(94 days)
No
The summary describes automated precision control and integration with pre-op analysis devices, but does not mention AI or ML. The "IntelliAxis" feature appears to be a form of automated alignment based on pre-operative data and iris registration, not necessarily an AI/ML algorithm.
Yes
The device is used to perform surgical procedures (anterior capsulotomy, laser phacofragmentation, and creation of corneal incisions) on patients undergoing cataract surgery, which directly treats the condition.
No
The device is described as a medical device for use in ophthalmic surgery for therapeutic procedures (cutting, fragmentation, incisions) rather than for diagnosing conditions. While it includes "integration with preop analysis devices" and "treatment planning tools," its primary function is surgical intervention.
No
The device description explicitly states it utilizes a "pulsed laser" and is a "medical device for use in ophthalmic surgery," indicating it is a hardware system that includes a laser component, not solely software.
Based on the provided information, this device is not an In Vitro Diagnostic (IVD).
Here's why:
- Intended Use: The intended use clearly states the device is for use in patients undergoing cataract surgery for procedures like anterior capsulotomy, laser phacofragmentation, and corneal incisions. These are surgical procedures performed directly on the patient's body.
- Device Description: The description details a laser system used for cutting and fragmenting tissue within the eye during surgery.
- Anatomical Site: The anatomical sites listed (Crystalline lens, cornea, anterior lens capsule) are all parts of the human eye, which is a living organism.
- IVD Definition: In Vitro Diagnostics are defined as medical devices and accessories used to perform tests on samples taken from the human body (such as blood, urine, or tissue) to provide information about a person's health. This device does not perform tests on samples taken from the body.
The LENSAR Laser System - fs 3D is a surgical device used in vivo (within a living organism), not in vitro (in glass or outside of a living organism).
N/A
Intended Use / Indications for Use
The LENSAR Laser System - fs 3D (LLS-fs 3D) is intended for use in patients undergoing cataract surgery for removal of the crystalline lens. Intended uses in cataract surgery include anterior capsulotomy, laser phacofragmentation, and the creation of full and partial thickness single-plane and multi-plane are cuts/incisions in the cornea, each of which may be performed either individually or consecutively during the same procedure.
Product codes
OOE, HQC
Device Description
The LENSAR Laser System - fs 3D (LLS-fs 3D) with Streamline™ is a medical device for use in ophthalmic surgery. The device utilizes a pulsed laser that can be used to cut a precision capsulotomy in the anterior lens capsule, to fragment the cataractous lens for removal during cataract surgery, and to create full and partial thickness single-plane and multi-plane arc cuts/ incisions in the cornea, each of which may be performed either individually or consecutively during the same procedure. Use of the laser provides automated precision control of the size of the capsular opening: the type and parameters of laser fragment within the lens; as well as the size, architecture of incisions within the cornea, and depth of arcuate incisions. The LENSAR Laser System - fs 3D (LLS-fs 3D) with Streamline" includes the integration with preop analysis devices, automated Iris Registration with automatic cyclorotation adjustment, IntelliAxis" corneal and capsule marking for simple alignment of Toric IOLs as well as treatment planning tools for precision-guided laser treatments.
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Not Found
Anatomical Site
Crystalline lens, cornea, lens capsule
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
Performance Evaluation of the Capsular IntelliAxis Feature: Verification and validation testing were completed to demonstrate that the proposed device performance complies with specifications and requirements identified for the LENSAR Capsular IntelliAxis (aka IntelliCap) feature. Each function and/or feature was verified through unit testing and system testing by means of the appropriate test case or test specification. The unit/system verification test reports provide the test cases, expected results for each test case, and the actual results obtained. All criteria for this testing were met and the results demonstrate that the LENSAR Capsular IntelliAxis feature meets all performance specifications and requirements. The objectives defined in the validation plan were achieved according to the validation results. The software on the proposed LLS-fs 3D System has been updated in support of the changes outlined above.
Specifically, a study using porcine eyes was undertaken to (a) demonstrate the effectiveness and ease of use of the Capsular IntelliAxis feature as compared to K170576 (use of topographic measurements in pre-operative data entry) and K123859 (Arcuate Incisions) and (b) establish the substantial equivalence of the safety profile comparing the biomechanical strength for the LENSAR laser capsulotomy with alignment marks to that of the standard LENSAR laser capsulotomy cleared by FDA under 510(k) K112098.
The results show that the alignment marks are visible intraoperatively and, therefore, effective in helping surgeons to align the Toric IOL marks along the axis of astigmatism. Furthermore, the tensile test study demonstrates that the capsular rim for capsulotomy with alignment marks or nubs is substantially equivalent in elongation and tensile strength (ability to elongate and resistance to tearing under a radial force) to the standard capsulotomy with no alignment marks. Further, the accuracy of the requirements of the Capsular IntelliAxis feature was validated. The minor differences between the proposed LENSAR device feature and the predicate device do not raise any new questions of safety or effectiveness.
Key Metrics
elongation and tensile strength
Predicate Device(s)
Reference Device(s)
Not Found
Predetermined Change Control Plan (PCCP) - All Relevant Information
Not Found
§ 886.4390 Ophthalmic laser.
(a)
Identification. An ophthalmic laser is an AC-powered device intended to coagulate or cut tissue of the eye, orbit, or surrounding skin by a laser beam.(b)
Classification. Class II.
0
DEPARTMENT OF HEALTH & HUMAN SERVICES
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Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
August 24, 2017
LENSAR, Inc. Keith Peck Director, Quality Assurance 2800 Discovery Drive, Suite 100 Orlando, Florida 32826
Re: K171337/S002
Trade/Device Name: LENSAR Laser System - fs 3D (LLS-fs 3D) Regulation Number: 21 CFR 886.4390, 886.4670 Regulation Name: Ophthalmic laser Regulatory Class: Class II Product Code: OOE, HOC Dated: June 16, 2017 Received: June 19, 2017
Dear Keith Peck:
This letter corrects our substantially equivalent letter of August 10, 2017.
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
1
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.
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 (DICE) 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 (DICE) 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,
Denise L. Hampton -S
for Malvina 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
Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2020 See PRA Statement below.
510(k) Number (if known) K171337
Device Name
LENSAR Laser System - fs 3D (LLS-fs 3D)
Indications for Use (Describe)
The LENSAR Laser System - fs 3D (LLS-fs 3D) is intended for use in patients undergoing cataract surgery for removal of the crystalline lens. Intended uses in cataract surgery include anterior capsulotomy, laser phacofragmentation, and the creation of full and partial thickness single-plane and multi-plane are cuts/incisions in the cornea, each of which may be performed either individually or consecutively during the same procedure.
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)
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510(k) SUMMARY
This 510(k) Summary document has been prepared in accordance with the requirements of 21 CFR 807.92.
SUBMITTER INFORMATION 1.0
The submitter of this 510(k) Summary is:
| Company: | |
|---|---|
| ---------- | -- |
Contact Person:
LENSAR, Inc. 2800 Discovery Drive, Suite 100 Orlando, FL 32826
Keith Peck (888) 575-6412 (Office) (407) 386-7228 (Fax)
Summary Preparation Date: May 5, 2017
2.0 DEVICE NAME
| Trade/Proprietary Name | LENSAR Laser System – fs 3D (LLS-fs 3D) |
|---|---|
| Common/Usual Name | LENSAR Laser System (LLS) |
| Classification Name(s) | Ophthalmic Femtosecond Laser (21 CFR 886.4390) |
| Phacofragmentation System (21 CFR 886.4670) | |
| Product Code(s) | OOE; HQC |
| Review Panel | Ophthalmic |
| Regulatory Class | II |
3.0 PREDICATE DEVICE(S)
The legally marketed (predicate) devices to which LENSAR is claiming substantial equivalence are:
| 510(k) Number | Device | Date Cleared |
|---|---|---|
| K170576 (Primary) | LENSAR Laser System - fs 3D (LLS-fs 3D) (Iris Registration | |
| and i-Optics Cassini, Nidek OPD Scan, Pentacam® HR and | ||
| AXL, and Topcon Aladdin Topographers) | 05/05/2017 | |
| K112098 | LENSAR Laser System - fs 3D (LLS-fs 3D) (Intended for use | |
| in cataract surgery includes anterior capsulotomy and laser | ||
| phacofragmentation, each of which may be performed either | ||
| individually or consecutively during the same procedure.) | 10/19/2011 | |
| K123859 | LENSAR Laser System - fs 3D (LLS-fs 3D) (Intended for use | |
| in cataract surgery includes anterior capsulotomy, laser | ||
| phacofragmentation, and the creation of full and partial | ||
| thickness single-plane and multi-plane arc cuts/ incisions in the | ||
| cornea, each of which may be performed either individually or | ||
| consecutively during the same procedure.) | 03/27/2013 |
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4.0 DEVICE DESCRIPTION
The LENSAR Laser System - fs 3D (LLS-fs 3D) with Streamline™ is a medical device for use in ophthalmic surgery. The device utilizes a pulsed laser that can be used to cut a precision capsulotomy in the anterior lens capsule, to fragment the cataractous lens for removal during cataract surgery, and to create full and partial thickness single-plane and multi-plane arc cuts/ incisions in the cornea, each of which may be performed either individually or consecutively during the same procedure. Use of the laser provides automated precision control of the size of the capsular opening: the type and parameters of laser fragment within the lens; as well as the size, architecture of incisions within the cornea, and depth of arcuate incisions. The LENSAR Laser System - fs 3D (LLS-fs 3D) with Streamline" includes the integration with preop analysis devices, automated Iris Registration with automatic cyclorotation adjustment, IntelliAxis" corneal and capsule marking for simple alignment of Toric IOLs as well as treatment planning tools for precision-guided laser treatments.
5.0 INDICATIONS FOR USE
The LENSAR Laser System - fs 3D (LLS-fs 3D) is intended for use in patients undergoing cataract surgery for removal of the crystalline lens. Intended uses in cataract surgery include anterior capsulotomy, laser phacofragmentation, and the creation of full and partial thickness single-plane and multi-plane arc cuts/incisions in the cornea, each of which may be performed either individually or consecutively during the same procedure.
6.0 COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE
All elements of the proposed device remain unchanged from that cleared in the legally marketed (predicate) devices except for:
- an update to the software that allows for a modification to the current capsulotomy . procedure that will place laser marks, using standard pre-operative data, onto the lens capsule as part of the capsulotomy to identify the astigmatic axis as prescribed by the surgeon. The modification allows the user to place two small protuberances/alignment marks created by the laser on the capsular rim on an axis that is defined by the surgeon using pre-operative data already received by the LENSAR Laser System from one of the cleared topographers or as entered by the surgeon.
7.0 PERFORMANCE DATA
The following performance data were undertaken in support of the substantial equivalence determination.
Performance Evaluation of the Capsular IntelliAxis Feature:
Verification and validation testing were completed to demonstrate that the proposed device performance complies with specifications and requirements identified for the LENSAR Capsular IntelliAxis (aka IntelliCap) feature. Each function and/or feature was verified through unit testing and system testing by means of the appropriate test case or test specification. The unit/
5
system verification test reports provide the test cases, expected results for each test case, and the actual results obtained. All criteria for this testing were met and the results demonstrate that the LENSAR Capsular IntelliAxis feature meets all performance specifications and requirements. The objectives defined in the validation plan were achieved according to the validation results. The software on the proposed LLS-fs 3D System has been updated in support of the changes outlined above.
Specifically, a study using porcine eyes was undertaken to (a) demonstrate the effectiveness and ease of use of the Capsular IntelliAxis feature as compared to K170576 (use of topographic measurements in pre-operative data entry) and K123859 (Arcuate Incisions) and (b) establish the substantial equivalence of the safety profile comparing the biomechanical strength for the LENSAR laser capsulotomy with alignment marks to that of the standard LENSAR laser capsulotomy cleared by FDA under 510(k) K112098.
The results show that the alignment marks are visible intraoperatively and, therefore, effective in helping surgeons to align the Toric IOL marks along the axis of astigmatism. Furthermore, the tensile test study demonstrates that the capsular rim for capsulotomy with alignment marks or nubs is substantially equivalent in elongation and tensile strength (ability to elongate and resistance to tearing under a radial force) to the standard capsulotomy with no alignment marks. Further, the accuracy of the requirements of the Capsular IntelliAxis feature was validated. The minor differences between the proposed LENSAR device feature and the predicate device do not raise any new questions of safety or effectiveness.
Summary of Clinical Studies
The addition of Capsular IntelliAxis feature of the LENSAR Laser System does not change the indication for use. Clinical performance data to demonstrate substantial equivalence was not required for this product change.
CONCLUSIONS 8.0
Based on the above supportive information, the proposed LENSAR Laser System - fs 3D (LLS-fs 3D) with the Capsular IntelliAxis feature is substantially equivalent with respect to safety and effectiveness and indication for use as cleared in the predicate laser file (K112098, K123859, and K170576).