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510(k) Data Aggregation
(83 days)
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.
Catalys® Precision Laser System is an ophthalmic surgical laser system used in healthcare facilities such as hospitals, Ambulatory Surgery Centers (ASCs) and surgeon office settings. The Catalys® Precision Laser 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 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).
The Catalys® Precision Laser System laser classification per 21 CFR 1040.10 and 21 CFR 1040.11 is Class 4.
This document describes the CATALYS® Precision Laser System, specifically focusing on the acceptance criteria and study that proves the device meets those criteria for a modified Liquid Optics Interface (LOI).
Here's an breakdown of the requested information:
1. Table of Acceptance Criteria and Reported Device Performance
The submission describes bench testing performed to confirm the ability of the Gen3 LOI to meet its intended use. The acceptance criteria themselves are explicitly stated as "All acceptance criteria were met" for various tests, implying successful completion against predefined benchmarks. The document also states, "The acceptance criteria remain unchanged between Gen2 and Gen3 LOI." While specific quantitative criteria are not listed in a table format within the provided text, the document asserts that they were met. The reported performance is that the device did meet these (unspecified) criteria.
Acceptance Criteria Category | Reported Device Performance |
---|---|
Sterilization Cycle Validity | All acceptance criteria were met. (Minimum 10-6 SAL achieved) |
Performance Testing (Baseline & Aged) | All acceptance criteria were met. |
Biocompatibility (Colorant) | No leaching and no cytotoxicity for the minor colorant addition. |
Overall Safety and Effectiveness | The device remains safe and effective for its intended use and is substantially equivalent. |
2. Sample Size Used for the Test Set and Data Provenance
The document mentions "bench testing" and "performance testing conducted for the Gen3 LOI." It indicates testing was done at "baseline time point T=0 (before aging) and at T=24 (after accelerated aging equivalent to 24 months)." However, the exact sample size for any of these tests is not specified in the provided text. The data provenance is stated as from the manufacturer's own internal testing, specifically AMO Manufacturing USA, LLC, which is a retrospective evaluation of a new manufacturing process for an existing component.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
The document does not describe the use of human experts to establish "ground truth" for the technical performance tests. These tests (sterilization, performance, biocompatibility) typically rely on standardized protocols and instrumental measurements against engineering specifications, rather than subjective expert assessment.
4. Adjudication Method for the Test Set
Not applicable, as the testing described focuses on objective technical performance criteria (e.g., sterilization assurance, mechanical integrity, biocompatibility) rather than subjective assessments requiring adjudication.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No, an MRMC comparative effectiveness study was not done. The submission explicitly states: "The proposed device does not include any changes to the indications for use or intended use of the primary predicate device. It does not introduce any new harms or unacceptable risks, and therefore does not require clinical testing to assess safety and performance or to demonstrate equivalence."
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
This device is an ophthalmic laser system for cataract surgery with a modified patient-user interface. It is a physical medical device, not an AI or algorithm-only product. Therefore, the concept of "standalone performance" in the context of an algorithm is not applicable. The performance evaluated here is the physical and functional performance of the device's components.
7. The Type of Ground Truth Used
The ground truth for the evaluations conducted ("sterilization cycle validation," "performance testing," and "biocompatibility testing") would be established by:
- Sterilization Validation: Meeting a predefined Sterility Assurance Level (e.g., 10-6 SAL) through standard microbiological challenge tests as defined by ISO 11135 and AAMI TIR28.
- Performance Testing: Adherence to engineering specifications and design requirements for the Liquid Optics Interface (LOI), ensuring it functions correctly with the CATALYS® Precision Laser System.
- Biocompatibility Testing: Compliance with biocompatibility standards (e.g., ISO 10993) demonstrating no cytotoxic effects or leaching for the specified materials.
8. The Sample Size for the Training Set
Not applicable. This submission is for a modification to a physical medical device component, not for an AI/machine learning algorithm that requires a "training set." The changes involve manufacturing site, sterilization parameters, and a colorant change for a single-use interface.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no training set for an AI/machine learning algorithm described in this document.
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(29 days)
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.
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.
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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(99 days)
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.
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.
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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