(135 days)
The Cochlear Baha Connect System (Baha sound processors and implant/abutment system) is intended for the following patients and indications for use:
- Patients aged 5 and older
- Patients who have a conductive or mixed hearing loss and can still benefit from sound amplification. The pure tone average bone-conduction hearing threshold (measured at 0.5, 1, 2, and 3kHz) should be better than or equal to 45 dB HL for use with the Baha 4 and Baha 5 sound processors, 55 db HL for use with the Baha 5 Power sound processors, and 65 db HL for use with the Baha 5 SuperPower Sound Processors.
- Bilateral fitting is intended for patients who meet the above criterion in both ears, with bilaterally symmetric moderate to severe conductive or mixed hearing loss. Symmetrical bone-conductive thresholds are defined as less than a 10 dB average difference between ears (measured at 0.5, 1, 2, and 3 kHz), or less than a 15dB difference at individual frequencies.
- Patients who suffer from unilateral sensorineural deafness in one ear with normal hearing in the other ear (i.e. Single-sided deafness: SSD™). Normal hearing is defined as a pure tone average air-conduction hearing threshold (measured at 0.5, 1, 2, and 3 kHz) of better than or equal to 20 dB HL.
- Baha for SSD is also indicated for any patient who is indicated for an air-conduction contralateral routing of signals (AC CROS) hearing aid, but who for some reason cannot or will not use an AC CROS.
Specific models of the Cochlear Baha abutments can be used with either the Cochlear Baha Connect System or compatible sound processors from Oticon Medical AB. Refer to the Cochlear Baha abutment labeling for a list of compatible Oticon Medical sound processors.
A bone anchored hearing system consists of a sound processor connected to an implant with a skin penetrating abutment. The implant is surgically anchored in the skull bone behind the ear. Vibrations generated by the sound processor are transmitted via the implant directly through the skull bone to the cochlea as bone conduction sound. The BA310 abutments are modifications of the previously cleared BA300 abutments and provide additional sound processor compatibility than the previously cleared abutments. Compared to the currently cleared BA300 and BA400 Abutments, a small "flange" has been added to the upper part of the BA310 Abutment and the core diameter of the abutment has been reduced by 0.7mm. This design allows sound processors from Oticon Medical to snap on the outside of the abutment while maintaining the same snap in coupling design for connection to Baha sound processors.
This document describes the premarket notification for the Cochlear BA310 Abutment and BIA310 Implant/Abutment, a bone-conduction hearing implant system. The submission focuses on demonstrating substantial equivalence to predicate devices, particularly regarding a design modification to the abutment.
Here's an analysis based on your request, highlighting what information is present and absent:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria (What was tested for?) | Reported Device Performance (Was it met?) |
|---|---|
| Compatibility between Oticon Medical Ponto sound processors and BA310/BIA310 abutments/implants | Verified |
| Compatibility between Cochlear Baha sound processors and BA310/BIA310 abutments/implants | Verified |
| Rotation torque of the coupling connection | Tested and verified |
| Snap force of the coupling connection | Tested and verified |
| Bend force of the coupling connection | Tested and verified |
| Frequency testing of the coupling connection | Tested and verified |
| Mitigation of surgical procedure impact due to design change | Mitigated through labeling recommendations |
| Mitigation of soft tissue reaction due to closer contact of Oticon sound processors | Mitigated through labeling recommendations |
| Overall safety and effectiveness | Demonstrated as safe and effective |
Gaps in information: The document states that performance data "verifies the compatibility" and that "All design requirements were met," but it does not provide specific numerical acceptance criteria (e.g., a minimum rotation torque value) or the quantitative results from the tests. It broadly indicates that the relevant parameters were "tested and verified."
2. Sample Size Used for the Test Set and the Data Provenance
Sample Size for the test set: Not specified. The document mentions "non-clinical testing and analysis" but does not detail the number of units or conditions tested.
Data Provenance: Not specified. Given it's a non-clinical/bench testing study for a medical device modification, the data would typically originate from a laboratory setting. It is not a clinical study involving human patients.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts
This information is not applicable and not provided. The "ground truth" concept, in this context, would typically refer to clinical diagnosis or outcome verification against which an AI algorithm's performance is measured. This document describes bench testing of a physical device modification, not an AI algorithm.
4. Adjudication Method for the Test Set
This information is not applicable and not provided. Adjudication methods like 2+1 or 3+1 are used in clinical studies or expert review processes, typically for establishing ground truth for diagnostic accuracy, which is not what this submission is about.
5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study Was Done, If So, What Was the Effect Size of How Much Human Readers Improve with AI vs Without AI Assistance
This information is not applicable and not provided. This submission concerns a physical medical device (a hearing implant abutment) and its bench testing, not an AI-powered diagnostic or assistive technology. Therefore, an MRMC study related to AI assistance is irrelevant here.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) Was Done
This information is not applicable and not provided. This document does not describe an algorithm or AI device; it describes a mechanical component of a hearing aid system.
7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.)
This information is not applicable and not explicitly defined in the context of "ground truth" as typically used for AI/diagnostic studies. For this device modification, the "ground truth" would be the engineering specifications and functional requirements for the abutment's mechanical performance and compatibility. The document states that "All design requirements were met," implying these engineering specifications served as the "ground truth" for the non-clinical tests.
8. The Sample Size for the Training Set
This information is not applicable and not provided. This is not an AI/machine learning study, so there is no concept of a "training set."
9. How the Ground Truth for the Training Set Was Established
This information is not applicable and not provided. As there is no training set, the establishment of its ground truth is irrelevant.
{0}------------------------------------------------
Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health and Human Services seal on the left and the FDA acronym along with the full name of the agency on the right. The FDA part of the logo is in blue, with the acronym in a square and the full name written out to the right of it. The text reads "FDA U.S. FOOD & DRUG ADMINISTRATION".
December 19, 2018
Cochlear Americas Beth Murray Senior Regulatory Affairs Specialist 13059 E. Peakview Ave. Centennial, CO 80111
Re: K182116
Trade/Device Name: BA310 Abutment, BIA310 Implant/Abutment Regulation Number: 21 CFR 874.3300 Regulation Name: Hearing Aid Regulatory Class: Class II Product Code: MAH Dated: November 19, 2018 Received: November 20, 2018
Dear Beth Murray:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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 (feporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see
https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.htm); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; 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 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,
Srinivas Nandkumar -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
{2}------------------------------------------------
Indications for Use
510(k) Number (if known)
Device Name
Cochlear Baha Connect System
Indications for Use (Describe)
The Cochlear Baha Connect System (Baha sound processors and implant/abutment system) is intended for the following patients and indications for use:
- Patients aged 5 and older
- Patients who have a conductive or mixed hearing loss and can still benefit from sound amplification. The pure tone average bone-conduction hearing thressured at 0.5, 1, 2, and 3kHz) should be better than or equal to 45 dB HL for use with the Baha 4 and Baha 5 sound processors. 55 db HL for use with the Baha 5 Power sound processors. and 65 db HL for use with the Baha 5 SuperPower Sound Processors.
- · Bilateral fitting is intended for patients who meet the above criterion in both ears, with bilaterally symmetric moderate to severe conductive or mixed hearing loss. Symmetrical bone-conductive thresholds are defined as 10 dB average difference between ears (measured at 0.5, 1, 2, and 3 kHz), or less than a 15dB difference at individual frequencies.
- · Patients who suffer from unilateral sensorineural deafness in one ear with normal hearing in the other ear (i.e. Singlesided deafness: SSD™). Normal hearing is defined as a pure tone average air-conduction hearing threshold (measured at 0.5, 1, 2, and 3 kHz) of better than or equal to 20 dB HL.
- · Baha for SSD is also indicated for any patient who is indicated for an air-conduction contralateral routing of signals (AC CROS) hearing aid, but who for some reason cannot or will not use an AC CROS.
Specific models of the Cochlear Baha abutments can be used with either the Cochlear Baha Connect System or compatible sound processors from Otical AB. Refer to the Cochlear Baha abutment labeling for a list of compatible Oticon Medical sound processors.
| 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) |
CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
*DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW *
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov
"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."
{3}------------------------------------------------
1. 510(k) Summary
A. Submitter Information
| Submitted by: | Cochlear Americas13059 East Peakview Ave.Centennial, CO 80111 |
|---|---|
| On behalf of the manufacturer: | Cochlear Bone Anchored Solutions ABKonstruktionsvägen 14SE-435 33 MölnlyckeSweden(Establishment Number 9616024) |
| Contact: | Beth MurrayEmail: bemurray@cochlear.com(303) 264-2318 (o)(303) 524-6825 (f) |
Date Prepared August 02, 2018
B. Device Name and Classification Information
| Trade Name: | Cochlear ™ Baha® Implant System |
|---|---|
| Common or Usual Name: | Bone Conduction Hearing Implant System |
| Classification Name: | Hearing Aid, Bone Conduction, Implanted21 CFR 874.3300, Class II |
| Classification Panel: | Ear, Nose, and Throat |
| Product Codes: | MAH |
C. Predicate Devices:
| Device | 510(k) no. | Manufacturer |
|---|---|---|
| BA300 Cochlear Baha Abutment(primary predicate device) | K100360 | Cochlear Bone Anchored SolutionsAB |
| BA400 Cochlear Baha Abutment(additional predicate device) | K121317 | Cochlear Bone Anchored SolutionsAB |
| Ponto System(additional predicate device) | K161671 | Oticon Medical AB |
{4}------------------------------------------------
Device Description
Intended Use
The Cochlear Baha Connect system is intended for treatment of patients who have conductive or mixed hearing loss as a result of certain medical conditions such as bilateral atresia and chronic supportive otitis media, and for those who have Single-Sided Deafness (SSD) caused by a congenital condition, surgery, trauma, or disease. The intended use of the system is to provide an osseointegrated fixation point for connection of an external sound processor. The intended use remains unchanged from the predicate device.
Indications for Use
The Cochlear Baha Connect System (Baha sound processors and implant/abutment system) is intended for the following patients and indications for use:
- Patients aged 5 and older ●
- . Patients who have a conductive or mixed hearing loss and can still benefit from sound amplification. The pure tone average bone-conduction hearing threshold (measured at 0.5, 1, 2, and 3kHz) should be better than or equal to 45 dB HL for use with the Baha 4 and Baha 5 sound processors, 55 db HL for use with the Baha 5 Power sound processors, and 65 db HL for use with the Baha 5 SuperPower Sound Processors.
- Bilateral fitting is intended for patients who meet the above criterion in both ears, with bilaterally symmetric moderate to severe conductive or mixed hearing loss. Symmetrical bone-conductive thresholds are defined as less than a 10 dB average difference between ears (measured at 0.5, 1, 2, and 3 kHz), or less than a 15dB difference at individual frequencies.
- Patients who suffer from unilateral sensorineural deafness in one ear with normal hearing ● in the other ear (i.e. Single-sided deafness: SSD™). Normal hearing is defined as a pure tone average air-conduction hearing threshold (measured at 0.5, 1, 2, and 3 kHz) of better than or equal to 20 dB HL.
- Baha for SSD is also indicated for any patient who is indicated for an air-conduction ● contralateral routing of signals (AC CROS) hearing aid, but who for some reason cannot or will not use an AC CROS.
Specific models of the Cochlear Baha abutments can be used with either the Cochlear Baha Connect System or compatible sound processors from Oticon Medical AB. Refer to the Cochlear Baha abutment labeling for a list of compatible Oticon Medical sound processors.
{5}------------------------------------------------
Technological Characteristics
The BA310 abutments are modifications of the previously cleared BA300 abutments and provide additional sound processor compatibility than the previously cleared abutments. A bone anchored hearing system consists of a sound processor connected to an implant with a skin penetrating abutment. The implant is surgically anchored in the skull bone behind the ear. Vibrations generated by the sound processor are transmitted via the implant directly through the skull bone to the cochlea as bone conduction sound. Compared to the currently cleared BA300 and BA400 Abutments, a small "flange" has been added to the upper part of the BA310 Abutment and the core diameter of the abutment has been reduced by 0.7mm. This design allows sound processors from Oticon Medical to snap on the outside of the abutment while maintaining the same snap in coupling design for connection to Baha sound processors. It was identified that the design change may have an impact on the surgical procedure if changing from a BA300 or BA400 abutment to a BA310 abutment. It was also identified that due to the close contact between the soft tissue and the snap on coupling connection of the Oticon Sound Processor, there may be an impact on soft tissue reaction. Both of these potential issues are mitigated through recommendations added to the BA310 surgery guide and any residual risk is regarded as acceptable when weighed against the benefit of the Baha system.
Performance Data
Pertinent dimensions of the BA310 Abutment were designed to permit compatibility between the Oticon Medical Ponto sound processors and BA310/BIA310 abutments/implants, and also between Cochlear Baha sound processors. The Cochlear Baha sound processor and Baha BA310 Abutment snap in coupling connection has been tested in cross combination with the Oticon Medical Ponto sound processor with snap on coupling connection. Rotation torque, snap force, bend force and frequency testing verifies the compatibility of both Oticon Medical Ponto sound processors and Cochlear Baha sound processors with the BA310 Abutment.
Substantial Equivalence
The Baha system with modified abutment has the same intended use, same indications, same principles of operations, and same materials as compared to the predicate Baha abutment. The only technological difference is a simple design change to the abutment. The updated labelling accounts for the abutment diameter change when changing from the BA300 or BA400 abutment to the BA310 abutment and accounts for the closer contact of Oticon Medical's sound processors snap coupling to the soft tissue. All design requirements were met and the conclusions drawn from non-clinical testing and analysis demonstrate the modified abutment is as safe, as effective, and performs as well as the previously cleared versions of the Baha system and Ponto abutment.
{6}------------------------------------------------
The minor design change has been accounted for through labeling recommendations and verified as safe and effective through non-clinical testing. It can be concluded that the BA310/BIA310 Abutments are substantially equivalent.
§ 874.3302 Bone-conduction hearing aid.
(a)
Identification. A bone-conduction hearing aid is a wearable sound-amplifying device intended to compensate for impaired hearing and that conducts sound to the inner ear through the skull. The non-implantable components of a bone-conduction hearing aid, such as the external sound processor, are subject to the requirements in § 801.422 of this chapter.(b)
Classification. Class II.