K Number
K163054
Device Name
DyeVert Plus Contrast Modulation/Monitoring System, Contrast Monitoring System
Date Cleared
2017-03-08

(127 days)

Product Code
Regulation Number
870.1650
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
Display: The device consists of a display to be used with the DyeVert Plus Disposable Kit or the Contrast monitoring Disposable Kit during angiographic or CT procedures requiring controlled infusion of radiopaque contrast media. DyeVert Plus Disposable Kit: The DyeVert™ Plus Contrast Modulation/Monitoring System consists of a Display and DyeVert Plus Disposable Kit. The system is to be used for contrast volume reduction and for the monitoring of radiopaque contrast media during angiographic or CT procedures with the following agents: Iodixanol 270 or 320 mg/mL, Iohexol 300 or 350 mg/mL and Iopamidol 370 mgI/mL. Contrast Monitoring Disposable Kit: The device consists of a Smart Syringe and Pressure Module to be used with the Contrast Monitoring Display during angiographic or CT procedures requiring controlled infusion of radiopaque contrast media.
Device Description
The Osprey Medical DyeVert™ Plus Contrast Modulation/Monitoring System is a compatible system to manual contrast injections and provides fluid pathway resistance modulation and/or monitoring such that excess contrast volume (i.e. contrast that is not needed for diagnostic or therapeutic purposes also referred to as 'refluxed contrast') is minimized in the patient's vasculature. This allows for a reduction in total contrast agent volume during coronary or peripheral imaging; while maintaining adequate image quality. The DyeVert Plus Contrast Modulation/Monitoring System consists of the Display and the DyeVert Plus Disposable Kit. The Contrast Monitoring System is a component of the DyeVert™ Plus Contrast Modulation/Monitoring System and also provided separately. The system allows for real-time, wireless, monitoring and display of manually injected contrast volumes. Volumes are displayed and compared to a physician entered contrast usage threshold during angiographic procedures. The system provides a visual and audible indication of when the cumulated volume injected into the patient is approaching a physician determined contrast volume threshold. This allows for attentive physician decision-making of total contrast volume use during a patient case while allowing the physician's primary focus to remain on the image and therapeutic need of imaging. When sold separately, the Contrast Monitoring System consists of the Display and the Contrast Monitoring Disposable Kit.
More Information

Not Found

No
The document describes a system for monitoring and modulating contrast media flow based on fluid pathway resistance and volume thresholds. There is no mention of AI, ML, or any algorithms that learn or adapt from data. The performance studies focus on standard engineering and regulatory testing (bench testing, sterilization, software validation, biocompatibility) rather than AI/ML model performance metrics.

Yes.

The device minimizes excess contrast volume in the patient's vasculature to allow for a reduction in total contrast agent volume during imaging procedures while maintaining adequate image quality. This directly influences the patient's physiological state by reducing their exposure to contrast media.

No

The device is designed for contrast volume reduction and monitoring during angiographic or CT procedures. Its primary function is to minimize excess contrast and monitor contrast usage, not to diagnose a condition. While contrast media are used for diagnostic imaging, the device itself is a tool for managing the administration of the contrast, not for interpreting the images or diagnosing a patient's medical state.

No

The device description explicitly states the system consists of a "Display" and a "Disposable Kit" (either DyeVert Plus or Contrast Monitoring), and the Contrast Monitoring System includes a "Smart Syringe and Pressure Module". This indicates the device includes hardware components beyond just software.

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

Here's why:

  • Intended Use/Indications for Use: The device is used during angiographic or CT procedures to manage and monitor the infusion of radiopaque contrast media. It focuses on controlling the delivery of the contrast agent into the patient's vasculature, not on analyzing a sample taken from the patient.
  • Device Description: The description emphasizes minimizing excess contrast volume in the patient's vasculature and monitoring injected volumes. This is a procedural aid, not a diagnostic test performed on a biological sample.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples (blood, urine, tissue, etc.), detecting analytes, or providing diagnostic information based on the analysis of such samples.

The device's function is to assist the physician in managing the amount of contrast media used during imaging procedures, which is a procedural and monitoring function, not an in vitro diagnostic function.

N/A

Intended Use / Indications for Use

Indications for Use (Describe)

Display

The device consists of a display to be used with the DyeVert Plus Disposable Kit or the Contrast monitoring Disposable Kit during angiographic or CT procedures requiring controlled infusion of radiopaque contrast media.

DyeVert Plus Disposable Kit

The DyeVert™ Plus Contrast Modulation/Monitoring System consists of a Display and DyeVert Plus Disposable Kit. The system is to be used for contrast volume reduction and for the monitoring of radiopaque contrast media during angiographic or CT procedures with the following agents: Iodixanol 270 or 320 mg/mL, Iohexol 300 or 350 mg/mL and Iopamidol 370 mgI/mL.

Contrast Monitoring Disposable Kit

The device consists of a Smart Syringe and Pressure Module to be used with the Contrast Monitoring Display during angiographic or CT procedures requiring controlled infusion of radiopaque contrast media.

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

DXT

Device Description

The Osprey Medical DyeVert™ Plus Contrast Modulation/Monitoring System is a compatible system to manual contrast injections and provides fluid pathway resistance modulation and/or monitoring such that excess contrast volume (i.e. contrast that is not needed for diagnostic or therapeutic purposes also referred to as 'refluxed contrast') is minimized in the patient's vasculature. This allows for a reduction in total contrast agent volume during coronary or peripheral imaging; while maintaining adequate image quality. The DyeVert Plus Contrast Modulation/Monitoring System consists of the Display and the DyeVert Plus Disposable Kit.

The Contrast Monitoring System is a component of the DyeVert™ Plus Contrast Modulation/Monitoring System and also provided separately. The system allows for real-time, wireless, monitoring and display of manually injected contrast volumes. Volumes are displayed and compared to a physician entered contrast usage threshold during angiographic procedures. The system provides a visual and audible indication of when the cumulated volume injected into the patient is approaching a physician determined contrast volume threshold. This allows for attentive physician decision-making of total contrast volume use during a patient case while allowing the physician's primary focus to remain on the image and therapeutic need of imaging. When sold separately, the Contrast Monitoring System consists of the Display and the Contrast Monitoring Disposable Kit.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

angiographic or CT procedures

Anatomical Site

coronary or peripheral vasculature (inferred from "coronary or peripheral imaging")

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)

Bench testing was performed and/or leveraged to support this submission and results demonstrate the materials, design considerations and manufacturing processes continue to meet product specifications and performance requirements. The following testing was successfully completed and/or leveraged within this submission:

  • Device performance testing included visual verifications to design specifications, accuracy testing of cumulative and individual injection volume measurement along with display verification, compatibility with disposable kits and testing demonstrating compliance to IEC 60601-1 3.1 edition, electrical safety for medical devices and IEC 60601-1-2 (2007) emissions and immunity for non-life supporting equipment through third party testing certification. In addition, device performance testing for compatibility with contrast media and catheter configurations was leveraged and included flow rate, peak pressure, leak testing, contrast diversion, mechanical cycle testing and visual verifications to design specifications for specific contrasts and catheter configurations. All testing passed and demonstrated product performance met all prior established acceptance criteria.
  • Sterilization - Sterilization conditions have been validated in accordance with ISO 11135-1:2014, Sterilization of health care products - Ethylene Oxide Part 1: Requirements for the development, validation, and routine control of a sterilization process for medical devices to provide a Sterility Assurance Level of 10-6. All testing passed.
  • Software development process was in accordance with IEC 62304:2006 Software life cycle process and testing was performed and included verification of all software requirement specifications. All testing passed.
  • Simulated Use (Bench) design validation was performed and included the assessment of priming, disposable wireless pairing and assessment of the ease of use, system set up and device priming ability (usability). In addition, design validation was performed and leveraged for injection pressure, contrast diversion and image analysis testing. Testing demonstrated no new or different question of safety or effectiveness.
  • Packaging, shelf life and distribution testing was performed and leveraged. Distribution testing was conducted per ASTM D4169:2016 Standard Practice for Performance Testing of Shipping Containers and Systems. Testing included visual inspection, cycle testing, dye leak/penetration test, seal strength test and functional testing. All testing passed and demonstrated product performance met all prior established acceptance criteria. Packaging was deemed to be in compliance with ISO 11607 part 1 and 2:2006 Packaging for terminally sterilized medical devices.
  • Biocompatibility testing was performed and leveraged in accordance with ISO 10993-1:2009 Biological Evaluation of Medical Devices - Part I: Evaluation and Testing. Testing included cytotoxicity, sensitization, irritation and acute systemic toxicity, and hemocompatibility. All testing passed and met prior established acceptance criteria.

No clinical testing was performed to support this 510(k) Premarket Notification.

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.

K161505, K142081

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

§ 870.1650 Angiographic injector and syringe.

(a)
Identification. An angiographic injector and syringe is a device that consists of a syringe and a high-pressure injector which are used to inject contrast material into the heart, great vessels, and coronary arteries to study the heart and vessels by x-ray photography.(b)
Classification. Class II (special controls). The device, when it is a non-patient contacting balloon inflation syringe intended only to inflate/deflate balloon catheters and monitor pressure within the balloon, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 870.9.

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

March 8, 2017

Osprey Medical, Inc. Melanie Hess Vice President, Regulatory Affairs 5600 Rowland Road Suite 250 Minnetonka, Minnesota 55343

Re: K163054

Trade/Device Name: DyeVert™ Plus Contrast Modulation/Monitoring System, Contrast Monitoring System Regulation Number: 21 CFR 870.1650 Regulation Name: Angiographic Injector And Syringe Regulatory Class: Class II Product Code: DXT Dated: February 3, 2017 Received: February 6, 2017

Dear Melanie Hess:

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 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,

Fernando Agnel
Fernando
Aquel-S

for

Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K163054

Device Name

DyeVert™ Plus Contrast Modulation/Monitoring System, Contrast Monitoring System

Indications for Use (Describe)

Display

The device consists of a display to be used with the DyeVert Plus Disposable Kit or the Contrast monitoring Disposable Kit during angiographic or CT procedures requiring controlled infusion of radiopaque contrast media.

DyeVert Plus Disposable Kit

The DyeVert™ Plus Contrast Modulation/Monitoring System consists of a Display and DyeVert Plus Disposable Kit. The system is to be used for contrast volume reduction and for the monitoring of radiopaque contrast media during angiographic or CT procedures with the following agents: Iodixanol 270 or 320 mg/mL, Iohexol 300 or 350 mg/mL and Iopamidol 370 mgI/mL.

Contrast Monitoring Disposable Kit

The device consists of a Smart Syringe and Pressure Module to be used with the Contrast Monitoring Display during angiographic or CT procedures requiring controlled infusion of radiopaque contrast media.

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

Prescription Use (Part 21 CFR 801 Subpart D)X
Over-The-Counter Use (21 CFR 801 Subpart C)

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K163054

510(k) Summary
510(k) Summary As required by 21CFR 807.92(c)
510(k) Number:K163054
Date Prepared:October 31, 2016
Submitter's Name/Address:Osprey Medical
5600 Rowland Road Suite 250
Minnetonka, MN 55343
Contact Person:Melanie Hess
Vice President, Regulatory Affairs
Tel: 952-955-8252
Fax: 952-955-8171
Mhess@ospreymed.com
Device Information:
Trade Name/Proprietary Name:DyeVert™ Plus Contrast Modulation/Monitoring System
Manufacturer:Osprey Medical, Inc.
Common Name:Injector and Syringe, Angiographic
Classification Registration:21 CFR § 870.1650
Product Code:DXT
FDA Center/Branch:CDRH/Interventional Cardiology Devices Branch (ICDB)
Trade Name/Proprietary Name:Contrast Monitoring System
Manufacturer:Osprey Medical, Inc.
Common Name:Injector and Syringe, Angiographic
Classification Registration:21 CFR § 870.1650
Product Code:DXT
FDA Center/Branch:CDRH/Interventional Cardiology Devices Branch (ICDB)

Device Description:

The Osprey Medical DyeVert™ Plus Contrast Modulation/Monitoring System is a compatible system to manual contrast injections and provides fluid pathway resistance modulation and/or monitoring such that excess contrast volume (i.e. contrast that is not needed for diagnostic or therapeutic purposes also referred to as 'refluxed contrast') is minimized in the patient's vasculature. This allows for a reduction in total contrast agent volume during coronary or peripheral imaging; while maintaining adequate image quality. The DyeVert Plus Contrast Modulation/Monitoring System consists of the Display and the DyeVert Plus Disposable Kit.

The Contrast Monitoring System is a component of the DyeVert™ Plus Contrast Modulation/Monitoring System and also provided separately. The system allows for real-time, wireless, monitoring and display of manually injected contrast volumes. Volumes are displayed and compared to a physician entered contrast usage threshold during angiographic procedures. The system provides a visual and audible indication of when the cumulated volume injected into the patient is approaching a physician determined contrast volume threshold. This allows for attentive physician decision-making of total contrast volume use during a patient case while allowing the physician's primary focus to remain on the image and therapeutic need of imaging. When sold separately, the Contrast Monitoring System consists of the Display and the Contrast Monitoring Disposable Kit.

Indications for Use:

Display

The device consists of a display to be used with the DyeVert Plus Disposable Kit or the Contrast monitoring Disposable Kit during angiographic or CT procedures requiring controlled infusion of radiopaque contrast media.

4

DyeVert Plus Disposable Kit

The DyeVert™ Plus Contrast Modulation/Monitoring System consists of a Display and DyeVert Plus Disposable Kit. The system is to be used for contrast volume reduction and for the monitoring of radiopague contrast media during angiographic or CT procedures with the following agents: Iodixanol 270 or 320 mg/mL, Iohexol 300 or 350 mg/mL and Iopamidol 370 mgI/mL.

Contrast Monitoring Disposable Kit

The device consists of a Smart Syringe and Pressure Module to be used with the Contrast Monitoring Display during angiographic or CT procedures requiring controlled infusion of radiopaque contrast media.

Primary Predicate Device:

Trade Name/Proprietary Name:DyeVert™ Contrast Modulation System
Manufacturer:Osprey Medical, Inc.
Common Name:Injector and Syringe, Angiographic
Classification:II
CFR Reference:21 CFR § 870.1650
Product Code:DXT
510(k) number(s)K161505

Secondary Predicate Device:

Trade Name/Proprietary Name:CMS™ Contrast Monitoring System
Manufacturer:Osprey Medical, Inc.
Common Name:Injector and Syringe, Angiographic
Classification:II
CFR Reference:21 CFR § 870.1650
Product Code:DXT
510(k) number(s)K142081

Comparison to the Predicate Device:

The proposed devices are substantially equivalent to the previously cleared DyeVert Contrast Modulation Systems (K161505) and CMS Contrast Monitoring System (K142081) respectively, in that they are both designed for use during the controlled infusion of manual injection of radiopaque contrast media for angiographic procedures.

The proposed devices have identical product performance specification processes and benefit risk profiles. The fundamental scientific technology, principle of operation and primary mechanism of action remains unchanged. No new intended use, intended user or different questions of safety or effectiveness are raised with the proposed modifications.

Technical CharacteristicProposed DevicePredicate Device
Intended UseIntended to be used for the controlled
infusion of radiopaque contrast media
for angiographic procedures.Intended to be used for the controlled
infusion of radiopaque contrast media
for angiographic procedures.
Indications for UseThe system is to be used for contrast
volume reduction and for the monitoring
of radiopaque contrast media during
angiographic or CT procedures with the
following agents: Iodixanol 270 or 320
mgI/mL, Iohexol 300 or 350 mgI/mL
and Iopamidol 370 mgI/mL.The system is to be used for contrast
volume reduction and for the
monitoring of radiopaque contrast
media during angiographic or CT
procedures with the following agents:
Iodixanol 270 or 320 mgI/mL, Iohexol
300 or 350 mgI/mL and Iopamidol 370
mgI/mL.
Indications for Use
(Display/Syringe)To be used during angiographic or CT
procedures requiring controlled infusion
of radiopaque contrast media.
TouchscreenCapacitive touchscreen, Resolution
1280x800Resistive touchscreen, Resolution
800x600

Summary of technical characteristics comparison

5

Technical CharacteristicProposed DevicePredicate Device
User accessMultiple USB, 1 internal user accessible
(Osprey User only)1 external USB
MemoryMicroSD socket with 32GB class 10
cardExternal flash memory using a SPI
interface
AlarmsVariable audioLimited audio
DyeVert ModuleDiversion valve with reservoir; includes
sensors, electronics, circuit board and
pressure transducer to allow wireless
positioning identification. Compatible
with Contrast Monitoring DisplayDiversion valve with reservoir (does
not include additional wireless
positioning components)
Not compatible with Contrast
Monitoring Display.
SyringeContrast injection syringe; includes Hall
Effect sensors, electronics and circuit
board to allow wireless positioning
identification and communication.Contrast injection syringe with IR light
sensing positioning identification
(does not include additional wireless
communication components)
CommunicationBluetooth communications to DisplayHard wire communications to Display
PowerInternal BatteryHard Wire
Visual IndicatorsBlinking and/or solid LED
(green/amber) indicates status;
additional blinking allowing additional
status communication during disposable
pairing through Bluetooth.Solid LED (green/amber) indicates
status
Compatible Catheter
ConfigurationsDiagnostic 4Fr, 5Fr, 6Fr
Guide 5Fr, 6Fr, 7Fr
Guide with RX 6Fr, 7Fr
Guide with OTW 6Fr, 7FrDiagnostic 4Fr, 5Fr, 6Fr
Guide 5Fr, 6Fr, 7Fr
Guide with RX 6Fr, 7Fr
Guide with OTW 6Fr, 7Fr
SterilizationEO sterilization to 10-6EO sterilization to 10-6

Summary of Non-Clinical Testing:

Bench testing was performed and/or leveraged to support this submission and results demonstrate the materials, design considerations and manufacturing processes continue to meet product specifications and performance requirements. The following testing was successfully completed and/or leveraged within this submission:

  • . Device performance testing included visual verifications to design specifications, accuracy testing of cumulative and individual injection volume measurement along with display verification, compatibility with disposable kits and testing demonstrating compliance to IEC 60601-1 3.1 edition, electrical safety for medical devices and IEC 60601-1-2 (2007) emissions and immunity for non-life supporting equipment through third party testing certification. In addition, device performance testing for compatibility with contrast media and catheter configurations was leveraged and included flow rate, peak pressure, leak testing, contrast diversion, mechanical cycle testing and visual verifications to design specifications for specific contrasts and catheter configurations. All testing passed and demonstrated product performance met all prior established acceptance criteria.
  • . Sterilization - Sterilization conditions have been validated in accordance with ISO 11135-1:2014, Sterilization of health care products - Ethylene Oxide Part 1: Requirements for the development, validation, and routine control of a sterilization process for medical devices to provide a Sterility Assurance Level of 10-6. All testing passed.
  • . Software development process was in accordance with IEC 62304:2006 Software life cycle process and testing was performed and included verification of all software requirement specifications. All testing passed.
  • . Simulated Use (Bench) design validation was performed and included the assessment of priming, disposable wireless pairing and assessment of the ease of use, system set up and device priming ability (usability). In addition, design validation was performed and leveraged for injection pressure, contrast diversion and image analysis testing. Testing demonstrated no new or different question of safety or effectiveness.

6

  • . Packaging, shelf life and distribution testing was performed and leveraged. Distribution testing was conducted per ASTM D4169:2016 Standard Practice for Performance Testing of Shipping Containers and Systems. Testing included visual inspection, cycle testing, dye leak/penetration test, seal strength test and functional testing. All testing passed and demonstrated product performance met all prior established acceptance criteria. Packaging was deemed to be in compliance with ISO 11607 part 1 and 2:2006 Packaging for terminally sterilized medical devices.
  • . Biocompatibility testing was performed and leveraged in accordance with ISO 10993-1:2009 Biological Evaluation of Medical Devices - Part I: Evaluation and Testing. Testing included cytotoxicity, sensitization, irritation and acute systemic toxicity, and hemocompatibility. All testing passed and met prior established acceptance criteria.

No performance standards have been established under Section 514 of the Food, Drug and Cosmetic Act for angiographic injectors and syringes.

Clinical Testing:

No clinical testing was performed to support this 510(k) Premarket Notification.

Statement of Equivalence:

The proposed subject devices are substantially equivalent in intended use, indications for use statement and fundamental scientific technology as the predicate devices. Based on this and data analyzed in accordance with Osprey Medical Quality System Procedure in compliance with EN ISO 13485:2012 Medical Devices – Quality management systems - requirements for regulatory purposes and EN ISO 14791:2012 Risk management for medical devices, the proposed subject devices have been shown to be substantially equivalent under 21 CFR Part 807 subpart E.