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510(k) Data Aggregation

    K Number
    K210701
    Date Cleared
    2021-04-07

    (29 days)

    Product Code
    Regulation Number
    886.4390
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K141079, K170322

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

    The CATALYS® Precision Laser System is indicated for use in patients undergoing cataract surgery for removal of the crystalline lens. Intended uses in cataract surgery include anterior capsulotomy, phacofragmentation, and the creation of single plane and multi-plane arc cuts/incisions in the cornea, each of which may be performed either individually or consecutively during the same procedure.

    Device Description

    Catalys® Precision Laser System ophthalmic surgical laser system used in healthcare facilities such as hospitals, Ambulatory Surgery Centers (ASCs) and surgeon office settings. The System is an electromedical device that contains software. System components include a single-use Liquid OpticsTM Interface and optional Mobile Patient Bed.

    The Catalys® Precision Laser System (also referred to as the Catalys® System or System) is an ophthalmic surgical laser system indicated for use in cataract surgery to create a precise anterior capsulotomy and/or to effect lens fragmentation, thus facilitating efficient lens removal. The System also creates single plane and multi-plane arccuts/incisions in the cornea, each of which may be performed either individually or consecutively during the same procedure. The System employs femtosecond ("FS") laser technology with integrated Optical Coherence Tomography ("OCT"), all of which are controlled and monitored by dedicated electronics. The System utilizes a common optical path for the OCT and femtosecond treatment laser (including the three-dimensional scanner and Liquid OpticsTM [patient] Interface). As such, the beams are intrinsically co-registered and provide for precise overlap between imaging and treatment beams. Ocular surfaces recognized by the system software include anatomy within the anterior chamber, such as the anterior and posterior corneal surfaces and the anterior and posterior surfaces of the crystalline lens. Detailed axial or sagittal cross-sectional views are available via OCT, to demarcate proposed incisions versus adjacent ocular structures (for example, iris, pupil and limbus).

    The Catalys® Precision Laser System laser classification per 21 CFR 1040.10 and 1040.11 is Class 4.

    AI/ML Overview

    This document is a 510(k) premarket notification for the CATALYS® Precision Laser System. It is a submission for a modified device, comparing it to a previously cleared predicate device (K200056). The core of this submission is to demonstrate that the modified device remains substantially equivalent to its predicate.

    Based on the provided information, the focus is on non-clinical performance data because clinical data was deemed not necessary for this submission. The device modifications are related to the Mobile Patient Bed, not the primary laser system itself.

    Here's an analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document doesn't explicitly state "acceptance criteria" in a quantitative, measurable format for this specific submission. Instead, it relies on demonstrating that the modified device's performance is maintained and that the changes do not introduce new safety or efficacy concerns compared to the predicate device. The "acceptance criteria" in this context are implicitly that the modified Mobile Patient Bed performs its intended function safely and effectively within the CATALYS® System, consistent with the original cleared device.

    Acceptance Criteria (Implicit)Reported Device Performance
    Mobile Patient Bed Functionality:
    • Maintain consistent motor output for Z-motors when lifting maximum weight.
    • Proper battery and charging management.
    • Diagnostic data logging capability (field service accessible).
    • Functional and tactile mechanical interface (pendant buttons, armrest, headrest). | Electronics/Circuits:
    • Z-Motors: "Consistent motor output between MPB's when lifting maximum weight."
    • Battery/Charging: "Vendor provided battery management module" (implies proper functionality).
      Firmware/FPGA:
    • "Diagnostic data logging (only field service accessible)."
      Mechanical:
    • "Tactile membrane switches on pendant."
    • "Armrest attached to seat near backrest."
    • "Simpler headrest assembly with only one articulation points." |
      | System Integration and Safety:
    • No adverse effects introduced by the changes to the Mobile Patient Bed.
    • Maintains same intended use, indications for use, and fundamental/scientific technology as the predicate device.
    • No new harms or unacceptable risks. | "Design verification and validation testing was performed to verify the ability of the modified Mobile Patient Bed to meet its intended use with the Catalys System and to ensure that no adverse effects have been introduced due to the changes."
      "The testings conducted and presented for the subject device, provides reasonable assurance that the System remains substantially equivalent for its intended use..."
      "It does not introduce any new harms or unacceptable risks..." |

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

    • Sample Size: The document does not specify a numerical sample size for the test set used in the design verification and validation testing. The testing refers to "subsystem level verification and regression testing, as well as system validation."
    • Data Provenance: The data is internally generated by AMO Manufacturing USA, LLC, as part of their design verification and validation process for the device modifications. The geographic origin of the data is not specified, but it would typically be internal testing data from the manufacturer's facilities. It is retrospective in the sense that it's performed on the modified device before submission for clearance, but it's prospective in terms of testing the changes being proposed.

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

    This section is not applicable as the study described is a non-clinical device verification and validation study, not a study involving expert-derived ground truth (e.g., image interpretation). The "ground truth" here is the expected functional and safety performance of the device components, which is defined by engineering specifications and regulatory standards.

    4. Adjudication method for the test set

    This section is not applicable for the same reasons as above. There isn't a need for adjudication in the context of verification and validation testing of device components.

    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

    An MRMC comparative effectiveness study was not done. This device is an ophthalmic laser system for cataract surgery, not an AI-powered diagnostic or assistive tool for human readers. The clinical performance data was deemed "not necessary."

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

    This section is not applicable in the context of an "algorithm only" performance. The device is a physical laser system with integrated software, not a standalone AI algorithm. The performance evaluation focuses on the entire system's functionality and safety.

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

    As this is a non-clinical validation of device modifications, the "ground truth" for the tests performed (subsystem verification, regression testing, system validation) would be based on:

    • Engineering specifications and design requirements: The modified components (electronics, battery, firmware, mechanical parts of the Mobile Patient Bed) must meet pre-defined engineering and performance criteria.
    • Regulatory standards: Compliance with relevant medical device safety and performance criteria (e.g., ISO 15004-2:2007 mentioned for output power) is an implicit ground truth.
    • Equivalence to predicate: The ultimate "ground truth" for this submission is demonstrating that the changes do not negatively impact the substantial equivalence to the already cleared predicate device.

    8. The sample size for the training set

    This section is not applicable as there is no mention of machine learning or an "AI algorithm" requiring a training set in the context of this 510(k) submission. The changes are hardware and associated firmware modifications to a component of an existing laser system.

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

    This section is not applicable for the same reasons as point 8.

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    K Number
    K182083
    Date Cleared
    2018-11-09

    (99 days)

    Product Code
    Regulation Number
    886.4390
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K141079, K170322

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

    The Catalys Precision Laser System is indicated for use in patients undergoing cataract surgery for removal of the crystalline lens. Intended uses in cataract surgery include anterior capsulotomy, phacofragmentation, and the creation of single plane and multi-plane arc cuts/incisions in the cornea, each of which may be performed either individually or consecutively during the same procedure.

    Device Description

    Catalys® Precision Laser System ophthalmic surgical laser system used in healthcare facilities such as hospitals, Ambulatory Surgery Centers (ASCs) and surgeon office settings. The System is an electromedical device which contains software. System components include a single-use Liquid Optics™ Interface and optional Mobile Patient Bed. The Catalys® Precision Laser System (also referred to as the Catalys® System) is a femtosecond laser system intended for use in patients undergoing cataract surgery for removal of the crystalline lens. Intended uses in cataract surgery include anterior capsulotomy, phacofragmentation, thus facilitating efficient lens removal. The System also creates single plane and multi-plane arc cuts/incisions in the cornea, each of which may be performed either individually or consecutively during the same procedure. The System employs femtosecond ("FS") laser technology with integrated Optical Coherence Tomography ("OCT"), all of which are controlled and monitored by dedicated electronics. The System utilizes a common optical path for the OCT and femtosecond treatment laser (including the three-dimensional scanner and Liquid Optics™ [patient] Interface1). As such, the beams are intrinsically co-registered and provide for precise overlap between imaging and treatment beams. Ocular surfaces recognized by the system software include anatomy within the anterior chamber, such as the anterior and posterior corneal surfaces and the anterior and posterior surfaces of the crystalline lens. Detailed axial or sagittal cross-sectional views are available via OCT, to demarcate proposed incisions versus adjacent ocular structures (for example, iris, pupil and limbus). In addition to the laser classifications per 21 CFR 1040.10 and 1040.11, the Catalys® Precision Laser System complies with the requirements for Class I lasers per ANSI Z136.1-2007.

    AI/ML Overview

    The provided document is a 510(k) summary for the AMO Manufacturing USA, LLC's Catalys® Precision Laser System. This submission is for software revisions to an already cleared device (predicate device K172002). The core of the summary focuses on demonstrating substantial equivalence to the predicate device, especially considering the software changes.

    Based on the provided text, we can extract the following information regarding acceptance criteria and study data:

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

    The document does not explicitly present a table of "acceptance criteria" with quantitative performance metrics for the software changes. Instead, it outlines the scope of the software revisions and states that verification and validation testing was performed to ensure the software meets its intended use and introduces no adverse effects.

    The "acceptance criteria" for this 510(k) are implicitly focused on demonstrating that the modified device's performance is maintained and that the software changes do not negatively impact its safety or effectiveness compared to the predicate. The performance aspects mentioned relate to maintaining the ability to deliver laser patterns for capsulotomy, phacofragmentation, and corneal incisions with corresponding accuracy and precision.

    Here's how we can interpret and present the information given:

    Acceptance Criterion (Implicit)Reported Device Performance (Summary of Study Findings)
    Software revisions do not introduce adverse effects and meet intended use.Software verification and validation testing, in addition to bench testing, was performed. This included subsystem level verification and regression testing, as well as system validation using the latest software, Mobile Patient Bed, and Liquid Optics Interface. The testing aimed to address:
    • Updates to hardware communication timing to reduce false positive alarms.
    • Graphical user interface changes to support use of the Mobile Patient Bed in environments with multiple Catalys systems.
    • A revision associated with trajectory timing offsets seen most evidently in the alignment verification function of the System.
      The modifications are stated to "employ additional tests to verify the performance of the laser's ability to execute the intended trajectory." |
      | Continued ability to deliver various laser patterns (capsulotomy, phacofragmentation, corneal incisions) with accuracy and precision. | Bench testing of the predicate device (K172002) regarding the ability to deliver these patterns with accuracy and precision is directly applicable to the subject device because "there are no significant changes to the subject device other than the design changes resident in the software." The modified device reportedly "employs additional tests to verify the performance of the laser's ability to execute the intended trajectory." |
      | System remains safe and effective for its intended use and is substantially equivalent to the predicate device. | Bench testing, coupled with software regression testing, verification, and validation, including regression testing, provides "reasonable assurance that the System remains safe and effective for its intended use and furthermore, that it is substantially equivalent to the identified predicate device." The changes in software are stated not to "raise new questions of safety and efficacy." |

    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 primarily describes bench testing, software regression testing, verification, and validation testing. It does not mention a 'test set' in terms of patient data or clinical samples. The testing is hardware and software focused.

    • Sample Size: Not applicable in the context of patient data. The "sample" would be the software builds and system configurations tested. No specific number of test cases or test runs is provided, only the types of testing.
    • Data Provenance: Not applicable in the context of patient data. The testing appears to be internal engineering and software validation. No country of origin for data is stated as it's not a clinical study on patients.
    • Retrospective/Prospective: Not applicable for this type of software/bench testing.

    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)

    This information is not provided in the document. The "ground truth" for this submission revolves around the correct functioning of the software and hardware according to design specifications, rather than expert interpretation of medical images or patient outcomes. The testing involves engineers and quality assurance personnel validating system performance against requirements.

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

    Not applicable for this submission. Adjudication methods are typically employed in clinical studies involving multiple expert readers assessing medical data. This submission focuses on software and bench testing, where the "ground truth" is defined by the technical specifications and expected system behavior.

    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

    No MRMC comparative effectiveness study was done or mentioned. This device is a laser system for cataract surgery, not an AI diagnostic or assistance tool for human readers of medical images. The submission pertains to software updates for the laser system's operational functionality.

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

    The device is a physical laser system with integrated software. Its performance is inherently "standalone" in the sense that the laser performs the surgical actions. However, it's a human-operated device. The software changes are about the internal operation and control of the laser system, not an external algorithm processing data for human interpretation. The testing described is of the full device system.

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

    The "ground truth" for the software revisions and the device's continued substantial equivalence is based on design specifications, pre-defined operational parameters, and expected system behavior for the laser's functions (capsulotomy, phacofragmentation, corneal incisions). This is primarily established through engineering validation, verification, and bench testing. There is no mention of expert clinical consensus, pathology, or outcomes data used as ground truth for these software changes. The original predicate device (K172002) would have had its own validation studies to support its initial clearance, but this submission specifically addresses the impact of software revisions.

    8. The sample size for the training set

    Not applicable. This submission is for software revisions to an existing medical device, not for an AI/machine learning algorithm that requires a "training set" of data. The software updates are described as modifying hardware communication timing, GUI, and trajectory timing offsets, which points to traditional software engineering rather than an AI model that learns from large datasets.

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

    Not applicable, as there is no mention of a training set or AI/machine learning in this 510(k) summary.

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    K Number
    K161455
    Date Cleared
    2016-09-20

    (117 days)

    Product Code
    Regulation Number
    886.4390
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K141079

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

    The OptiMedica Catalys Precision Laser System is indicated for use in patients undergoing cataract surgery for removal of the crystalline lens. Intended uses in cataract surgery include anterior capsulotomy, phacofragmentation, and the creation of single plane and multi-plane arc cuts/incisions in the cornea, each of which may be performed either individually or consecutively during the same procedure.

    Device Description

    The Catalys Precision Laser System ("Catalys System" or "System") is an ophthalmic surgical laser system indicated for use in cataract surgery to create a precise anterior capsulotomy and/or to effect lens fragmentation, thus facilitating efficient lens removal. The System also creates single plane and multi-plane arc cuts/incisions in the cornea, each of which may be performed either individually or consecutively during the same procedure. The System employs femtosecond ("FS") laser technology with integrated Optical Coherence Tomography ("OCT"), all of which are controlled and monitored by dedicated electronics. The System utilizes a common optical path for the OCT and femtosecond treatment laser (including the three-dimensional scanner and Liquid Optics "[patient] Interface). As such, the beams are intrinsically co-registered and provide for precise overlap between imaging and treatment beams. Ocular surfaces recognized by the system software include anatomy within the anterior chamber, such as the anterior and posterior corneal surfaces and the anterior and posterior surfaces of the crystalline lens. Detailed axial or sagittal cross-sectional views are available via OCT, to demarcate proposed incisions versus adjacent ocular structures (for example, iris, pupil and limbus).

    AI/ML Overview

    The provided document, a 510(k) summary for the Catalys Precision Laser System, focuses on demonstrating substantial equivalence to a predicate device (K141079) due to a software upgrade (cOS 3.90). It explicitly states that "there are no significant changes to the subject device other than the design changes resident in the software." As such, the document refers back to the testing performed for the predicate device to justify safety and effectiveness.

    Because of this, the document does NOT contain information about acceptance criteria and a study proving the device meets those criteria, specifically concerning the clinical performance of the device's therapeutic functions. Instead, it refers to prior submissions.

    Here's an analysis of what is available and what is missing based on your request:

    Information Present in the Document (or deducible):

    • Device: Catalys Precision Laser System
    • Purpose of current submission: Software upgrade (cOS 3.90) providing additional surveillance of vacuum pressure and LOI suction during docking, and video monitoring for fluid loss during treatment.
    • Study type mentioned: "Software specific bench testing of the Catalys System was conducted to demonstrate the System's ability to meet all intended design specifications related to the software design changes." This is a purely standalone test of the software's functionality, not related to clinical outcomes or human performance.
    • General assertion: "The bench, animal and clinical performance testing provided in K141079, when coupled with the software verification and validation testing presented for the subject device, provides reasonable assurance that the System is safe and effective for its intended use and furthermore, that it is substantially equivalent to the identified predicate device." This indicates that detailed performance data would be in K141079.
    • Ground Truth for software testing: For the software-specific bench testing, the "intended design specifications related to the software design changes" serve as the ground truth. This would involve comparing the software's output (e.g., reported vacuum pressure, fluid loss detection) against pre-defined correct operational parameters.
    • Sample size for software testing: Not specified.
    • Data provenance for software testing: Not specified, but generally, bench testing data would be internal development data.
    • Training set: Not applicable for this type of software-specific bench testing as described. This is a validation of new software features, not a model requiring a training dataset.

    Information NOT Present in the Document:

    1. Table of acceptance criteria and reported device performance (for clinical outcomes): Not provided. The document references prior submissions for clinical performance.
    2. Sample size used for the test set and data provenance (for clinical outcomes): Not provided; referenced in K141079.
    3. Number of experts and their qualifications (for clinical outcomes ground truth): Not provided; referenced in K141079.
    4. Adjudication method (for clinical outcomes): Not provided; referenced in K141079.
    5. Multi Reader Multi Case (MRMC) comparative effectiveness study: Not mentioned for this submission. The device is a surgical laser system, not an AI diagnostic tool that assists human readers.
    6. Standalone (algorithm only) performance (for clinical outcomes): While software bench testing was performed, clinical standalone performance data is not explicitly detailed in this document; referenced in K141079.
    7. Type of ground truth used (for clinical outcomes): Not provided; referenced in K141079.
    8. Sample size for the training set (if applicable for AI/ML): Not applicable for the described software update. This is a rule-based software design change, not an AI/ML system that would require a 'training set'.
    9. How the ground truth for the training set was established: Not applicable.

    Summary based on the provided text:

    The document describes a 510(k) submission for a software upgrade (cOS 3.90) to an existing device, the Catalys Precision Laser System. The primary study described in this specific document is "Software specific bench testing" to verify the new software's ability to meet its intended design specifications related to vacuum pressure monitoring and fluid loss detection. This is a standalone test of the new software features.

    For clinical efficacy and safety, the document explicitly states that the "bench, animal and clinical performance testing provided in K141079" (the predicate device's submission) is directly applicable due to "no significant changes to the subject device other than the design changes resident in the software." Therefore, details regarding acceptance criteria, sample sizes, ground truth establishment, or expert involvement for clinical outcomes would need to be sought in the K141079 submission, not in the provided text.

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