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510(k) Data Aggregation

    K Number
    K240615
    Date Cleared
    2025-04-03

    (394 days)

    Product Code
    Regulation Number
    886.4390
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Beaver-Visitec International, Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Leos system is indicated for intraoperative photocoagulation of the ciliary processes in the treatment of glaucoma, proliferative retinopathies, retinal detachment, and for evaluation of the internal ocular structures in patients with dense opacifications of the anterior segment which do not allow a posterior view.

    Glaucoma - This instrument is indicated for the treatment of glaucoma in patients who have failed with conventional topical and systemic medications, or previous laser photocoagulation, or trabeculectomy and other filtering procedures, or cyclocryotherapy or other cyclodestructive procedures.

    Vitreoretinal Surgery - The endoscopically controlled endophotocoagulation that is possible with the ophthalmic laser endoscope is also useful for endophotocoagulation:

    • During vitreous surgery to produce chorioretinal scar around retinal breaks or retinotomy sites.
    • To perform intraoperative panretinal photocoagulation (PRP) in proliferative retinopathies.
    • To perform intraoperative retinal photocoagulation on a scleral buckle.
    • To perform intraoperative photocoagulation around focal neovascularization
    Device Description

    The Leos Laser and Endoscopic System is a next generation ophthalmic laser and endoscopy system used for the treatment of glaucoma, vitreoretinal diseases, and intraocular visualization. The system contains an 810 nm powered diode laser delivered by the stainless-steel endoscopic laser probe (trade name: VueProbe), which is placed into eye tissue to illuminate and visualize the target tissue and deliver laser energy under direct visualization. The console is a fully integrated portable device, containing a laser module assembly, viewing and control monitors, and a wireless footswitch for activating the laser. The larger passive monitor is for viewing the endoscopic video image and key treatment information, while the smaller touchscreen is used for parameters selection, rotation and viewing. The camera chip uses CMOS technology and is located at the tip of the probe. The LED light source is located within the plastic handpiece of the probe and illumination fibers carry the light to the tip. Additionally, the probe contains a laser fiber within its full length.

    AI/ML Overview

    Based on the provided FDA 510(k) Clearance Letter for the Leos Laser and Endoscopy System, here's an analysis of the acceptance criteria and study that proves the device meets them:

    It's important to note that the provided document is a 510(k) clearance letter, which focuses on substantial equivalence to predicate devices rather than proving specific performance against predefined acceptance criteria from a clinical trial. Therefore, explicit acceptance criteria are not detailed in this document in the way they would be for a clinical study report. Instead, the "acceptance" is based on demonstrating that the new device is as safe and effective as a legally marketed predicate device.

    The "study" in this context is primarily a non-clinical bench testing regimen designed to ensure the device performs within acceptable parameters and is comparable to predicate devices. Clinical studies were explicitly stated as not applicable and not required for this clearance.

    Here's the breakdown of the information requested, as extractable from the provided document:


    Acceptance Criteria and Device Performance Study (Based on 510(k) Substantial Equivalence)

    The "acceptance criteria" for a 510(k) clearance are primarily met by demonstrating substantial equivalence to predicate devices in terms of intended use, technological characteristics, and performance. The performance data presented are primarily from non-clinical bench testing.

    1. Table of Acceptance Criteria and Reported Device Performance

    Since specific quantitative clinical "acceptance criteria" are not given in a 510(k) clearance letter (which relies on equivalence, not novel performance claims), this table will reflect the performance characteristics demonstrating equivalence as described in the document. The "criteria" are implicitly that the performance is comparable or superior to the predicate and meets relevant safety standards.

    CharacteristicAcceptance Criteria (Implicitly: Comparable to Predicate & Meets Standards)Reported Device Performance (Leos System)
    Indications for UseSame as predicate devicesSame as predicate devices (minor wording changes, removal of performance claim)
    Treatment Laser Wavelength810 nm810 nm
    Treatment Laser TypeDouble hetero-structure, GaAs, Semiconductor Diode (Class IV)Double hetero-structure, GaAs, Semiconductor Diode (Class IV)
    Treatment Laser Power Range0 – 1.2 Watts (Predicate)0.05 – 1.2 Watts (Leos System) - Implicit acceptance: within safe and effective range, slight change noted.
    Laser Power Accuracy+/- 20%+/- 20%
    Aiming Beam Wavelength640 nm (red/orange)640 nm (red/orange)
    Aiming Beam Powerup to 1500uW (Predicate)up to 60 uW (Leos System) - Implicit acceptance: sufficient for aiming, lower power due to improved camera sensitivity.
    Image Resolution10,000 pixels (Predicate, limited by fiber count)40,000 pixels (Leos System) - Implicit acceptance: performance exceeds predicate, deemed equivalent or better.
    EMC and Electrical SafetyCompliant with IEC 60601-1 and IEC 60601-1-2Compliant with IEC 60601-1 and IEC 60601-1-2
    Laser Safety and Optical SafetyCompliant with IEC 60825-1, IEC 60601-2-22, ANSI Z80.36Compliant with IEC 60825-1, IEC 60601-2-22, ANSI Z80.36
    Software Level of Concern"Major" (V&V per FDA guidance & IEC 62304)"Major" (V&V completed successfully per FDA guidance & IEC 62304)
    BiocompatibilityCompliant with ISO 10993Confirmed compliant to FDA recognized standards per ISO 10993
    Sterilization & Shelf LifeConfirmed per FDA recognized standardsConfirmed per ASTM D4169-22, ISO 11135, ISO 10993-7, AAMI TIR 28, and ISO 11607-1

    2. Sample Size Used for the Test Set and Data Provenance

    • Sample Size for Test Set: Not explicitly stated as a number of patients or cases. The "test set" in this context primarily refers to bench testing of the device and its components. The document indicates:
      • Design Verification and Validation Testing: Confirms product meets requirements.
      • Software Verification and Validation: Completed successfully.
      • Biocompatibility, Sterilization, Shelf life testing.
    • Data Provenance: Not applicable in terms of patient data. The provenance is from internal lab bench testing and verification activities. The study is non-clinical.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts

    • Number of Experts: Not applicable. For non-clinical bench testing, "ground truth" is established by engineering specifications, regulatory standards (e.g., IEC, ISO, ASTM), and validated test methods. Human expert review of data is inherent but not quantified in this summary.
    • Qualifications of Experts: Not specified. This would typically be internal R&D, Quality, and Regulatory personnel with expertise in device design, testing, and regulatory compliance.

    4. Adjudication Method for the Test Set

    • Adjudication Method: Not applicable. This refers to the process of resolving discrepancies among human readers or raters in clinical studies. For non-clinical bench testing, "adjudication" is achieved through adherence to specifications, standards, and robust quality control processes.

    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

    • MRMC Study: No. The device is an Ophthalmic Laser and Endoscopy System, not an AI-powered diagnostic imaging device requiring a comparative effectiveness study with human readers.
    • Effect Size of Human Reader Improvement: Not applicable.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

    • Standalone Performance: Not applicable. This refers to AI algorithm performance. The Leos system is a direct medical intervention device (laser and endoscopy), not an AI diagnostic algorithm.

    7. The Type of Ground Truth Used

    • Type of Ground Truth: For the non-clinical tests, the "ground truth" is based on:
      • Engineering specifications: The device is designed to meet certain performance parameters (e.g., laser power, resolution).
      • Regulatory standards: Compliance with international and national standards (e.g., IEC 60601 series, ISO 10993 series, ANSI Z80.36, ASTM D4169-22, ISO 11135, ISO 11607-1, AAMI TIR 28).
      • Predicate device characteristics: The Leos system's performance is compared against the established characteristics of the predicate devices for substantial equivalence.

    8. The Sample Size for the Training Set

    • Sample Size for Training Set: Not applicable. This device is not an AI/ML algorithm that requires a "training set" of data.

    9. How the Ground Truth for the Training Set Was Established

    • How Ground Truth for Training Set Was Established: Not applicable.

    Summary of the "Study" Proving Acceptance:

    The "study" proving the device meets the (implicit) acceptance criteria for 510(k) clearance is a comprehensive non-clinical testing program that includes:

    • Bench Testing: Verifying electrical safety, electromagnetic compatibility (EMC), laser and optical safety, and general design performance against engineering specifications and relevant industry standards.
    • Software Verification and Validation: Ensuring the software operates correctly and safely, given its "Major" level of concern.
    • Biocompatibility Testing: Confirming the materials used in the probe are safe for contact with patients.
    • Sterilization and Shelf Life Testing: Validating the sterilization process and ensuring the product maintains sterility and functionality over its intended shelf life.

    The conclusion drawn from this testing is that the Leos Laser and Endoscopy System is substantially equivalent to its predicate devices, performing similarly (or better in some aspects like image resolution) while not raising any new safety or effectiveness concerns. This substantial equivalence is the basis for its FDA clearance.

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