K Number
K242133
Device Name
Intra-Operative Positioning System (IOPS®) (Fiducial Tracking Pad); Intra-Operative Positioning System (IOPS®) (Guidewire Handle)
Date Cleared
2024-10-11

(81 days)

Product Code
Regulation Number
870.1425
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The IOPS (Intra-Operative Positioning System) is intended for the evaluation of vascular anatomy as captured via 3D modeling from previously acquired scan data. It is intended for real time tip positioning and navigation using sensor-equipped compatible catheters and quidewires used in endovascular interventions in the descending aorta. The system is indicated for use as an adjunct to fluoroscopy. The IOPS does not make a diagnosis.
Device Description
IOPS Fiducial Tracking Pad is a sterile, single use tracking pad intended for use with the Intra-Operative Positioning System (IOPS), manufactured by Centerline Biomedical. It is equipped with a single tracking sensor allowing IOPS to track gross patient motion to allow maintenance of patient registration during a procedure. It will not track minor patient motion such as breathing or cardiac movement. The tracking pad is equipped with radiopaque beads which allow registration of a conebeam CT scan of the patient in their current position to a previously acquired CT scan. IOPS Guidewire Handle is a sterile, single use, non-sensorized device intended for use with the Intra-Operative Positioning System (OPS) and its sensorized 0.035″ guidewire, manufactured by Centerline Biomedical. It is meant to be connected to an IOPS sensorized guidewire to allow detection and visualization of the guidewire tip position, in real time, on a 3D rendering of the patient's vascular map.
More Information

Not Found

No
The summary describes a system for real-time tracking and navigation using sensors and pre-acquired scan data, but there is no mention of AI or ML algorithms being used for image processing, analysis, or decision-making. The focus is on positional tracking and visualization.

No.
The device is intended for real-time tip positioning and navigation during endovascular interventions, acting as an adjunct to fluoroscopy and providing evaluation of vascular anatomy; it does not directly treat or diagnose a disease.

No

The "Intended Use / Indications for Use" section explicitly states, "The IOPS does not make a diagnosis." The device is intended for "evaluation of vascular anatomy" and "real time tip positioning and navigation" during interventions, serving as an "adjunct to fluoroscopy," which are all related to guiding a procedure rather than making a diagnosis.

No

The device description explicitly mentions physical components like the "IOPS Fiducial Tracking Pad" and "IOPS Guidewire Handle," which are described as sterile, single-use devices with physical features (tracking sensor, radiopaque beads, handle). The performance studies also include testing on these physical components (dimensional analysis, tensile, radiopacity, biocompatibility, sterilization, etc.), indicating they are integral hardware parts of the system.

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

Here's why:

  • Intended Use: The intended use clearly states that the IOPS is for the "evaluation of vascular anatomy as captured via 3D modeling from previously acquired scan data" and for "real time tip positioning and navigation using sensor-equipped compatible catheters and guidewires used in endovascular interventions." It explicitly states that the "IOPS does not make a diagnosis."
  • Device Description: The device components described (Fiducial Tracking Pad, Guidewire Handle) are used for tracking and navigation during a medical procedure, not for analyzing biological samples to diagnose a condition.
  • Lack of IVD Characteristics: There is no mention of the device being used to examine specimens derived from the human body (like blood, urine, tissue, etc.) to provide information for diagnosis, monitoring, or treatment.

The device is a surgical navigation system that uses imaging data to guide instruments during a procedure. This falls under the category of medical devices used for surgical planning and guidance, not in vitro diagnostics.

N/A

Intended Use / Indications for Use

The IOPS (Intra-Operative Positioning System) is intended for the evaluation of vascular anatomy as captured via 3D modeling from previously acquired scan data. It is intended for real time tip positioning and navigation using sensor-equipped compatible catheters and quidewires used in endovascular interventions in the descending aorta. The system is indicated for use as an adjunct to fluoroscopy. The IOPS does not make a diagnosis.

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

DQK

Device Description

IOPS Fiducial Tracking Pad is a sterile, single use tracking pad intended for use with the Intra-Operative Positioning System (IOPS), manufactured by Centerline Biomedical. It is equipped with a single tracking sensor allowing IOPS to track gross patient motion to allow maintenance of patient registration during a procedure. It will not track minor patient motion such as breathing or cardiac movement. The tracking pad is equipped with radiopaque beads which allow registration of a conebeam CT scan of the patient in their current position to a previously acquired CT scan.

IOPS Guidewire Handle is a sterile, single use, non-sensorized device intended for use with the Intra-Operative Positioning System (OPS) and its sensorized 0.035″ guidewire, manufactured by Centerline Biomedical. It is meant to be connected to an IOPS sensorized guidewire to allow detection and visualization of the guidewire tip position, in real time, on a 3D rendering of the patient's vascular map.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

3D modeling from previously acquired scan data. conebeam CT scan.

Anatomical Site

descending aorta

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)

Non-Clinical Testing:
The following tests were conducted on the IOPS Fiducial Tracking Pad and IOPS Guidewire Handle to establish equivalency to the predicate device in safety and effectiveness:

  • Dimensional Analysis
  • Device Functionality and Essential Performance
  • Tensile
  • Radiopacity
  • Accuracy Testing with IOPS per ASTM F2554
  • IEC 60601 and Applied Part Testing
  • Biocompatibility per ISO 10993
  • Sterilization per ISO 14937 and TIR56
  • EO/ECH Residuals per ISO 10993-7
  • Packaging Integrity per ISO 11607
  • Design Validation

Conclusion:
The subject devices have similar technological characteristics and the same indications/intended use as the predicate device. The differences in technological characteristics do not raise new or different questions of safety or effectiveness. The successful completion of non-clinical testing demonstrates that the IOPS Fiducial Tracking Pad and IOPS Guidewire Handle perform as intended and are substantially equivalent to the predicate.

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.

K190106, K230309

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

§ 870.1425 Programmable diagnostic computer.

(a)
Identification. A programmable diagnostic computer is a device that can be programmed to compute various physiologic or blood flow parameters based on the output from one or more electrodes, transducers, or measuring devices; this device includes any associated commercially supplied programs.(b)
Classification. Class II (performance standards).

0

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October 11, 2024

Centerline Biomedical, Inc. Amanda Shade Sr. Regulatory Affairs Manager 10000 Cedar Ave Cleveland, Ohio 44106

Re: K242133

Trade/Device Name: Intra-Operative Positioning System (IOPS®) (Fiducial Tracking Pad); Intra-Operative Positioning System (IOPS®) (Guidewire Handle) Regulation Number: 21 CFR 870.1425 Regulation Name: Programmable Diagnostic Computer Regulatory Class: Class II Product Code: DQK Dated: July 19, 2024 Received: July 22, 2024

Dear Amanda Shade:

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 (the 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 available 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.

1

Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).

Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30. Design controls; 21 CFR 820.90. Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).

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 of medical device-related adverse events) (21 CFR Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.

All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rule"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-device-advicecomprehensive-regulatory-assistance/unique-device-identification-system-udi-system.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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 medical devices and radiation-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-regulatory

2

assistance/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,

Aneesh S. Deoras -S

Aneesh Deoras Assistant Director Division of Cardiac Electrophysiology, Diagnostics, and Monitoring Devices Office of Cardiovascular Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

3

Indications for Use

Submission Number (if known)

K242133

Device Name

Intra-Operative Positioning System (IOPS®) (Fiducial Tracking Pad);

Intra-Operative Positioning System (IOPS®) (Guidewire Handle)

Indications for Use (Describe)

The IOPS (Intra-Operative Positioning System) is intended for the evaluation of vascular anatomy as captured via 3D modeling from previously acquired scan data. It is intended for real time tip positioning and navigation using sensor-equipped compatible catheters and quidewires used in endovascular interventions in the descending aorta. The system is indicated for use as an adjunct to fluoroscopy. The IOPS does not make a diagnosis.

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) #:K242133510(k) SummaryPrepared on: 2024-09-11
-------------------------------------------------------------

Contact Details

Applicant NameCenterline Biomedical, Inc.
Applicant Address10000 Cedar Ave Cleveland OH 44106 United States
Applicant Contact Telephone216-206-7364
Applicant ContactAmanda Shade
Applicant Contact Emailamanda@centerlinebiomedical.com

Device Name
21 CFR 807.92(a)(2)

| Device Trade Name | Intra-Operative Positioning System (IOPS®) (Fiducial Tracking Pad);
Intra-Operative Positioning System (IOPS®) (Guidewire Handle) |
|---------------------|--------------------------------------------------------------------------------------------------------------------------------------|
| Common Name | Programmable diagnostic computer |
| Classification Name | Computer, Diagnostic, Programmable |
| Regulation Number | 870.1425 |
| Product Code(s) | DQK |

Legally Marketed Predicate Devices
21 CFR 807.92(a)(3)

Predicate #Predicate Trade Name (Primary Predicate is listed first)Product Code
K190106Intra-Operative Positioning System (IOPS): Tracking Pad; GuideDQK
K230309IOPS Tracking Pad (TP-1); IOPS Guidewire Handle (SSH-1)DQK

Device Description Summary
21 CFR 807.92(a)(4)IOPS Fiducial Tracking Pad is a sterile, single use tracking pad intended for use with the Intra-Operative Positioning System (IOPS), manufactured by Centerline Biomedical. It is equipped with a single tracking sensor allowing IOPS to track gross patient motion to allow maintenance of patient registration during a procedure. It will not track minor patient motion such as breathing or cardiac movement. The tracking pad is equipped with radiopaque beads which allow registration of a conebeam CT scan of the patient in their current position to a previously acquired CT scan.

IOPS Guidewire Handle is a sterile, single use, non-sensorized device intended for use with the Intra-Operative Positioning System (OPS) and its sensorized 0.035″ guidewire, manufactured by Centerline Biomedical. It is meant to be connected to an IOPS sensorized guidewire to allow detection and visualization of the guidewire tip position, in real time, on a 3D rendering of the patient's vascular map.

Intended Use/Indications for Use

The IOPS (Intra-Operative Positioning System) is intended for the evaluation of vascular anatomy as captured via 3D modeling from previously acquired scan data. It is intented for real time tip position using sensor-equipped compatible catheters and guidewires used in endovascular interventions in the system is indicated for use as an adjunct to fluoroscopy. The IOPS does not make a diagnosis.

Indications for Use Comparison

21 CFR 807.92(a)(5)

21 CFR 807.92(a)(5)

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The indications for use of IOPS Fiducial Tracking Pad and IOPS Guidewire Handle have not changed from the predicate devices.

Technological Comparison

21 CFR 807.92(a)(6)

The subject and predicate devices are intended for use with the Intra-Operative Positioning System. The principles of operation of IOPS Fiducial Tracking Pad and IOPS Guidewire Handle remain unchanged from the predicate devices have a longer shelf life and a different packaging system than the predicate device. Both the subject and predicate devices are sterilized by ethylene oxide gas but the sterilization method was changed from established category A to established category B.

The following technological differences apply to the IOPS Fiducial Tracking Pad and its predicate:

  • The subject device is smaller in size than the predicate device.

  • The subject device utilizes a different EM sensor than the predicate device.

  • The subject device has less quantity of EM sensors and fiducials than the predicate device.

  • The subject device contains a printed circuit board and a longer signal cable than the predicate device.

  • Some materials used in the construction of the subject device are different from the predicate device.

The following technological differences apply to the IOPS Guidewire Handle and its predicate:

  • The subject device is smaller in size than the predicate device.
  • The subject device does not have a metal shielding while the predicate does.
  • The subject device contains a printed circuit board and a longer signal cable than the predicate device.
  • Some materials used in the construction of the subject device are different from the predicate device.

Non-Clinical and/or Clinical Tests Summary & Conclusions 21 CFR 807.92(b)

Non-Clinical Testing:

The following tests were conducted on the IOPS Fiducial Tracking Pad and IOPS Guidewire Handle to establish equivalency to the predicate device in safety and effectiveness:

  • Dimensional Analysis
  • · Device Functionality and Essential Performance
  • Tensile
  • Radiopacity
  • · Accuracy Testing with IOPS per ASTM F2554
  • · IEC 60601 and Applied Part Testing
  • · Biocompatibility per ISO 10993
  • · Sterilization per ISO 14937 and TIR56
  • EO/ECH Residuals per ISO 10993-7
  • · Packaging Integrity per ISO 11607
  • Design Validation

Conclusion:

The subject devices have similar technological characteristics and the same indications/intended use as the predicate device. The differences in technological characteristics do not raise new or different questions of safety or effectiveness. The successful completion of non-clinical testing demonstrates that the IOPS Fiducial Tracking Pad and IOPS Guidewire Handle perform as intended and are substantially equivalent to the predicate.