K Number
K192005
Device Name
Bausch + Lomb PreVue Inserter for enVista Preloaded
Manufacturer
Date Cleared
2019-10-04

(67 days)

Product Code
Regulation Number
886.4300
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Bausch + Lomb PreVue inserter for enVista preloaded is indicated for folding and inserting of enVista IOLs (Model MX60PL) and IOL models approved for use with this IOL insertion device as indicated in the IOL approved labeling.
Device Description
The Bausch + Lomb PreVue inserter for enVista preloaded is a sterile, single-use device used to fold and insert an intraocular lens (MX60PL) through surgical procedure into a human eye. The Inserter provides a tubular pathway through an incision over the iris, allowing delivery of an IOL into the capsular bag.
More Information

Not Found

No
The summary describes a mechanical device for inserting an intraocular lens and makes no mention of AI or ML.

No
The device is described as an inserter for intraocular lenses, which folds and inserts the lens during surgery. It is a tool used for a surgical procedure to deliver a medical device (IOL), rather than directly treating a disease or condition itself.

No

This device is described as an inserter for intraocular lenses, used to fold and implant IOLs into the eye during a surgical procedure. Its function is to deliver a medical device (IOL), not to diagnose a condition or disease.

No

The device description explicitly states it is a "sterile, single-use device used to fold and insert an intraocular lens... through surgical procedure into a human eye," indicating it is a physical hardware device.

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

Here's why:

  • IVD Definition: In vitro diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections.
  • Device Function: The description clearly states the device is used for "folding and inserting an intraocular lens (MX60PL) through surgical procedure into a human eye." This is a surgical tool used in vivo (within the living body) during a procedure, not a test performed on a sample in vitro (outside the living body).
  • Intended Use: The intended use is for inserting an IOL into the eye, which is a surgical intervention, not a diagnostic test.

Therefore, this device falls under the category of a surgical instrument or medical device used for treatment, not an in vitro diagnostic.

N/A

Intended Use / Indications for Use

The Bausch + Lomb PreVue inserter for enVista preloaded is indicated for folding and inserting of enVista IOLs (Model MX60PL) and IOL models approved for use with this IOL insertion device as indicated in the IOL approved labeling.

Product codes

MSS

Device Description

The Bausch + Lomb PreVue inserter for enVista preloaded is a sterile, single-use device used to fold and insert an intraocular lens (MX60PL) through surgical procedure into a human eye. The Inserter provides a tubular pathway through an incision over the iris, allowing delivery of an IOL into the capsular bag.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

human 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

Bench tests, laboratory tests, and evaluations were completed on the proposed B+L Pre Vue Inserter for enVista Preloaded. No animal or clinical testing was required for this submission.

Device functional performance testing all passed and demonstrates equivalence to predicate device. EO/ ECH residual transfer and Endotoxin validation testing passed. Sterilization evaluation, packaging verification, biocompatibility evaluation all met requirements and demonstrated equivalence to the predicate device. All results support the conclusion that the proposed device PreVue Inserter for enVista Preloaded demonstrates substantial equivalence to the predicate devices.

A risk analysis was conducted for the PreVue Inserter in accordance with EN ISO 14971: 2012. The Hazard and Risk Assessment follows a systematic approach by a cross-functional team to help prioritize problem prevention efforts for the PreVue, considering possible failures of components and subsystems of the product and the resulting effects. The technique employed used the bottom-up approach that is typical of Failure Mode and Effects Analysis (FMEA), while capturing all results in an FMEA table. The document is used in the design, development, and testing of PreVue to identify risks and track mitigation efforts.

Product safety risks are assessed in terms of probability that harm may occur, taking into consideration normal use and reasonably foreseeable misuse conditions. As well as, historical complaint data and applying other risk management elements as per EN ISO 14971. Each residual risk was evaluated for acceptability through a risk/benefit analysis. All identified foreseeable hazards and potential failure modes have been subjected to risk/ benefit analysis and it has been determined that the medical benefits of the intended use outweigh the overall residual risk.

Key Metrics

Not Found

Predicate Device(s)

K113852, K131958

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

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 shows 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 consists of the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG" in blue, with the word "ADMINISTRATION" underneath in a smaller font.

October 4, 2019

Bausch & Lomb, Inc Ms. Rekha Janarthanan Regulatory Affairs Manager 3365 Tree Court Industrial Blvd. St. Louis, MO 63122

Re: K192005

Trade/Device Name: Bausch + Lomb PreVue Inserter for enVista Preloaded Regulation Number: 21 CFR 886.4300 Regulation Name: Intraocular Lens Guide Regulatory Class: Class I Product Code: MSS Dated: September 3, 2019 Received: September 4, 2019

Dear Ms. Janarthanan:

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 or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's

1

requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting 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/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

for Tieuvi Nguyen, Ph.D. Acting Division Director DHT1A: Division of Ophthalmic Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K192005

Device Name

Bausch + Lomb PreVue Inserter for enVista Preloaded

Indications for Use (Describe)

The Bausch + Lomb PreVue inserter for enVista preloaded is indicated for folding and inserting of enVista IOLs (Model MX60PL) and IOL models approved for use with this IOL insertion device as indicated in the IOL approved labeling.

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)

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510(k) Summary

| Submitter: | Bausch & Lomb, Inc.
3365 Tree Court Industrial Blvd.
St. Louis, MO 63122 |
|----------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Rekha Janarthanan
Regulatory Affairs Manager
Phone: 636-226-3095
Email: rekha.janarthanan@bausch.com |
| Trade name: | Bausch + Lomb PreVue Inserter for enVista preloaded |
| Classification Name: | Intraocular lens guide (21 CFR 886.4300) |
| FDA Product Code: | MSS |
| Predicate Devices: | 1. Bausch & Lomb Injector System (K113852)
2. Bausch & Lomb Injector System, BLIS (K131958) |
| Device Description: | The Bausch + Lomb PreVue inserter for enVista preloaded is a sterile,
single-use device used to fold and insert an intraocular lens (MX60PL)
through surgical procedure into a human eye. The Inserter provides a
tubular pathway through an incision over the iris, allowing delivery of an
IOL into the capsular bag. |
| Indications for Use: | The Bausch + Lomb PreVue inserter for enVista preloaded is indicated for
folding and inserting of enVista IOLs (Model MX60PL) and IOL models
approved for use with this IOL insertion device as indicated in the IOL
approved labeling. |
| Comparative Analysis: | The Bausch + Lomb IOL Inserters have been demonstrated to be
equivalent to the predicate devices for their intended use. |
| Functional/Safety Testing: | The Bausch + Lomb IOL Inserters have successfully undergone
functional testing and are found to deliver the Bausch + Lomb IOLs in
conformance with the requirements set forth in ISO 11979-3. |
| Conclusion: | The Bausch + Lomb IOL Inserters are substantially equivalent to the
predicate devices. |

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| a. | Technological
Similarities | Predicate - Bausch + Lomb
IOL Injector, INJ100
(K113852) | Predicate - Bausch + Lomb
Injector System, BLIS
(K131958) | Subject Device - Bausch +
Lomb PreVue Inserter |
|---------------------------------|-------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Indications for
Use | | The Bausch + Lomb IOL
Injector is indicated for
folding and injection of
Bausch + Lomb IOLs
approved for use with this
injector. | The BLIS Bausch + Lomb
Injector System is indicated
for the folding and insertion
of Bausch + Lomb intraocular
lenses cleared or approved for
use with this IOL Injector
system. | The Bausch +Lomb PreVue
inserter for enVista preloaded is
indicated for folding and
inserting of enVista IOLs
(Model MX60PL) and IOL
models approved for use with
this IOL insertion device as
indicated in the IOL approved
labeling. |
| How device is
used | | The IOL is placed in the
loading chamber. A
plunger pushes the IOL
into the tip, which folds
the IOL. Pushing the
plunger further advances
the IOL out through the tip
into the eye. | The IOL is placed in the
loading cartridge. The
cartridge is snapped into the
handpiece. The screw plunger
advances the IOL through the
cartridge, which folds the
IOL and advances it into the
eye. | The preloaded IOL shuttle is
snapped into loading chamber
of the PreVue
inserter. The screw plunger
advances the IOL through the
shuttle into the cartridge
which folds the IOL and
advances it into the eye. |
| Injector/Inserter
Components | | • ABS Body
• ABS Plunger
• Polyamide Cartridge
• Medicoat A Coating | • Titanium Body
• Stainless Steel Plunger Shaft
• Titanium Plunger Tip
• Polyamide Cartridge
• Medicoat A Coating | • ABS Body
• Polyamide Cartridge
• ABS Thread Bushing
• Polypthalamide Plunger
(this uses AI- 28 as
predicate)
• ABS Spindle
• Medicoat A Coating |
| Single Use | | Injector: Yes
Cartridge: Yes | Injector: No
Cartridge: Yes | Inserter: Yes
Cartridge: Yes |
| Sterilization
Method | | Ethylene Oxide | • Cartridge: Stainless
Steel
• Injector: Shipped Non-
Sterile. Steam Sterilized
by User | Ethylene Oxide |
| Shelf Life | | 24 months | Cartridge: 24 months
Injector: Reusable | 12 months |

b.

Non Clinical TestingTestStandardsResults
Delivery VerificationFold and recovery testISO 11979-3: 2012Pass
Delivery VerificationDioptric Power and Image quality Post deliveryISO 11979-2: 2012Pass
Delivery VerificationLens Dimensions Post DeliveryISO 11979-3: 2012Pass
Delivery VerificationSurface and Bulk HomogeneityISO 11979-3: 2012Pass
Delivery VerificationPreVue Inserter Cosmetic InspectionN/APass
Delivery VerificationCoating transfer studyISO 10993-1Pass
Delivery VerificationParticle counting studyISO 10993-1Pass

5

Biocompatibility and Baseline StabilityISO 10993-1Pass
Leachable ExtractionsISO 10993-18Pass
Chemical EvaluationEvaluation and rationale for inclusion in “family
grouping” of similar devicesANSI/AAMI/ISO
11135Pass
Sterilization Validation
AdoptionProduct Adoption AnalysisEN ISO 11135:2014Pass
EO ResidualsETO/ECH Transfer Engineering Study– MVD
00170164ISO 10993-7: 2008Pass
Bacterial EndotoxinBacterial Endotoxin testANSI/AAMI
ST72:2011/(R)2016Pass
Packaging VerificationInjector Sealing Validation ReportASTM F88-09 and
ASTM F1929Pass
  • No clinical testing was performed on the subject device. c.

Summary of Nonclinical tests and Results: d.

Bench tests, laboratory tests, and evaluations were completed on the proposed B+L Pre Vue Inserter for enVista Preloaded. No animal or clinical testing was required for this submission.

Device functional performance testing all passed and demonstrates equivalence to predicate device. EO/ ECH residual transfer and Endotoxin validation testing passed. Sterilization evaluation, packaging verification, biocompatibility evaluation all met requirements and demonstrated equivalence to the predicate device. All results support the conclusion that the proposed device PreVue Inserter for enVista Preloaded demonstrates substantial equivalence to the predicate devices.

A risk analysis was conducted for the PreVue Inserter in accordance with EN ISO 14971: 2012. The Hazard and Risk Assessment follows a systematic approach by a cross-functional team to help prioritize problem prevention efforts for the PreVue, considering possible failures of components and subsystems of the product and the resulting effects. The technique employed used the bottom-up approach that is typical of Failure Mode and Effects Analysis (FMEA), while capturing all results in an FMEA table. The document is used in the design, development, and testing of PreVue to identify risks and track mitigation efforts.

Product safety risks are assessed in terms of probability that harm may occur, taking into consideration normal use and reasonably foreseeable misuse conditions. As well as, historical complaint data and applying other risk management elements as per EN ISO 14971. Each residual risk was evaluated for acceptability through a risk/benefit analysis. All identified foreseeable hazards and potential failure modes have been subjected to risk/ benefit analysis and it has been determined that the medical benefits of the intended use outweigh the overall residual risk.