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510(k) Data Aggregation

    K Number
    K243600
    Date Cleared
    2025-08-14

    (266 days)

    Product Code
    Regulation Number
    886.1120
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    3nethra neo HD FA:

    3nethra neo HD FA is used as a wide-field retinal imaging digital camera for photo documentation of ocular diseases that manifest in infants. The device acquires only images and does not provide any pathological analysis or diagnosis for treatment.

    3nethra neo HD:

    3nethra neo HD is used as a wide-field retinal imaging digital camera for photo documentation of ocular diseases that manifest in infants. The device acquires only images and does not provide any pathological analysis or diagnosis for treatment.

    Device Description

    The 3nethra neo-HD FA is a handheld wide-angle fundus imaging system for neonatal screening. It is designed to acquire, display, store and transmit images of the posterior and anterior surfaces of human eye. The images assist clinicians in the evaluation and documentation of visual health in retinopathy of prematurity (ROP) and other problems. It operates in contact with the cornea of the eye under test. 3nethra neo HD FA uses continuous white light for operation and hence need pupil dilation. It also equipped with blue light source and green filters for fundus fluorescein angiography (FFA).

    The 3nethra neo-HD is a handheld wide-angle fundus imaging system for neonatal screening. It is designed to acquire, display, store and transmit images of the posterior and anterior surfaces of human eye. The images assist clinicians in the evaluation and documentation of visual health in retinopathy of prematurity (ROP) and other problems. It operates in contact with the cornea of the eye under test. 3nethra neo HD uses continuous white light for operation and hence need pupil dilation. The 3nethra neo HD is a lower end variant of the 3nethra neo HD FA without the Fluorescein Angiography feature.

    AI/ML Overview

    The provided 510(k) clearance letter and summary describe the acceptance criteria and a study to prove the device's performance. Here's a breakdown of the information requested:

    The device in question, 3nethra neo HD FA and 3nethra neo HD, are ophthalmic cameras intended for wide-field retinal imaging and photo documentation of ocular diseases in infants. They acquire images only and do not provide pathological analysis or diagnosis.


    Acceptance Criteria and Reported Device Performance

    The core acceptance criterion for this device, based on the provided document, is substantial equivalence to existing predicate devices, particularly in terms of image quality for the FA functionality. The study focuses on demonstrating that the fluorescent angiography (FA) images produced by the subject device are comparable in quality to those produced by a predicate device.

    Acceptance CriterionReported Device Performance
    Safety and EffectivenessDemonstrated through compliance with electrical safety (IEC 60601-1, IEC 60601-1-2) and light safety standards (ISO 15004-2, ANSI Z80.36) and comparable image quality to a cleared reference device for its intended use.
    Image Quality (for FA images, specifically for 3nethra neo HD FA)All study images produced by the 3nethra neo HD FA were found to be of comparable quality to those produced by the RetCam 3 reference device (K182263).

    Study Details

    The study described is a clinical observational study focused on image quality comparison.

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

      • The document states "of all study images," implying that all images collected within the clinical observational study were used for the comparison. However, the exact numerical sample size (number of images or patients) for the test set is not explicitly stated in the provided text.
      • Data Provenance: The document does not explicitly state the country of origin of the data or whether the study was retrospective or prospective. It is described as a "clinical observational study," which typically implies prospective data collection, but this is not confirmed.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • The document does not explicitly state the number of experts used or their specific qualifications (e.g., number of years of experience, specific certifications). It simply refers to the primary objective being to demonstrate comparability to a cleared reference device. The process of expert evaluation for "comparable quality" is not detailed.
    3. Adjudication method (e.g., 2+1, 3+1, none) for the test set:

      • The document does not describe any specific adjudication method for evaluating image quality. It states that "all study images were found to be of comparable quality," but the process by which this finding was made (e.g., consensus, majority vote) is not provided.
    4. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, and if so, what was the effect size of how much human readers improve with AI vs. without AI assistance:

      • No, a multi-reader multi-case (MRMC) comparative effectiveness study was not performed or described in the provided text.
      • The device is described as an "Ophthalmic Camera" that "acquires only images and does not provide any pathological analysis or diagnosis for treatment." Therefore, there is no AI assistance component for human readers to be compared against. The study focused on assessing the image quality of the camera itself, not the impact of AI on human interpretation.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • This question is not applicable as the device is an imaging camera that acquires images for human interpretation, not an algorithm providing a standalone diagnostic or analytical output. The study assessed the quality of the images produced by the device.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

      • The ground truth for the "comparable image quality" assessment appears to be based on a clinical observational study comparing the subject device's images to those from a predicate device (RetCam 3). The implicit ground truth is the accepted, established quality of images from the predicate device.
      • The document does not mention pathology or outcomes data as a direct ground truth for image quality assessment in this context. The study aimed to show that the images themselves were of sufficient quality for their intended purpose (photo documentation) by comparing them to a cleared device.
    7. The sample size for the training set:

      • The document does not mention a training set. This is because the device is an imaging camera, not a machine learning or AI algorithm that requires a training set.
    8. How the ground truth for the training set was established:

      • This question is not applicable as there is no mention of a training set for this device.
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    K Number
    K183059
    Device Name
    3nethra neo
    Date Cleared
    2018-12-21

    (49 days)

    Product Code
    Regulation Number
    886.1120
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    3nethra neo is used as a wide field retinal imaging digital camera for photo documentation of ocular diseases that manifest in infants.

    Device Description

    The 3nethra neo is a compact, portable and easy to use, mydriatic, digital wide field imaging camera used for the photo documentation of ocular diseases that manifest in infant eyes. 3nethra neo needs to be connected to a computer for running the application software, to store, view, retrieve, and export the digital ophthalmic images. The 3nethra neo has a hand-held probe unit, a control box and a foot-pedal control unit. Warm white LED with intensity control via foot-pedal is used to provide illumination to the eye in order to capture images.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and the study proving the device meets those criteria, based on the provided text:

    Acceptance Criteria and Device Performance

    The document doesn't explicitly state "acceptance criteria" in a table format with specific quantitative targets that the device must meet to be cleared. Instead, it details performance testing results, and the overall conclusion is that these results "supportive of substantial equivalence to the predicate devices." The clinical performance data also aims to demonstrate equivalence in diagnostic capability.

    However, we can infer some criteria from the performance testing section. The device's performance is presented in comparison to established standards and its predicate devices.

    Acceptance Criteria (Inferred)Reported Device Performance
    Electrical SafetyComplies with IEC 60601-1
    Electromagnetic Compatibility (EMC)Complies with IEC 60601-1-2
    Ophthalmic Instrument StandardsComplies with ISO 15004-2 and ANSI Z80.36 (Group 1 instrument requirements)
    Central Resolving PowerGreater than 60 lp/mm (verified using an artificial eye and clinical setups, and for the full FOV region)
    Biocompatibility (Skin Sensitization)Complies with ISO 10993-10:2010
    Biocompatibility (Intracutaneous Reactivity)Complies with ISO 10993-10:2010
    Biocompatibility (Cytotoxicity)Complies with ISO 10993-5:2009
    Clinical Sensitivity for detecting any stage ROP97.4% (Observer 1) and 99.3% (Observer 2)
    Clinical Specificity for detecting any stage ROP81.1% (Observer 1) and 75.6% (Observer 2)
    Kappa for clinical decision and agreement0.60 and 79% (Observer 1); 0.90 and 95% (Observer 2)
    Inter-rater agreeability for staging0.8 and 73.4% agreement
    Identification of Zone 3 ROPAll (n=27) Zone 3 diseases correctly identified by both observers

    Study Details

    The document describes a clinical study to evaluate the performance of the 3nethra neo device.

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

    • Sample Size: 128 premature Asian Indian Infants (144 sessions were analyzed).
    • Data Provenance: From 35 neonatal centers in India (implied by "premature Asian Indian Infants"). The study was prospective in nature, as infants were screened using both devices "alternately with either device first."

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

    • Number of Experts: Two Retinopathy of Prematurity (ROP) specialists.
    • Qualifications: "Two ROP specialists masked to the origin of the randomly presented images." No further specific qualifications (e.g., years of experience) are provided in this document excerpt.

    4. Adjudication method for the test set:

    • The two ROP specialists "reported the presence of retinal immaturity, maturity or on the stage of Retinopathy of Prematurity (ROP) and zone of involvement, for each eye, in each session and reached a 'decision' on whether to treat, follow-up or discharge the baby based on the findings in both eyes." This suggests a consensus-based adjudication, but the exact method (e.g., 2+1, discussions, independent review) is not explicitly detailed beyond "reached a 'decision'". The "kappa for clinical decision and agreement" also indicates an assessment of their agreement.

    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 was not an MRMC comparative effectiveness study involving AI assistance for human readers. The study compared the imaging new device (3nethra neo) to a predicate device (RetCam), both used by human readers (ROP specialists). The document does not mention any AI component or AI assistance for readers in the clinical study.

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

    • No, a standalone algorithm performance study was not described. The clinical study evaluates the 3nethra neo imaging device when used by human ROP specialists.

    7. The type of ground truth used:

    • The ground truth was established by expert consensus/adjudication of two ROP specialists. They made diagnoses and clinical decisions based on images from both devices. (Note: The study compares the imaging device's performance to a predicate, with expert readers acting as the "interpreters" of the images to determine the clinical ground truth within the study context).

    8. The sample size for the training set:

    • The document does not provide information about a training set or its sample size. This is expected as the device being described is an imaging camera, not a standalone AI diagnostic tool.

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

    • As no training set is mentioned for the 3nethra neo in this document, this information is not applicable/provided.
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