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510(k) Data Aggregation

    K Number
    K983637
    Manufacturer
    Date Cleared
    1999-12-10

    (420 days)

    Product Code
    Regulation Number
    886.5925
    Reference & Predicate Devices
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Hydron ActiFresh 400 (lidofilcon A) Soft (Hydrophilic) Contact Lens is indicated for daily wear for the correction of refractive ametropia (myopia and hyperopia) in aphakic and notaphakic persons with non-diseased eyes that may exhibit refractive and/or corneal astigmatism up to 2.00 diopters.

    Eyecare practitioners may prescribe the lens for frequent replacement wear, with cleaning, disinfection and replacement. The lens may be disinfected using either a heat, chemical or hydrogen peroxide disinfection system.

    Device Description

    The ActiFresh 400 soft contact lens is a hemispherical shell manufactured of a high water content (73%), polymerised material of n-vinyl pyrrolidone (nVP) and methy methacrylate (MMA) and other components which yield the appearance of a lens which is designed to fit over the corneal surface of the eye. A UV filter has been incorporated into the lens material. The lens is visibility tinted with a minute amount of poly (2-hydroxyethyl methacrylate and Reactive Blue Dye #4 copolymer. The lens is designed with varying base curves which conform to the shape of the radius of the cornea and centre over the apex of the cornea to provide corrective refraction for functional conditions of the eye including myopia (nearsightedness) and hyperopia (farsightedness). The lens provides corrective power which is to correspond to the refractive power of the eye to which it is being treated. The lens is designed with a spherical lenticulated front surface and spherical bicurve back surface. The lens is manufactured by cast molding.

    AI/ML Overview

    The provided document describes the ActiFresh™ 400 Soft (hydrophilic) Contact Lens and its application for 510(k) clearance, asserting substantial equivalence to the predicate device, Hydron Omniflex SofBlue. The document does not describe acceptance criteria in the typical sense of a table with specific thresholds for performance metrics. Instead, it presents a comparative study against a predicate device and notes the absence of adverse events and comparability of clinical findings.

    Here's an analysis based on the information provided:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly state acceptance criteria in a table format with numerical thresholds for clinical outcomes. Instead, it relies on demonstrating substantial equivalence to a predicate device (Hydron Omniflex SofBlue) through a combination of non-clinical (physical, chemical, mechanical properties, toxicology, microbiology, stability) and clinical studies. The "acceptance criteria" are implicitly met if the ActiFresh 400 performs comparably to the predicate device and does not raise new questions of safety or effectiveness.

    Here's a summary of the comparative performance as presented, alongside the predicate device, which can be interpreted as demonstrating "meeting acceptance criteria" by being comparable:

    PropertyAcceptance Criteria (Implied: Comparable to Predicate)Reported Device Performance (ActiFresh 400)Predicate Device Performance (Omniflex SofBlue)
    Non-Clinical
    USANlidofilcon Alidofilcon Alidofilcon A
    MonomersnVP, MMAnVP, MMAnVP, MMA
    Manufacturing Process- (Different permitted if equivalent performance)Cast MoldingLathe-cut
    Diameter (mm)14.314.314.3
    Center Thickness (mm)0.120.120.12
    Base Curves (mm)- (Within specified range)8.4, 8.88.10 to 9.30
    Refractive IndexComparable$1.37 \pm 0.0003$$1.39 \pm 0.0007$
    Water Content (%)Comparable$73 \pm 0.3$$69 \pm 0.5$
    Oxygen Permeability (Dk)Comparable$28 \times 10^{-11}$$24 \pm 2.7 \times 10^{-11}$
    Light TransmittanceComparable$94.11\pm14.68%$$95.24\pm3.42%$
    Modulus (N/mm²)Comparable$0.31 \pm 0.04$$0.52 \pm 0.065$
    Tensile Strength (N/mm²)Comparable$0.48 \pm 0.14$$1.01\pm0.338$
    Elongation at Break (%)Comparable$126 \pm 27$$213\pm63$
    ToxicologyNon-toxic (according to ISO standards)All results provide reasonable assurance of non-toxicityNot explicitly stated but assumed for predicate
    MicrobiologySterilizable to SAL of 10⁻⁶Efficacy of sterilization checked, bioburden < 10 cfu/mlNot explicitly stated but assumed for predicate
    Lens Stability8-year shelf lifeDemonstrated up to 8 yearsNot explicitly stated but assumed for predicate
    Clinical
    Adverse ReactionsAbsence ofAbsentNot explicitly stated but implied low incident in predicate
    Clinically Significant Slit-lamp FindingsLow incidence, comparable to predicateLow incidence, one subject discontinued with positive findingsComparable to predicate
    Changes in Keratometry, Refraction, BCVAVery low incidenceVery low incidenceNot explicitly stated but assumed low incident in predicate
    Efficacy (Visual Acuity)High incidence of BCVA within one line of initialHigh incidenceNot explicitly stated but assumed for predicate
    Acceptability (Completion Rate, Discomfort)High completion rate, low incidence of discomfortHigh completion rate, low incidence of symptoms of discomfortComparable to predicate
    Average Daily Wear Time- (Relevant for daily wear claim)12.1-12.7 hours per dayNot explicitly stated but assumed for predicate

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

    • Sample Size (Clinical Study):
      • Enrolled: 39 subjects (78 eyes)
      • Dispensed lenses: 38 subjects (76 eyes)
      • Completed full 3 months: 33 subjects (66 eyes)
    • Data Provenance: The study was conducted by Hydron Ltd., a company based in Farnborough, UK ("Hawley Lane, Famborough, Hants, GU14 8EQ, U.K."). The report itself is a submission to the FDA for market clearance in the US, but the studies were likely conducted in the UK or a similar location accessible to the company. The document does not explicitly state the country of origin for the clinical data in detail, beyond the company's location.
    • Retrospective or Prospective: The clinical studies described (e.g., "Clinical Evaluation of Cast-Moulded ActiFresh 400 During a 3-month Period of Daily Wear," "High Power ActiFresh 400 Study," "Comparative Clinical Evaluation") appear to be prospective clinical trials. The description "3-month, 39 subject, open-label, uncontrolled, daily wear, dispensing study" confirms this.

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

    The document does not specify human experts establishing a "ground truth" for the test set in the sense of independent review of images or data. The "ground truth" is derived directly from clinical observations and measurements by the study investigators (presumably ophthalmologists, optometrists, or trained clinical staff) during the prospective clinical trials. The qualifications of these investigators are not provided.

    4. Adjudication Method for the Test Set

    No explicit adjudication method (e.g., 2+1, 3+1) is mentioned. The clinical study results are reported as direct observations and measurements from the study.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    • No, an MRMC comparative effectiveness study, as typically understood for AI-assisted diagnostic devices, was not done.
    • This device is a contact lens, not a diagnostic imaging AI. The "study" is a clinical trial evaluating the safety and efficacy of the contact lens itself, comparing its performance to a predicate device (Omniflex SofBlue) and demonstrating substantial equivalence, rather than comparing human readers with and without AI assistance. Therefore, no effect size of human readers improving with AI is reported.

    6. Standalone Performance

    • Yes, a standalone performance evaluation was conducted for the device. The clinical studies (LIDF-219, LIDF-220, DISP-203) evaluate the safety, efficacy, and acceptability of the ActiFresh 400 lens itself, independent of human interpretation nuances that would be present in an AI diagnostic device. However, "standalone" in this context refers to the device's inherent physical, mechanical, and clinical performance when worn by subjects, not an algorithm's performance.

    7. Type of Ground Truth Used

    The ground truth for the clinical studies was established through:

    • Expert Clinical Observation and Measurement: Slit-lamp findings (e.g., corneal staining, palpebral follicles), keratometry, refraction, best-corrected visual acuity (BCVA), and patient-reported symptoms (discomfort) were directly assessed by clinical investigators.
    • Patient Outcomes Data: Completion rates, discontinuation reasons, and daily wearing times.

    For non-clinical properties, the ground truth was via laboratory measurements using standard industry methods (e.g., Abbe refractometer for refractive index, gravimetric determination for water content, Fatt method for oxygen permeability, UV/visible spectrophotometer for light transmittance, tensile measurements for mechanical properties).

    8. Sample Size for the Training Set

    • Not applicable in the AI sense. This submission is for a physical medical device (contact lens), not an AI algorithm. Therefore, there is no "training set" for machine learning. The "training" in the context of device development would refer to manufacturing process optimization and material formulation.

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

    • Not applicable. As there is no AI algorithm, there is no ground truth established for an AI training set. The clinical and non-clinical data collected serve to validate the performance of the manufactured device.
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