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510(k) Data Aggregation

    K Number
    K142179
    Device Name
    D-KAT Z-YPE
    Manufacturer
    Date Cleared
    2014-09-17

    (40 days)

    Product Code
    Regulation Number
    886.1930
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    KEELER LTD.

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

    The Z-type Digital Keeler Applanation Tonometer is indicated for measuring intraocular pressure to aid in the screening and diagnosis of Glaucoma.

    Device Description

    The Z-type Digital Keeler Applanation Tonometer is a screening device used to measure intraocular pressure which is one of the factors considered in diagnosing glaucoma. The product is an active medical device, powered by a single AA battery. The operation principal is based on Goldmann applanation method.

    AI/ML Overview

    The provided text is a 510(k) summary for a modified medical device, the Z-type Digital Keeler Applanation Tonometer. The primary focus of this document is to demonstrate "substantial equivalence" to a predicate device, rather than to establish new performance criteria for a novel device. As such, it relies heavily on the fact that existing performance characteristics (like measurement deviation, range, and technique) remain unchanged.

    Here's an analysis of the acceptance criteria and study information available in the document:

    1. A table of acceptance criteria and the reported device performance

    Since this is a submission for a modified device claiming substantial equivalence, the "acceptance criteria" are essentially the performance characteristics of the predicate device, which the modified device is expected to match. The document explicitly states "No change" for most performance-related characteristics when comparing the modified device to the predicate device.

    Characteristic FeatureAcceptance Criteria (Predicate Device Performance)Reported Device Performance (Modified Device)Notes
    TypeManual contact TonometerManual contact TonometerNo change.
    Indicated UseMeasuring intraocular pressure to aid in the screening and diagnosis of Glaucoma.Measuring intraocular pressure to aid in the screening and diagnosis of Glaucoma.No change.
    Intended UseIntraocular Pressure (IOP) measurementIntraocular Pressure (IOP) measurementNo change.
    Target PopulationPatients with high IOPPatients with high IOPNo change.
    Anatomical SitesCorneaCorneaNo change.
    Where UsedIn a professional healthcare facility environmentIn a professional healthcare facility environmentNo change.
    Units of MeasuremmHg - millimeter of mercurymmHg - millimeter of mercuryNo change.
    DisplayNumerical display - Direct reading of IOP in mmHg from displayNumerical display - Direct reading of IOP in mmHg from displayNo change.
    Measurement Range5-65mmHg5-65mmHgNo change.
    Measurement TechniqueApplanationApplanationNo change.
    Measurement MethodGoldmann method - the measuring of pressure to maintain a uniform applanation of the surface of the eye.Goldmann method - the measuring of pressure to maintain a uniform applanation of the surface of the eye.No change.
    Measurement Deviation0.49 mN or 1.5% of measurement value, whichever is the greater.0.49 mN or 1.5% of measurement value, whichever is the greater.No change.
    Power RequirementsAA Battery to power digital displayAA Battery to power digital displayNo change.
    SoftwareContains softwareContains softwareNo change.
    Maintenance and CalibrationMaintenance and calibration required, factory set. Calibration arm assembly supplied with each device.Maintenance and calibration required, factory set. Calibration arm assembly supplied with each device.No change.
    MaterialsTonometer body - anodized aluminium; Tonometer prism - Medical grade acrylic.Tonometer body - anodized aluminium; Tonometer prism - Medical grade acrylic.No change.
    BiocompatibilityAll materials are tested for biocompatibility.All materials are tested for biocompatibility.No change.
    Design / MountingMounted on top illuminating (Haag-Streit-style) Slit lamp, manual dial. (Predicate device K093445)Mounted on bottom-illuminating (Zeiss-style) Slit lamp, manual dial.Change in shape of the device to allow mounting on bottom-illuminating slit lamp (Zeiss-type illumination system). The change does not affect the intended use, safety and effectiveness or the fundamental scientific technology.
    Mounting method on slit lampFixed (R-Type) and Take-away (T-Type)FixedNo change (referring to the modified device being fixed, which is a specific characteristic of the Z-type mentioned in the product description, not necessarily a change from the predicate which may have had both fixed and take-away options). The comparison table is a bit ambiguous here as it lists "Fixed (R-Type) and Take-away (T-Type)" for the predicate and "Fixed" for the modified, but then says "No change." It seems to imply that the new model is just one type of mounting.

    2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    The document mentions "Verification tests have been carried out in accordance to the FDA guidelines 'Tonometers - Premarket Notification [510(k)] Submissions'." However, it does not specify the sample size for any clinical or performance test set, nor does it provide details about data provenance (country of origin, retrospective/prospective). The tests mentioned are primarily engineering verification tests (electrical safety, EMC, software).

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

    No information is provided regarding the number or qualifications of experts used to establish ground truth for any clinical test set. Given it's a 510(k) for a modification and claims substantial equivalence based on engineering verification, explicit clinical ground truth establishment with experts is not detailed.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    No information is provided regarding an adjudication method.

    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 device is not an AI-assisted diagnostic tool. It is a physical tonometer. Therefore, an MRMC comparative effectiveness study involving human readers and AI assistance is not applicable and was not performed.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    The device is a manual contact tonometer that requires a human operator for its use. It is not an algorithm-only standalone device.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    For the mechanical and electrical verification mentioned, the ground truth would be based on established engineering standards (e.g., ISO 8612:2009 for tonometer calibration, BS EN 60601-1 for electrical safety, BS EN 60601-1-2 for electromagnetic compatibility). For the primary function of measuring IOP, the gold standard is stated as the "Goldmann tonometer." The document indicates that the device's operating principle is based on the Goldmann method, and its measurement deviation aligns with previous models.

    8. The sample size for the training set

    This is not an AI/machine learning device, so there is no concept of a "training set" in the traditional sense. The device's "training" or calibration is factory-based using known pressures and a calibration arm.

    9. How the ground truth for the training set was established

    For the calibration process, the ground truth is established by "known pressures covering the measurement range applied to the measurement arm using a calibration arm verified using the calibration procedure outlined in the Tonometer standard ISO 8612:2009." This means the ground truth for the device's accuracy is derived from international standards for tonometer calibration.

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    K Number
    K131787
    Manufacturer
    Date Cleared
    2013-12-23

    (188 days)

    Product Code
    Regulation Number
    886.4170
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    KEELER LTD.

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

    The Keeler Cryomatic System and probes are for use in ophthalmic surgery such as cryopexy for retinal detachment, cyclo destructive procedures in refractory glaucoma, extraction of fragments within the vitreous cavity, cataract extraction, cryo destruction of lash follicles for trichiasis and treatment of retinopathy of prematurity (ROP).

    Device Description

    The Cryomatic MKII console is a self-contained system. The console consists of a rigid PU enclosure, housing the principle subsystems, switch mode power supply, controller PCB and pneumatic control module. On the front of the console is an LCD screen and membrane key panel. The console provides the connection point for the range of probe (reusable and disposable), footswitch, mains electricity, gas supply and scavenging system.

    There is a variety of Keeler Re-usable Cryomatic Probes whose stainless tips are shaped depending on surgical application. The plastic handle is permanently connected to flexible pressure hose and integral connector, which connects to Cryomatic MKII Console.

    The Keeler Disposable Cryo Probe comprises a stainless steel stem with a metal handle connected to a 2m long bi-lumen high-pressure plastic hose contained within a protective outer tube and terminated with a customdesigned plastic connector for insertion into the Cryomatic MKII console.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and study information for the Keeler Cryomatic MKII System, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Evaluated Aspects)Reported Device Performance
    a) Probe external temperature and repeatabilityConfirmed to be comparable with the predicate device.
    b) Iceball growth capabilityConfirmed to be comparable with the predicate device.
    c) Defrost performanceConfirmed to be comparable with the predicate device.
    d) Tractive powerConfirmed to be comparable with the predicate device.
    Electrical Safety (IEC 60601-1)In compliance with the standard.
    Electromagnetic Compatibility (IEC 60601-1-2)In compliance with the standard.
    Sterilization of Re-usable ProbesValidation of the steam sterilization process was carried out to demonstrate that the sterilization parameters outlined in the instruction for use are sufficient to sterilize the modified probes. The modified device's sterilization methods (Pre-vacuum (porous load) 134 - 137 °C, 3 minutes and 18 minutes) were validated and deemed acceptable, despite differing from the predicate's gravity method and having only one method instead of two for some parameters.
    Intended UseUnchanged from the predicate device and the original 510(k) clearances (K062412 & K112093). The device maintains its indications for use in ophthalmic surgery (cryopexy for retinal detachment, cyclodestructive procedures, extraction of fragments, cataract extraction, cryodestruction of lash follicles, and treatment of retinopathy of prematurity). This was confirmed through a comparison of IFUs and overall assessment that the modifications do not affect safety or effectiveness.
    Coupling MechanismThe new quick-release coupling mechanism accepts both Keeler Cryomatic disposable and re-useable probes without an adaptor. This was observed as a design modification that did not affect safety or effectiveness.

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

    The document does not explicitly state specific sample sizes for each verification test. It refers to "verification tests" and "all tests," implying a comprehensive evaluation.

    • Data Provenance: The document does not specify the country of origin of the data or whether the studies were retrospective or prospective. Given that Keeler Instruments Inc. is based in Broomall, PA, USA, and the 510(k) is submitted to the FDA, it is highly probable that the testing was conducted in a manner consistent with US regulatory requirements for medical devices. The nature of the modifications (simplification of a coupling mechanism) suggests bench testing and internal validation rather than clinical trials with patient data.

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

    The document does not mention the use of experts to establish "ground truth" in the context of diagnostic accuracy. This submission is for a modification to an existing surgical system, not a diagnostic imaging device that requires expert interpretation. The "ground truth" for this device's performance would be established through engineering and performance testing against predefined specifications and recognized standards.

    4. Adjudication Method for the Test Set

    Not applicable. As described in point 3, this is a modification to a surgical device, not a diagnostic AI system requiring adjudication of expert interpretations.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was Done

    No. An MRMC comparative effectiveness study is not mentioned and would not be relevant for this type of device modification. This device is a surgical instrument, not an assistive technology for diagnostic interpretation.

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

    Not explicitly applicable in the context of a "standalone algorithm." The device itself functions as a "standalone" surgical tool in that it performs its intended function without requiring human input beyond operating it. The "verification tests" described are essentially standalone performance evaluations of the modified hardware and associated software.

    7. The Type of Ground Truth Used

    The "ground truth" for this device modification is based on:

    • Engineering Specifications: The device's performance (probe temperature, iceball growth, defrost, tractive power) was measured against established specifications for the predicate device and the new design.
    • Safety Standards: Compliance with recognized international standards (IEC 60601-1 for electrical safety, IEC 60601-1-2 for electromagnetic compatibility).
    • Sterilization Validation: Specific protocols and measurements to ensure the re-usable probes could be adequately sterilized according to defined parameters.

    8. The Sample Size for the Training Set

    Not applicable. This device is not an AI/ML algorithm that requires a "training set" in the conventional sense. The "training" for this device would be its design, engineering tolerances, and manufacturing processes.

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

    Not applicable for the same reasons as point 8.

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    K Number
    K131589
    Manufacturer
    Date Cleared
    2013-06-27

    (27 days)

    Product Code
    Regulation Number
    886.1850
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    KEELER LTD.

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

    The Keeler Slit Lamp is an AC-powered Slit lamp biomicroscope and is intended for use in eye examination of the anterior eye segment, from the cornea epithelium to the posterior capsule. It is used to aid in the diagnosis of diseases or trauma which affects the structural properties of the anterior eye segment

    This device is intended to be used only by suitably trained and authorised healthcare professionals.

    Device Description

    An AC-powered slit lamp biomicroscope is an AC-powered device that is a microscope intended for use in eye examination that projects into the patient's eye through a control diaphragm a thin, intense beam of light.

    This Keeler Slit Lamp has an XYZ translation base that is either mounted onto a custom table top supplied by Keeler or can be mounted on a third parties table top (refraction unit) by suitably trained technicians.

    Fitted to the XYZ base is the illumination and observation system; fitted to the table top is the chinrest assembly with fixation target.

    The illumination system rotates around its mounting axis and has a number of filters and graticules allowing the user to control precisely the characteristics of the examination light. The magnification body has a magnification change systems and eyepieces adjustable for the user's individual pupillary distance and distance correction.

    The patient is seated in front of the slit lamp with his/her chin in the chin rest and forehead against the forehead rest. The chin rest can be adjusted in height to align the eyes of the patient with the optics/light beam.

    With the control lever the instrument can be moved back and forward until the slit appears in focus on the cornea. The image can be observed through the microscope. The base unit has a rheostat to control the illumination level.

    Various magnifications can be selected on the microscope. For different observations the slit width can be changed, the slit can be tilted horizontally, and the angle between the illumination unit and the microscope can also be varied horizontally.

    AI/ML Overview

    The Keeler Slit Lamp - H Series is an AC-powered slit lamp biomicroscope intended for use in eye examination of the anterior eye segment, from the cornea epithelium to the posterior capsule. It is used to aid in the diagnosis of diseases or trauma affecting the structural properties of the anterior eye segment.

    Here's an analysis of the acceptance criteria and the study proving the device meets them:

    1. Table of Acceptance Criteria and Reported Device Performance

    The provided document does not explicitly state "acceptance criteria" in a quantitative sense for performance metrics like sensitivity, specificity, or accuracy, as would be common for AI/diagnostic devices. Instead, the focus is on demonstrating substantial equivalence to a predicate device (Haag-Streit Slit Lamp BQ 900, K100202) through comparison of technical specifications and compliance with recognized safety and performance standards.

    The "acceptance criteria" can be inferred to be compliance with relevant safety and performance standards and demonstrating that any differences from the predicate device do not affect safety or effectiveness.

    FeaturePredicate Device (Haag-Streit BQ 900)Keeler Slit Lamp H-SeriesAcceptance Criteria (Implicit)Reported Performance (Keeler H-Series)
    Intended Use"An AC-powered slit lamp biomicroscope is an AC-powered device...""An AC-powered slit lamp biomicroscope is an AC-powered device..."Same intended use as predicate.Same.
    Operating PrincipleNot explicitly detailed, but implied by device type.Not explicitly detailed, but implied by device type.Same operating principle as predicate.Same.
    Basic Optical DesignNot explicitly detailed, but implied by device type.Not explicitly detailed, but implied by device type.Same basic optical design as predicate.Same.
    Magnification6.3x / 10x / 16x / 25x / 40xx6, x10, x16, x25 & x40Differences are not significant and do not affect safety or effectiveness.Differences noted (6x vs 6.3x, etc.), but deemed not significant and not affecting safety or effectiveness.
    Objective lens working distance105mm107mmDifferences are not significant and do not affect safety or effectiveness.Differences noted, but deemed not significant and not affecting safety or effectiveness.
    Field of view32.0 @ 6.3x / 20.0 @ 10x / 12.7@ 16x / 8.0@ 25x / 5.1@ 40x34.0 @ 6x / 22.0 @ 10x / 14 @ 16x / 8.5 @ 25x / 5.5 @ 40xDifferences are not significant and do not affect safety or effectiveness.Differences noted, but deemed not significant and not affecting safety or effectiveness.
    Range of PD adjustment52 - 78 mm49.0 to 77mmRange conforms to requirement of ISO 10939 and does not affect safety or effectiveness.Differences noted, but conformance to ISO 10939 and no affect on safety/effectiveness is reported.
    Eyepiece dioptric adjustment range+8 to -8 diopters+8 to -8 dioptersSame as predicate.Same.
    Slit Length1-8 mm continuous12mm (1mm - 12mm continuously variable)Difference not significant; sufficient for clinical use (e.g., iris diameter), meets ISO 10939, does not affect safety/effectiveness.Differences noted, but deemed not significant. 12mm is more than sufficient for clinical use (iris diameter max 6mm), meets ISO 10939, and does not affect safety or effectiveness.
    Slit Width0 - 8 mm continuous0-12mm continuously variableDifference not significant; not critical as long as ≥ 8mm, meets ISO 10939, does not affect safety/effectiveness.Differences noted, but deemed not significant. Maximum slit width not critical as long as ≥ 8mm, with narrow slits often needed for examination. Meets ISO 10939, and does not affect safety or effectiveness.
    Light source7.5V, 38 W Halogen Lamp, 24VDC 1A LED6V 20W Halogen lamp and LEDAll light sources conform to ISO 15004-2 (Photo-toxicity) and do not affect safety or effectiveness.Differences noted, but all light sources conform to ISO 15004-2 and there is no affect on safety or effectiveness.
    Duration of illuminationMaximum examination times according to ISO 15004-2 and ISO 10939Maximum examination times according to ISO 15004-2 and ISO 10939Same as predicate, conforming to ISO 15004-2 and ISO 10939.Same.
    Light intensity selectionThree selections: Full, 1/4 and 1/16 via neutral density filter.0-100% continuous potentiometerAllows the user to select the necessary light intensity to perform the relevant task, difference not significant.Differences noted, but deemed not significant as both allow user to select necessary light intensity for the task.
    FiltersBlue, red-free (green), grey (10%); UV and heat absorption filters permanently mounted.Clear; red-free; neutral density; diffuser; blue; IR heat absorbing filter permanently installed.Difference not significant and does not affect safety or effectiveness; both have permanently installed heat absorbing filter.Differences noted, but deemed not significant and not affecting safety or effectiveness. Both devices have a permanently installed heat absorbing filter.
    Electrical RatingsSame as predicate.Same for input voltage, power output, and output voltage.
    Compliance with Safety StandardsIEC60601-1-2, IEC60601-1, ISO 15004-2IEC 60601-1-2, IEC 60601-1, ISO15004-2Device must be in compliance with these FDA recognized standards.In compliance with all listed standards (BS EN ISO 15004-2, BS EN ISO 10939 for radiation hazards, IEC 60601-1 for electrical safety, IEC 60601-1-2 for electromagnetic compatibility).

    The study that proves the device meets the acceptance criteria is described as the "Summary of Performance, EMC and Safety Testing."

    2. Sample size used for the test set and the data provenance

    The document does not describe a test set involving patient data or clinical samples for performance evaluation in the context of diagnostic accuracy (e.g., retrospective or prospective studies with a specific sample size). Since this is a hardware device (slit lamp biomicroscope), testing primarily focuses on engineering performance, electrical safety, EMC, and radiation safety.

    Therefore, there is no mention of:

    • Sample size for a test set.
    • Data provenance (e.g., country of origin of the data, retrospective or prospective).

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    Not applicable. This device is a viewing instrument, and its "performance" is evaluated against technical specifications and safety standards, not against clinical ground truth established by experts.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Not applicable. No clinical test set or ground truth adjudication process is described for this type of device.

    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

    Not applicable. This device is an ophthalmic instrument, not an AI-powered diagnostic tool. No MRMC study was conducted.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    Not applicable. This is not an algorithm-only device.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    The "ground truth" for this device's acceptance is its compliance with internationally recognized consensus standards for medical electrical equipment and ophthalmic instruments (IEC 60601-1, IEC 60601-1-2, ISO 15004-2, ISO 10939). The testing involved objective measurements against these standards, rather than clinical ground truth like pathology or expert consensus on disease diagnosis.

    8. The sample size for the training set

    Not applicable. This is a hardware device; there is no training set in the context of machine learning or AI.

    9. How the ground truth for the training set was established

    Not applicable. As there is no training set mentioned, no ground truth needed to be established for it.

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    K Number
    K093445
    Manufacturer
    Date Cleared
    2010-01-19

    (90 days)

    Product Code
    Regulation Number
    886.1930
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    KEELER LTD.

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

    The Keeler Applanation Tonometer is indicated for measuring intraocular pressure to aid in the screening and diagnosis of Glaucoma.

    Device Description

    The Keeler Applanation Tonometer is a screening device used to measure intraocular pressure which is one of the factors considered in diagnosing glaucoma. The product is a non-active medical device and is completely mechanical, therefore without electrical components. The operation principal is based on Goldmann applanation method. The product is installed on a special support on the slit lamp and is used in conjunction with commercially available slit lamps.

    AI/ML Overview

    Let's break down the information provided about the Keeler Applanation Tonometer (KAT) and its performance study.

    Based on the provided K093445 submission, the Keeler Applanation Tonometer is a manual contact tonometer and its submission is based on substantial equivalence to predicate devices, rather than a standalone clinical study with defined acceptance criteria and specific performance metrics in the way one might see for an AI/software device. For mechanical devices like this, the 'acceptance criteria' are typically met by demonstrating that the device functions identically or equivalently to legally marketed devices, and passes relevant engineering standards.

    Here's an analysis based on the provided document:


    Acceptance Criteria and Device Performance

    The concept of "acceptance criteria" for a diagnostic accuracy as seen in AI or complex diagnostic devices isn't directly applied here. Instead, the "acceptance criteria" are implied by substantial equivalence to predicate devices and adherence to relevant standards. The performance is assessed by comparison.

    Criterion TypeAcceptance Criteria (Implied)Reported Device Performance (Keeler Applanation Tonometer)
    Technological Equivalence (Bench Testing)Device must possess comparable technological characteristics (type, indication, design, prism material, measurement range, measurement technique, measurement method, calibration, intended use) to predicate devices. Device must meet nominal requirements of Tonometer Standard BSENISO 8612:2001. The KAT has identical technological characteristics to both predicate devices (CSO F900/A900 and Haag-Streit AT 900) across all listed criteria. Bench testing verified KAT units against the nominal requirements of Tonometer Standard BSENISO 8612:2001. Comparative bench study showed KAT and predicate devices were "substantially equivalent" when subjected to the same nominal standard requirements.
    Clinical Equivalence (Field Trial)Device performance in a clinical setting should be comparable to predicate devices. The field test, conducted by an ophthalmic professional, confirmed that the findings with the KAT were "comparable" to its predicate device.
    Safety and EffectivenessDevice is as safe and effective as predicate devices.Based on all performance testing (bench and field), the Keeler Applanation Tonometer is "judged to be as safe, as effective and performs as well as the predicate devices."

    Study Information & Data Provenance

    1. Sample size used for the test set and the data provenance:

      • Test Set Sample Size: Not explicitly stated as a numerical sample size for patients or measurements in the provided document. The "bench testing" would involve a sample of the manufactured devices, and the "field trial" would involve some number of patients/eyes tested by an ophthalmic professional. However, specific numbers are not given.
      • Data Provenance: The bench testing and field trial were likely conducted by the manufacturer or on their behalf. The country of origin of the data is implied to be within the UK (where the manufacturer is located), but this is not explicitly stated for the studies themselves. The studies appear to be prospective in nature, as they were conducted to test the performance of the new device.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • Number of Experts: Not explicitly stated. The field test was conducted by "an ophthalmic professional." This implies at least one expert, but doesn't specify if it was a single individual or a group, nor are their specific qualifications (e.g., years of experience, sub-specialty) detailed.
      • Qualifications of Experts: Described as "ophthalmic professional." No further detail (e.g., ophthalmologist, optometrist, specific experience) is provided.
    3. Adjudication method for the test set:

      • Not applicable/Not explicitly stated in the context of this submission. For substantial equivalence of a general-purpose mechanical device, an adjudication method for ground truth is typically not required as it would be for a complex diagnostic algorithm. The comparison is against established, legally marketed devices.
    4. 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:

      • No, an MRMC comparative effectiveness study was not done. This type of study is specifically relevant to evaluating AI (artificial intelligence) systems or other diagnostic aids where human interpretation is assisted. The Keeler Applanation Tonometer is a purely mechanical device, not an AI system. Therefore, this question is not applicable.
    5. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:

      • No. This question is also not applicable as the Keeler Applanation Tonometer is a manual, mechanical device and does not involve an algorithm or AI. Its operation inherently requires a human operator ("manual contact tonometer").
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

      • For the bench testing, the "ground truth" was adherence to the Tonometer Standard BSENISO 8612:2001 and direct comparison of measurements against the predicate devices.
      • For the field trial, the "ground truth" was likely the intraocular pressure (IOP) readings obtained by the "ophthalmic professional" using both the Keeler Applanation Tonometer and the predicate device(s) on actual patients, with comparability being the key outcome. It's not based on pathology or outcomes data in the sense of disease progression, but on the agreement of the measurement value itself.
    7. The sample size for the training set:

      • Not applicable. The Keeler Applanation Tonometer is a mechanical device, not a machine learning model. Therefore, it does not have a "training set."
    8. How the ground truth for the training set was established:

      • Not applicable. As there is no training set, there is no ground truth for a training set.

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