K Number
K173480
Device Name
Crystalsert Lens Delivery System
Manufacturer
Date Cleared
2017-12-11

(28 days)

Product Code
Regulation Number
886.4300
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The Crystalsert Delivery System is intented to fold and deliver the Crystalens accommodating intraocular lens and other intraocular lenses identifying the Crystalsert Delivery System in their approved labeling.
Device Description
The Crystalsert Delivery System is a device used for folding and delivering the Crystalens accommodating intraocular lens and other IOLs indicating use of the Crystalsert Delivery System in their approved labeling into the eye. The Crystalsert Delivery System consists of a syringe shaped body and tip with a plunger and drawer. The Crystalsert Delivery System is a sterile, disposable plastic device, with a small tubular pathway in which the lens can be placed into the eye with one continuous motion, designed for single use only.
More Information

Not Found

No
The description focuses on the mechanical function of folding and delivering an intraocular lens and does not mention any computational or learning capabilities.

No
The device is described as a delivery system for intraocular lenses, not as a device that provides therapy itself. Its function is to facilitate the surgical insertion of a lens.

No

This device is used for delivering intraocular lenses into the eye, not for diagnosing medical conditions.

No

The device description clearly states it is a physical, disposable plastic device with a syringe-shaped body, tip, plunger, and drawer, used for folding and delivering intraocular lenses. This is a hardware device, not software.

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

Here's why:

  • Intended Use: The intended use is to "fold and deliver the Crystalens accommodating intraocular lens and other intraocular lenses... into the eye." This is a surgical delivery system for an implantable device, not a test performed on a sample taken from the body to diagnose a condition.
  • Device Description: The description details a physical device used for inserting a lens into the eye. It does not describe reagents, test strips, or equipment used for analyzing biological samples.
  • Anatomical Site: The anatomical site is the "Eye," which is the site of implantation, not the source of a diagnostic sample.
  • Performance Studies: The performance studies described are bench tests, laboratory tests, and evaluations related to the functional performance, sterilization, packaging, shelf-life, and biocompatibility of the delivery system itself. These are typical evaluations for a surgical device, not for an IVD which would focus on analytical and clinical performance related to a diagnostic test.

IVDs are used to examine specimens derived from the human body (like blood, urine, tissue) to provide information for diagnosis, monitoring, or screening. This device is a tool for delivering a therapeutic device (an intraocular lens) into the body.

N/A

Intended Use / Indications for Use

The Crystalsert Delivery System is intended to be used to fold and deliver the Crystalens accommodating intraocular lens and other intraocular lenses identifying the Crystalsert Delivery System in their approved labeling.

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

MSS

Device Description

The Crystalsert Delivery System is a device used for folding and delivering the Crystalens accommodating intraocular lens and other IOLs indicating use of the Crystalsert Delivery System in their approved labeling into the eye. The Crystalsert Delivery System consists of a syringe shaped body and tip with a plunger and drawer. The Crystalsert Delivery System is a sterile, disposable plastic device, with a small tubular pathway in which the lens can be placed into the eye with one continuous motion, designed for single use only.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Eye

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 tests, laboratory tests, and evaluations were completed on the proposed B+L Crystalsert Lens Delivery System (Model Cl-26). No animal or clinical testing was required for this submission.

Summary table of tests and results:

  • Function Performance (Before and after insertion) IOL surface & bulk homogeneity: Pass
  • Function Performance (Before and after insertion) IOL lens power: Pass
  • Function Performance (Before and after insertion) IOL image quality: Pass
  • Function Performance (Before and after insertion) IOL dimensions: Pass
  • Function Performance IOL delivery outcome: Pass
  • Function Performance Damage to insertion device: Pass
  • Function Performance Coating transfer study: Pass
  • Function Performance Particle counting study: Pass
  • Sterilization verification Evaluation and rationale for inclusion in "family grouping" of similar devices per ISO11135:2014 and AAMI TIR 28:2009: Pass
  • Packaging verification Evaluation and rationale for inclusion in "family grouping" of similar devices.: Pass
  • Product shelf life Evaluation and rationale for inclusion in "family grouping" of similar devices for a one-year shelf life.: Pass
  • Biocompatibility Evaluation and rationale was performed per ISO 10993-1:2009 and ISO 10993-18:2005. Components are either the same part or considered to be materially equivalent to parts in the predicate device. As such, no additional biocompatibility testing was warranted or conducted.: Pass
  • EO/ ECH residuals transfer test Lab testing per ISO 10993-7:2008 with protocols and acceptance criteria previously reviewed by FDA.: Pass
  • Bacterial Endotoxin Validation pre- and post-sterilization Lab testing per EN ISO 13485:2012: Pass

Device functional performance testing all passed and demonstrates equivalence to predicate device. EO/ ECH residual transfer tests all passed. Endotoxin validation testing passed. Sterilization evaluation, packaging verification, shelf-life evaluation, biocompatibility evaluation all met requirements and demonstrated equivalence to the predicate device. All results support the conclusion that the proposed device (Model Cl-26) is as safe and as effective, and therefore equivalent to the predicate device (Model CI-28).

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.

K132593

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

§ 886.4300 Intraocular lens guide.

(a)
Identification. An intraocular lens guide is a device intended to be inserted into the eye during surgery to direct the insertion of an intraocular lens and be removed after insertion is completed.(b)
Classification. Class I (general controls). Except when used as folders or injectors for soft or foldable intraocular lenses, the device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to § 886.9.

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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

December 11, 2017

Bausch & Lomb, Inc Gary Rauvola Regulatory Affairs Manager 3365 Tree Ct. Industrial Blvd. St. Louis, Missouri 63122

Re: K173480

Trade/Device Name: Crystalsert Lens Delivery System Regulation Number: 21 CFR 886.4300 Regulation Name: Intraocular Lens Guide Regulatory Class: Class I Product Code: MSS Dated: November 2, 2017 Received: November 13, 2017

Dear Gary Rauvola:

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

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(21 CFR Part 807); labeling (21 CFR Part 801); medical device 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.

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.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Denise L. Hampton -S

for Malvina B. 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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Indications for Use

510(k) Number (if known)

Device Name

Crystalsert Lens Delivery System CI-26

Indications for Use (Describe)

The Crystalsert Delivery System is intented to fold and deliver the Crystalens accommodating intraocular lens and other intraocular lenses identifying the Crystalsert Delivery System in their approved labeling.

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

This summary document has been prepared in accordance with section 21 CFR 807.92(c).

The submitter of the 510(k) is:

Gary Rauvola Regulatory Affairs Manager Bausch + Lomb 3365 Tree Court Industrial Blvd St. Louis, MO. 63122 Phone: 636-226-3402

Date Summary Prepared: November 02, 2017

1. Subject Device:

Trade name:Crystalsert Lens Delivery System
Common Name:Intraocular lens Guide
Classification Name:21 CFR 886.4300

2. Predicate Device:

Primary Predicate DeviceK132593Crystalsert Lens Delivery SystemCI-28
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3. Device Description:

The Crystalsert Delivery System is a device used for folding and delivering the Crystalens accommodating intraocular lens and other IOLs indicating use of the Crystalsert Delivery System in their approved labeling into the eye. The Crystalsert Delivery System consists of a syringe shaped body and tip with a plunger and drawer. The Crystalsert Delivery System is a sterile, disposable plastic device, with a small tubular pathway in which the lens can be placed into the eye with one continuous motion, designed for single use only.

4. Indications for Use:

The Crystalsert Delivery System is intended to be used to fold and deliver the Crystalens accommodating intraocular lens and other intraocular lenses identifying the Crystalsert Delivery System in their approved labeling.

The indications for use of the proposed device are identical to the primary predicate device.

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5. Brief Summary of Nonclinical Tests and Results:

Bench tests, laboratory tests, and evaluations were completed on the proposed B+L Crystalsert Lens Delivery System (Model Cl-26). No animal or clinical testing was required for this submission. Please refer to the summary table shown below.

ItemTestResults
Function
Performance(Before and after insertion) IOL surface & bulk
homogeneityPass
(Before and after insertion) IOL lens powerPass
(Before and after insertion) IOL image qualityPass
(Before and after insertion) IOL dimensionsPass
IOL delivery outcomePass
Damage to insertion devicePass
Coating transfer studyPass
Particle counting studyPass
Sterilization
verificationEvaluation and rationale for inclusion in "family grouping" of
similar devices per ISO11135:2014 and AAMI TIR 28:2009Pass
Packaging verificationEvaluation and rationale for inclusion in "family grouping" of
similar devices.Pass
Product shelf lifeEvaluation and rationale for inclusion in "family grouping" of
similar devices for a one-year shelf life.Pass
BiocompatibilityEvaluation and rationale was performed per ISO 10993-
1:2009 and ISO 10993-18:2005. Components are either the
same part or considered to be materially equivalent to parts
in the predicate device. As such, no additional
biocompatibility testing was warranted or conducted.Pass
EO/ ECH residuals
transfer testLab testing per ISO 10993-7:2008 with protocols and
acceptance criteria previously reviewed by FDA.Pass
Bacterial Endotoxin
Validation pre- and
post-sterilizationLab testing per EN ISO 13485:2012Pass

Device functional performance testing all passed and demonstrates equivalence to predicate device. EO/ ECH residual transfer tests all passed. Endotoxin validation testing passed. Sterilization evaluation, packaging verification, shelf-life evaluation, biocompatibility evaluation all met requirements and demonstrated equivalence to the predicate device. All results support the conclusion that the proposed device (Model Cl-26) is as safe and as effective, and therefore equivalent to the predicate device (Model CI-28).

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6. Comparative Analysis

A table comparing the proposed device to the primary predicate device is provided below.

Table 6-1: Comparison of Crystalsert Lens Delivery System Predicate Device
(Model CI-28) to the Proposed Minor Modification (Model CI-26)
CharacteristicPrimary Predicate Device
CI-28 (K132593)Proposed Device
CI-26
Indications for useThe Crystalsert Delivery System is
intended to be used to fold and deliver
the Crystalens accommodating
intraocular lens and other intraocular
lenses identifying the Crystalsert
Delivery System in their approved
labeling.The Crystalsert Delivery System is
intended to be used to fold and deliver
the Crystalens accommodating
intraocular lens and other intraocular
lenses identifying the Crystalsert
Delivery System in their approved
labeling.
ContraindicationsNoneNone
Anatomical siteEyeEye
Injector configurationBody, drawer, plunger, bearingBody, cartridge, drawer, plunger,
bearing, haptic guide
MaterialsBody, drawer, plunger, bearing:
PolypropyleneBody: drawer, plunger, bearing:
Polypropylene
Cartridge: Polyimide
How is the device
usedAn IOL is placed into the loading area
and the drawer is closed. This
compresses the IOL. The plunger is
advanced until it stops at a detent
position. The distal end is filled with
viscoelastic or balanced salt solution
and placed through an incision into the
eye. Once the tip is in the eye, the
plunger is advanced until the lens is
fully expressed into the capsular bag.An IOL is placed into the loading area
and the drawer is closed. This
compresses the IOL. The plunger is
advanced until it stops at a detent
position. The haptic guide is removed
and distal end is filled with viscoelastic
or balanced salt solution and placed
through an incision into the eye. Once
the tip is in the eye, the plunger is
advanced until the lens is fully
expressed into the capsular bag.
Single use?YesYes
Is the product sterile?SterileSterile
How sterilized/SALEthylene oxide/ 10-6Ethylene oxide/ 10-6
Shelf life12 months12 months

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7. Conclusion

The proposed Crystalsert Lens Delivery System CI-26 is substantially equivalent to the CI-28 predicate device.