent tube is removed prior to the molding process. The vent tube serves to expel excess air to allow for an accurate mold. The mixture of the Part A and Part B liquid plastics should yield a hardened mold. The fully cured mold provides a dimensionally stable cushion required by radiotherapy systems.
More Information

Not Found

No
The device description and intended use focus on a physical, moldable cushion for patient stabilization, with no mention of software, algorithms, or data processing that would indicate AI/ML.

No
The device provides stable support and positioning for patients during radiation therapy, but it does not directly treat a disease or condition. Its purpose is to immobilize patients for treatment, not to be a therapeutic intervention itself.

No

The device is described as a moldable stabilization cushion used for patient positioning and immobilization during radiation therapy. It does not perform any diagnostic function such as detecting, diagnosing, or monitoring a disease or condition. Its purpose is purely supportive and therapeutic.

No

The device description clearly outlines a physical product (cushion, fabric, resins, beads, vent tube) that is molded and hardens, indicating it is a hardware device, not software.

Based on the provided information, the CushionCast™ Moldable Cushion is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVDs are used to examine specimens derived from the human body. The CushionCast™ is a physical device used to position and stabilize a patient's head during radiation therapy. It does not interact with or analyze any biological samples.
  • The intended use is for patient positioning and support. The description clearly states its purpose is for "stable support and positioning of patients undergoing radiation therapy or other treatment." This is a physical support function, not a diagnostic one.
  • The device description focuses on its physical properties and molding process. The details about the resins, beads, and curing process relate to its function as a moldable cushion, not as a diagnostic tool.

Therefore, the CushionCast™ falls under the category of a medical device used for patient support and positioning, not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

The CushionCast Moldable Cushion is to be used by trained medical professionals for stable support and positioning of patients undergoing radiation therapy or other treatment in a clinic or hospital setting.

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

IYE

Device Description

The CushionCast™ is moldable stabilization cushions for radiation therapy patients. This product targets customers who require stabilization cushions for patients who are undergoing radiation therapy. The CushionCast™ is needed in order to mold to the shape of the patient's head to immobilize any movement during radiation therapy.

The cushion is constructed with a biocompatible and water resistant fabric and internal components, which include low viscosity casting resins that are sealed in pouches and polystyrene beads as filler material. To activate the cushion, the pouches are popped, and the internal components are mixed for 2 minutes. The plug inserted in the vent tube is removed prior to the molding process. The vent tube serves to expel excess air to allow for an accurate mold. The mixture of the Part A and Part B liquid plastics should yield a hardened mold. The fully cured mold provides a dimensionally stable cushion required by radiotherapy systems.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

The device is intended for use by a trained healthcare professional in a healthcare facility.

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)

A design verification study was conducted to ensure that the dimensional stability of the CushionCast™ meets necessary requirements. The study also indicated that the CushionCast™ performs equivalently to the Klarity Mold Cushions.

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.

K132124

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

§ 892.5050 Medical charged-particle radiation therapy system.

(a)
Identification. A medical charged-particle radiation therapy system is a device that produces by acceleration high energy charged particles (e.g., electrons and protons) intended for use in radiation therapy. This generic type of device may include signal analysis and display equipment, patient and equipment supports, treatment planning computer programs, component parts, and accessories.(b)
Classification. Class II. When intended for use as a quality control system, the film dosimetry system (film scanning system) included as an accessory to the device described in paragraph (a) of this section, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9.

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Image /page/0/Picture/1 description: The image shows the seal of the Department of Health & Human Services - USA. The seal is circular, with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. In the center of the seal is an emblem featuring a stylized depiction of three human profiles facing to the right, overlaid on top of each other. The emblem is black and white.

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

November 15, 2016

IZI Medical Products LLC % Mr. Oiang Cao Manager of Quality Assurance and Regulatory Affairs 5 Easter Court Suite J OWINGS MILLS MD 21117

Re: K162265

Trade/Device Name: CushionCast" Moldable Cushion Regulation Number: 21 CFR 892.5050 Regulation Name: Medical charged-particle radiation therapy system Regulatory Class: II Product Code: IYE Dated: September 29, 2016 Received: October 4, 2016

Dear Mr. Cao:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food. Drug. and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21. Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set 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.

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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/Resourcesfor You/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.

Michael D'Hara

For

Robert Ochs, Ph.D. Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health 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) K162265

Device Name CushionCast Moldable Cushion

Indications for Use (Describe)

The CushionCast Moldable Cushion is to be used by trained medical professionals for stable support and positioning of patients undergoing radiation therapy or other treatment in a clinic or hospital setting.

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

X 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)

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5.0 510(k) Summary

510(k) Owner

IZI Medical Products LLC 5 Easter Court, Suite J Owings Mills, MD 21117 Phone: (410) 594-9403 Fax: (410) 594-0540 Contact Person: Qiang Cao, Quality Assurance and Regulatory Affairs Manager

Date Summary Prepared: August 10th, 2016

Device Name

Trade Name: CushionCast™ Moldable Cushion

Common or Usual Name: moldable cushion

Classification Name: Medical charged-particle radiation therapy system (21 CFR 892.5050)

Product Code: IYE

Predicate Devices

Klarity Mold Cushions (K132124)

Prior Submissions

There were no prior submissions for the subject device.

Device Description

The CushionCast™ is moldable stabilization cushions for radiation therapy patients. This product targets customers who require stabilization cushions for patients who are undergoing radiation therapy. The CushionCast™ is needed in order to mold to the shape of the patient's head to immobilize any movement during radiation therapy.

The cushion is constructed with a biocompatible and water resistant fabric and internal components, which include low viscosity casting resins that are sealed in pouches and polystyrene beads as filler material. To activate the cushion, the pouches are popped, and

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the internal components are mixed for 2 minutes. The plug inserted in the vent tube is removed prior to the molding process. The vent tube serves to expel excess air to allow for an accurate mold. The mixture of the Part A and Part B liquid plastics should yield a hardened mold. The fully cured mold provides a dimensionally stable cushion required by radiotherapy systems.

Intended Use of the Device

The CushionCast™ Moldable Cushions are designed for the positioning and repositioning of patients receiving radiation therapy or other treatment. The moldable cushion is to be used by trained medical professionals for stable support and positioning of patients undergoing a radiation therapy or other treatment in a clinic or hospital setting.

Patient Population

The device is intended for use in patients undergoing external-beam radiation therapy or other teatment.

Environment of Use

The device is intended for use by a trained healthcare professional in a healthcare facility.

Claim of Substantial Equivalence

This product is substantially equivalent to existing patient positioning cushions currently being marketed as accessories to radiation therapy systems.

The equivalent device is Klarity Mold Cushion (AccuCushion) marketed by Klarity (K132124).

The Klarity Mold Cushions has an inner component of small polystyrene spheres. These are surrounded by a 1/16" layer of polycaprolactone thermoplastic that softens and is moldable at 150°F. To use the Klarity Mold cushion, a therapist must first place the cushion in an oven or in a hot water bath to heat it to about 150 F. At this temperature the cushion becomes moldable by hand and will remain moldable for about 5 to 8 minutes as it cools to room temperature.

The CushionCast™ is constructed with a biocompatible and water resistant fabric shell and internal components, which include small polystyrene beads and casting resins that are sealed in pouches. The mixture of Part A and Part B casting resins yields a durable mold with a hardening time approximately between 5 to 7 minutes after mixing. Fully cured molds provide a dimensionally stable cushion.

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Like the Klarity Mold cushion, IZI CushionCast™ hardens to create a firm support cushion, conforming to and stabilizing the patient. The cushions also conform to the structure underneath the cushion, providing a means to specifically locate a patient on a treatment table or other support device.

Based on the similarity of design and construction of the CushionCast™ and the Klarity Mold Cushions, it is reasonable to expect that these devices will have similar properties and should function in a substantially equivalent fashion. Both devices are intended for use in positioning and re-positioning patients during radiation therapy procedures and are employed in clinically similar fashions.

A design verification study was conducted to ensure that the dimensional stability of the CushionCast™ meets necessary requirements. The study also indicated that the CushionCast™ performs equivalently to the Klarity Mold Cushions. It is reasonable to conclude that the CushionCast™ and Klarity Mold Cushion are substantially equivalent with respect to use, safety, and effectiveness.