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510(k) Data Aggregation

    K Number
    K141917
    Date Cleared
    2014-10-17

    (94 days)

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

    The UNICON (etafilcon A) Soft (hydrophilic) Contact Lens with UV Blocker for Daily Wear is indicated for the correction of ametropia (myopia and hyperopia) in aphakic persons with non-diseased eye who may have 1.00 D or less astigmatism. The UNICON (etafilcon A) Soft (hydrophilic) Contact Lens with UV Blocker for Daily Wear are single disposable wear and are to be discarded after each removal. UNICON (etaffilcon A) Soft (hydrophilic) Contact Lens with UV Blocker for Daily Wear helps protect against transmission of harmful UV radiation to the cornea and into the eye.

    Device Description

    UNICON (Etafilcon A) Soft (Hydrophilic) Contact Lens with UV Blocker for Daily Wear is available as aspherical lenses manufactured by case-molding method. The model illuminated with high water content (58 %). The hydrogel lens' material is a random copolymer composed of 2-hydroxyethyl methacrylate (HEMA) and methacrylic acid (MAA), which was cross-linked with Trimethylolpropane trimethacrylate (TMPTMA) and Ethylene Glycol Dimethacrylate (EGDMA) via UV photo-polymerization. The UNICON (Etafilcon A) Soft (Hydrophilic) Contact Lens with UV Blocker for Daily Wear with visible tint is light tinted blue using Blue 15:3 to make the lens more visible for handling. The lenses also contain a UV absorber { { 2-[ 3-( 2 -( 2 -( 2 -( ) - 4 - h dr ox y p hen y l which is included during the manufacturing process as a monomer to block UV radiation. The average transmittance characteristics are less than 5% in the UVB range of 280 to 315 nm and less than 30% in the UVA range of 316 to 380nm.

    With more specific explanation, the "UNICON (Etafilcon A) Soft (Hydrophilic) Contact Lens with UV Blocker for Daily Wear' is 58% water and 42% HEMA/MAA cast-molding aspherical soft contact lens. It is blister packaged and produced from +4.00D to -6.00D in 0.25D per step, from +4.50D to +6.00D in 0.50D per step, and from -6.50D to -13.00D in 0.50D per step.

    AI/ML Overview

    The document provided is a 510(k) premarket notification for a soft contact lens. It aims to establish substantial equivalence to a predicate device rather than presenting a study proving a device meets specific acceptance criteria in the context of an AI/algorithm-driven medical device.

    Therefore, many of the requested elements (like sample size for test set, data provenance, number of experts for ground truth, adjudication method, MRMC comparative effectiveness study, standalone performance, training set sample size, and ground truth establishment for the training set) are not applicable to this type of submission.

    However, I can extract the acceptance criteria as defined by the non-clinical testing performed and compare them to the device's reported performance as presented in the "Substantial Equivalence Determination" section.

    Here's an interpretation based on the available information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The device (UNICON (Etafilcon A) Soft (Hydrophilic) Contact Lens with UV Blocker for Daily Wear) is asserting substantial equivalence to the VISTAKON (Etafilcon A) Soft (hydrophilic) Contact Lens (K051900). The "acceptance criteria" here are effectively the performance characteristics of the predicate device, which the proposed device aims to match or demonstrate equivalency to.

    MetricAcceptance Criteria (Predicate Device K051900)Reported Device Performance (UNICON K141917)
    General Characteristics
    Regulatory Number886.5925886.5925
    ClassificationIIII
    Prescription UseYesYes
    Single UseYesYes
    MaterialEtafilcon AEtafilcon A
    Manufacturing MethodCast MoldedCast Molded
    Sterilization MethodTraditional moist heatTraditional moist heat
    Primary PackagingPP container with aluminum foil sealingPP container with aluminum foil sealing
    Physical/Optical Properties
    Base Curve7.85mm to 10.0mm7.85mm to 10.0mm
    Diameter12.0mm to 15.0mm12.0mm to 15.0mm
    Water Content58%58%
    UV Transmittance @280~315 nmAvg < 5%Avg < 5%
    UV Transmittance @316~380 nmAvg < 30%Avg < 30%
    UV AbsorbingBenzotriazoleBenzotriazol
    Refractive Index1.401.399
    Power+20.00D to -20.00D+6.00D to -13.00D
    Specific Gravity0.98-1.121.14
    Tensile Strength2.00 Mpa1.66 Mpa
    Break Elongation189%393%
    Secant Modulus1.06 Mpa0.43 Mpa
    Oxygen Permeability (edged corrected) @ 35°C28 x 10-11 (cm2/sec) (mlO2/ml-mmHg)30.8 x 10-11 (cm2/sec) (mlO2/ml-mmHg)
    Visible Light TransmittanceMinimum 85%Minimum 90%
    Color & TintReactive Blue Dye #4Blue 15:3
    FDA 21 CFR (Color additive)73.3121 Poly(hydroxyethyl methacrylate)-dye copolymers74.3045 [Phthalocyaninato(2-)]copper

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

    • Sample Size: Not explicitly stated as a "test set" in the context of an algorithm. For non-clinical tests (sterilization, shelf life, biocompatibility, mechanical properties, etc.), samples of the manufactured contact lenses would have been tested. The exact number of lenses or batches tested for each non-clinical parameter is not provided in this summary.
    • Data Provenance: The non-clinical tests were performed in "UNICON QC lab and subcontracted test services" (Taiwan, based on submitter address). These are prospective tests on the manufactured device.

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

    This is not applicable to this type of device submission. There is no mention of expert-established ground truth as would be relevant for an AI/algorithm.

    4. Adjudication method for the test set:

    Not applicable.

    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 is a contact lens, not an AI-assisted diagnostic device.

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

    Not applicable.

    7. The type of ground truth used:

    For the non-clinical tests, the "ground truth" is defined by the established industry standards and recognized consensus standards (e.g., EN/ISO 17665 for sterilization, FDA guidance for daily wear contact lenses) which specify acceptable ranges or thresholds for each parameter. For example, for sterilization, achievement of a Sterility Assurance Level (SAL) of 10^-6 is the "ground truth" or acceptance criterion.

    8. The sample size for the training set:

    Not applicable. This is a manufactured physical device, not an algorithm that requires a training set.

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

    Not applicable.


    Summary of Device Performance against Acceptance Criteria

    The submission asserts that "All the test results were met the requirements of products specification" (page 6). The comparative table (pages 7-9) shows that the proposed device is largely identical or very similar to the predicate device across most physical, chemical, and performance characteristics.

    Key observations:

    • Intended Use, Material, Manufacturing, Sterilization, Water Content, UV Blocking: The proposed device matches the predicate.
    • Power Range: The proposed device has a narrower power range (+6.00D to -13.00D) compared to the predicate (+20.00D to -20.00D). This is a difference, but typically a narrower range for a device is not considered a safety or effectiveness concern unless it fails to meet its own stated range.
    • Specific Gravity: The proposed device (1.14) is slightly outside the predicate's range (0.98-1.12). The significance of this difference is not discussed in detail other than the general statement of substantial equivalence.
    • Tensile Strength, Break Elongation, Secant Modulus: There are differences in these mechanical properties (Tensile Strength: 1.66 MPa vs 2.00 MPa; Break Elongation: 393% vs 189%; Secant Modulus: 0.43 MPa vs 1.06 MPa). The differences are significant in magnitude. The submission implicitly indicates these are acceptable variations for substantial equivalence.
    • Oxygen Permeability: The proposed device (30.8 x 10^-11) has slightly higher oxygen permeability than the predicate (28 x 10^-11), which is generally a positive attribute for contact lenses.
    • Visible Light Transmittance: The proposed device (Minimum 90%) has a slightly higher minimum transmittance than the predicate (Minimum 85%), also generally a positive attribute.
    • Color & Tint / FDA Color Additive: This is identified as the main difference between the devices. The proposed device uses Blue 15:3 (Phthalocyaninato(2-)]copper) which is approved under 21 CFR 874.3045, while the predicate uses Reactive Blue Dye #4 (Poly(hydroxyethyl methacrylate)-dye copolymers) approved under 21 CFR 73.3121. The submission explicitly states that "the difference of proposed device and predicate device did not raise any problems of safety or effectiveness" and therefore does not impede substantial equivalence.

    Conclusion from the document: The manufacturer concludes, and the FDA agrees by issuing the letter, that the UNICON (Etafilcon A) Soft (Hydrophilic) Contact Lens with UV Blocker for Daily Wear is substantially equivalent to the predicate device based on the non-clinical tests performed and the comparison of characteristics. The clinical safety and effectiveness were established through the predicate device.

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