K181662 · Iridex Corporation · GEX · Sep 5, 2018 · General, Plastic Surgery
Device Facts
Record ID
K181662
Device Name
Iridex TruFocus LIO Premiere
Applicant
Iridex Corporation
Product Code
GEX · General, Plastic Surgery
Decision Date
Sep 5, 2018
Decision
SESE
Submission Type
Special
Regulation
21 CFR 878.4810
Device Class
Class 2
Attributes
Therapeutic, Pediatric
Indications for Use
The Iridex TruFocus LIO Premiere Laser Indirect Ophthalmoscope with the Family of Iridex® IQ Laser Systems (IQ 532 [532nm], IQ 577 [577mm], IQ 630-670 [630mm-670mm], IQ 810 [810mm]), hand pieces & accessories that are used with them to deliver laser energy in either CW-pulse™ or LongPulse™ mode. Intended for soft and fibrous tissue, including osseous tissue incision, coagulation, vaporization, ablation and vessel hemostasis in the medical specialties of, dermatology, ear, nose and throat (ENT)/ otolaryngology, and ophthalmology as follows: 532 nm: Dermatology: · Pigmented Skin Lesions · Vascular Lesions Ear, Nose, and Throat (ENT)/ Otolaryngology Otosclerotic Hearing loss and/or diseases of the inner ear: · Stapedectomy · Stapedotomy · Myringotomies · Lysis of Adhesions · Control of Bleeding · Removal of Acoustic Neuromas · Soft tissue Adhesion in Micro/Macro Otologic Procedures Ophthalmology: Indicated for retinal photocoagulation, laser trabeculoplasty, iridotomy, iridoplasty including: · Retinal photocoagulation (RPC) for the treatment of Diabetic retinopathy, including: Nonproliferative retinopathy Macular edema Proliferative retinopathy · Retinal tears and detachments Lattice degeneration Age-related macular degeneration (AMD) Retinopathy of prematurity Sub-retinal (choroidal) neovascularization Central and branch retinal vein occlusion · Laser trabeculoplasty, iridotomy, iridoplasty for the treatment of glaucoma, including Primary open angle/Closed angle 577nm Dermatology: · Treatment of Vascular and pigmented lesions Ophthalmology: Indicated for use in photocoagulation of both anterior and posterior segments including: · Retinal photocoagulation, panretinal photocoagulation and intravitreal endophotocolagulation of vascular and structural abnormalities of the retina and choroid including : Proliferative and nonproliferative diabetic retinopathy; Choroidal neovascularization; Branch retinal vein occlusion; Age-related macular degeneration Retinal tears and detachments Retinopathy of prematurity · Iridotomy, iridectomy and trabeculoplasty in angle closure glaucoma and open angle glaucoma 630 - 670nm Ophthalmology: Indicated for use in photocoagulation of both anterior and posterior segments including: · Retinal photocoagulation, panretinal photocoagulation and intravitreal endophotocoagulation of vascular and structural abnormalities of the retina and choroid including: Proliferative and non-proliferative diabetic retinopathy; Choroidal neovascularization: Branch retinal vein occlusion; Age-related macular degeneration Retinal tears and detachments Retinopathy of prematurity · Iridotomy, iridectomy and trabeculoplasty in angle glaucoma and open angle glaucoma 810nm Ophthalmology: Indicated for retinal photocoagulation, laser trabeculoplasty, transscleral cyclophotocoagulation, transscleral retinal photocoagulation, iridotomy, including the following examples: · Retinal photocoagulation for the treatment of: · Diabetic retinopathy, including: Nonproliferative retinopathy Macular edema Proliferative retinopathy · Retinal Tears, Detachments and Holes · Lattice degeneration · Age-related macular degeneration (AMD) with choroidal neovascularization (CNV) · Retinopathy of prematurity · Sub-retinal (choroidal) neovascularization · Central and Branch Retinal Vein Occlusion · Laser trabeculoplasty, Iridotomy, Transscleral Cyclophotocoagulation (TSCPC) for the treatment of glaucoma, including: Primary open angle Closed angle Refractory Glaucoma (recalcitrant/uncontrolled)
Device Story
Device is a head-mounted laser indirect ophthalmoscope (LIO) used by physicians in clinics, ORs, or ambulatory centers. It combines a laser treatment beam from an Iridex laser console with an illumination beam from a binocular indirect ophthalmoscope. The physician uses a handheld condensing lens to focus the beam through the patient's pupil to the retina. The device enables visualization and treatment of retinal/choroidal abnormalities. It provides a portable alternative to fixed slit-lamp systems. Output is a focused laser beam for photocoagulation or tissue ablation. Benefits include portability for patients unable to use fixed systems. The device is non-sterile and reusable.
Clinical Evidence
Bench testing only. Simulated use validation test performed on 25 units to verify alignment of illumination and aiming/treatment beams through a 20-diopter condensing lens into a 6mm simulated pupil. All units passed.
Technological Characteristics
Headband-mounted binocular indirect ophthalmoscope; air-cooled; LED illumination (optional halogen); fiber-optic delivery (resistive or RFID connector); 532nm, 577nm, 810nm wavelengths; weight ≤1000g; rechargeable battery (100-240VAC).
Indications for Use
Indicated for patients of all ages, including infants, requiring soft/fibrous tissue incision, coagulation, vaporization, ablation, or hemostasis in dermatology, ENT, and ophthalmology. Specific ophthalmic indications include diabetic retinopathy, macular edema, retinal tears/detachments, AMD, retinopathy of prematurity, retinal vein occlusion, and glaucoma (trabeculoplasty, iridotomy, iridoplasty, cyclophotocoagulation).
Regulatory Classification
Identification
(1) A carbon dioxide laser for use in general surgery and in dermatology is a laser device intended to cut, destroy, or remove tissue by light energy emitted by carbon dioxide.(2) An argon laser for use in dermatology is a laser device intended to destroy or coagulate tissue by light energy emitted by argon.
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Image /page/0/Picture/0 description: The image contains two logos. The logo on the left is the Department of Health & Human Services - USA logo. The logo on the right is the FDA U.S. Food & Drug Administration logo. The FDA logo is in blue.
September 5, 2018
Iridex Corporation Edward Sinclair Vice President, Regulatory and Ouality Affairs 1212 Terra Bella Avenue Mountain View, California 94043-1824
Re: K181662
Trade/Device Name: Iridex TruFocus LIO Premiere Regulation Number: 21 CFR 878.4810 Regulation Name: Laser Surgical Instrument For Use In General And Plastic Surgery And In Dermatology Regulatory Class: Class II Product Code: GEX Dated: August 3, 2018 Received: August 6, 2018
Dear Edward Sinclair:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal
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statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Alexander Beylin -S 2018.09.05 18:03:14 -04'00'
for Malvina Eydelman, M.D. Director Division of Ophthalmic and Ear, Nose, and Throat Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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## Indications for Use
510(k) Number (if known) K181662
#### Device Name TruFocus LIO Premiere
#### Indications for Use (Describe)
The Iridex TruFocus LIO Premiere Laser Indirect Ophthalmoscope with the Family of Iridex® IQ Laser Systems (IQ 532 [532nm], IQ 577 [577mm], IQ 630-670 [630mm-670mm], IQ 810 [810mm]), hand pieces & accessories that are used with them to deliver laser energy in either CW-pulse™ or LongPulse™ mode. Intended for soft and fibrous tissue, including osseous tissue incision, coagulation, vaporization, ablation and vessel hemostasis in the medical specialties of, dermatology, ear, nose and throat (ENT)/ otolaryngology, and ophthalmology as follows:
532 nm:
- Dermatology:
- · Pigmented Skin Lesions
- · Vascular Lesions
Ear, Nose, and Throat (ENT)/ Otolaryngology
Otosclerotic Hearing loss and/or diseases of the inner ear:
- · Stapedectomy
- · Stapedotomy
- · Myringotomies
- · Lysis of Adhesions
- · Control of Bleeding
- · Removal of Acoustic Neuromas
- · Soft tissue Adhesion in Micro/Macro Otologic Procedures
#### Ophthalmology:
Indicated for retinal photocoagulation, laser trabeculoplasty, iridoplasty including:
- · Retinal photocoagulation (RPC) for the treatment of
- Diabetic retinopathy, including:
- Nonproliferative retinopathy
- Macular edema
- Proliferative retinopathy
- · Retinal tears and detachments
- Lattice degeneration
- Age-related macular degeneration (AMD)
- Retinopathy of prematurity
- Sub-retinal (choroidal) neovascularization
- Central and branch retinal vein occlusion
- · Laser trabeculoplasty, iridotomy, iridoplasty for the treatment of glaucoma, including
- Primary open angle/Closed angle
#### 577nm
Dermatology:
- · Treatment of Vascular and pigmented lesions
Ophthalmology:
Indicated for use in photocoagulation of both anterior and posterior segments including:
· Retinal photocoagulation, panretinal photocoagulation and intravitreal endophotocoagulation of vascular and structural abnormalities of the retina and choroid including :
- Proliferative and nonproliferative diabetic retinopathy;
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- Choroidal neovascularization;
- Branch retinal vein occlusion;
- Age-related macular degeneration
- Retinal tears and detachments
- Retinopathy of prematurity
- · Iridotomy, iridectomy and trabeculoplasty in angle closure glaucoma and open angle glaucoma
#### 630 - 670nm
Ophthalmology:
- Indicated for use in photocoagulation of both anterior and posterior segments including:
· Retinal photocoagulation, panretinal photocoagulation and intravitreal endophotocoagulation of vascular and structural abnormalities of the retina and choroid including:
- Proliferative and non-proliferative diabetic retinopathy;
- Choroidal neovascularization:
- Branch retinal vein occlusion;
- Age-related macular degeneration
- Retinal tears and detachments
- Retinopathy of prematurity
- · Iridotomy, iridectomy and trabeculoplasty in angle glaucoma and open angle glaucoma
#### 810nm
Ophthalmology:
Indicated for retinal photocoagulation, laser trabeculoplasty, transscleral cyclophotocoagulation, transscleral retinal photocoagulation, iridotomy, including the following examples:
- · Retinal photocoagulation for the treatment of:
- · Diabetic retinopathy, including:
- Nonproliferative retinopathy
- Macular edema
- Proliferative retinopathy
- · Retinal Tears, Detachments and Holes
- · Lattice degeneration
- · Age-related macular degeneration (AMD) with choroidal neovascularization (CNV)
- · Retinopathy of prematurity
- · Sub-retinal (choroidal) neovascularization
- · Central and Branch Retinal Vein Occlusion
- · Laser trabeculoplasty, Iridotomy, Transscleral Cyclophotocoagulation (TSCPC) for the treatment of glaucoma, including:
- Primary open angle
- Closed angle
- Refractory Glaucoma (recalcitrant/uncontrolled)
Type of Use (Select one or both, as applicable)
X Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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Image /page/5/Picture/1 description: The image shows the logo for IRIDEX. The logo consists of a circular emblem on the left and the word "IRIDEX" in bold, sans-serif font on the right. The emblem features a stylized floral design within a blue circle.
## 510(k) SUMMARY
## Submitter Information
| Company: | Iridex Corporation<br>1212 Terra Bella Ave<br>Mountain View, CA 94043-1824<br>Phone: (650) 940-4700<br>Fax: (650) 355-1305<br>Establishment Registration No.: 2939653 |
|--------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Edward J. Sinclair<br>Vice President, Regulatory and Quality Affairs<br>Phone: (650) 940-4700<br>Fax: (650) 355-1305 |
| Date Prepared: | August 3, 2018 |
| Device Name and Classification | |
| Common Name: | Laser Indirect Ophthalmoscope |
| Proprietary Name: | Iridex TruFocus LIO Premiere™ |
| Classification Name: | Laser Powered Surgical Instruments (and Accessories |
| Product Code: | GEX |
| Regulation Number: | 21 CFR§ 878.4810 |
| Device Class: | II |
| Predicate Device | |
| Company: | Iridex Corporation |
#### Intended Use (Indications For Use)
The intended use of the modified device, as described in its labeling, has not changed as a result of the modifications. The indications for use are described below:
The Iridex TruFocus LIO Premiere Laser Indirect Ophthalmoscope with the Family of Iridex® IQ Laser Systems (IQ 532 [532nm], IQ 577 [577nm], IQ 630-670 [630mm-670mm], IQ 810 [810nm]), hand pieces, delivery devices & accessories that are used with them to deliver laser energy in either CW-pulse, MicroPulse™ or LongPulse™ mode. Intended for soft and fibrous tissue, including osseous tissue incision, excision, coagulation, vaporization, ablation and vessel hemostasis in the medical specialties of, dermatology, ear, nose and throat (ENT)/ otolaryngology, and ophthalmology as follows: 532 nm:
Dermatology:
• Pigmented Skin Lesions
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Image /page/6/Picture/2 description: The image contains the word "IRIDEX" in a bold, sans-serif font. To the left of the word is a circular logo with a blue border. Inside the border is a white design that resembles a snowflake or a stylized flower with three intersecting lines in the center.
- · Vascular Lesions
Ear, Nose, and Throat (ENT)/ Otolaryngology
Otosclerotic Hearing loss and/or diseases of the inner ear:
- · Stapedectomy
- · Stapedotomy
- · Myringotomies
- · Lysis of Adhesions
- · Control of Bleeding
- · Removal of Acoustic Neuromas
- Soft tissue Adhesion in Micro/Macro Otologic Procedures
## Ophthalmology:
Indicated for retinal photocoagulation, laser trabeculoplasty, iridotomy, iridoplasty including:
- · Retinal photocoagulation (RPC) for the treatment of
- Diabetic retinopathy, including:
- Nonproliferative retinopathy
- Macular edema
- Proliferative retinopathy
- · Retinal tears and detachments
- Lattice degeneration
- Age-related macular degeneration (AMD)
- Retinopathy of prematurity
- Sub-retinal (choroidal) neovascularization
- Central and branch retinal vein occlusion
- · Laser trabeculoplasty, iridotomy, iridoplasty for the treatment of glaucoma, including - Primary open angle/Closed angle
#### 577mm:
Dermatology:
- · Treatment of Vascular and pigmented lesions
Ophthalmology:
Indicated for use in photocoagulation of both anterior and posterior segments including: · Retinal photocoagulation, panretinal photocoagulation and intravitreal
endophotocoagulation of vascular and structural abnormalities of the retina and choroid including:
- Proliferative and nonproliferative diabetic retinopathy;
- Choroidal neovascularization:
- Branch retinal vein occlusion;
- Age-related macular degeneration
- Retinal tears and detachments
- Retinopathy of prematurity
· Iridotomy, iridectomy and trabeculoplasty in angle closure glaucoma and open angle glaucoma
630 - 670nm:
Ophthalmology:
Indicated for use in photocoagulation of both anterior and posterior segments including:
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Image /page/7/Picture/2 description: The image shows the logo for IRIDEX. The logo consists of a circular emblem on the left and the word "IRIDEX" in bold, black letters on the right. The emblem features a stylized flower-like design with a blue border and a complex geometric pattern inside.
- · Retinal photocoagulation, panretinal photocoagulation and intravitreal
endophotocoagulation of vascular and structural abnormalities of the retina and choroid including:
- Proliferative and non-proliferative diabetic retinopathy;
- Choroidal neovascularization;
- Branch retinal vein occlusion;
- Age-related macular degeneration
- Retinal tears and detachments
- Retinopathy of prematurity
- · Iridotomy, iridectomy and trabeculoplasty in angle glaucoma and open angle glaucoma
## 810mm:
Ophthalmology:
Indicated for retinal photocoagulation, laser trabeculoplasty, transscleral
cyclophotocoagulation, transscleral retinal photocoagulation, iridotomy, including the following examples:
- · Retinal photocoagulation for the treatment of:
- · Diabetic retinopathy, including:
- Nonproliferative retinopathy
- Macular edema
- Proliferative retinopathy
- · Retinal Tears, Detachments and Holes
- · Lattice degeneration
- · Age-related macular degeneration (AMD) with choroidal neovascularization (CNV)
- Retinopathy of prematurity
- Sub-retinal (choroidal) neovascularization
- · Central and Branch Retinal Vein Occlusion
- · Laser trabeculoplasty, Iridotomy, Transscleral Cyclophotocoagulation (TSCPC) for the treatment of glaucoma, including:
- Primary open angle
- Closed angle
- Refractory Glaucoma (recalcitrant/uncontrolled)
## Device Description
The Iridex TruFocus LIO Premiere Laser Indirect Ophthalmoscope is a light combination and reflection viewing system used with the Iridex IQ/GL/SL/TX laser system families. The LIO combines a laser treatment beam from an Iridex laser source with the illumination beam of a Heine binocular indirect ophthalmoscope into a mixed optical beam used by a physician with a handheld ophthalmic examination (condensing) lens to enter a patient's pupil and to collect and view reflections by a patient's retina returned through the same pupil. It provides a portable alternative to patients who cannot be examined or treated with a fixed slit lamp adapter. The LIO is supplied non-sterile and is intended for reuse and worn on the physician's head to view and treat the patient's retina. The device can be used to evaluate and treat patients of all ages, including infants, in an office, operating room and ambulatory surgical center setting.
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Image /page/8/Picture/0 description: The image shows the logo for IRIDEX. The logo consists of a blue circular emblem on the left and the word "IRIDEX" in bold, black letters on the right. The emblem features a white floral design with three stylized petals inside a blue circle.
There are five models of the TruFocus LIO Premiere available that differ in the laser wavelength to be delivered, spot size, and the type of LIO-to-laser console connector, as listed in the table below.
| Product No.<br>(Model) | Description | Iridex Laser Console<br>Compatibility | Spot Size | Connector<br>Type |
|------------------------|--------------------------------|---------------------------------------|-----------|-------------------|
| 87300 | TruFocus LIO Premiere, 532/810 | OcuLight GL, TX, SL, SLx, IQ<br>532 | 350 µm | Resistive |
| 87301 | TruFocus LIO Premiere, 810 | OcuLight SL, SLx | 350 µm | Resistive |
| 87302<br>(Large Spot) | TruFocus LIO Premiere, 810 LS | OcuLight SL, SLx | 1400 µm | Resistive |
| 87303 | TruFocus LIO Premiere, 532 | IQ 532 | 350 µm | RFID |
| 87304 | TruFocus LIO Premiere, 577 | IQ 577 | 350 µm | RFID |
Each LIO includes:
- · Accessory Kit (PN 87526) comprised of a carry case (PN 87284), headband-mounted rechargeable battery (PN 87287), and a plug-in transformer (PN 87286). These accessories are also available for individual purchase.
- · LIO instructions are provided in the form of an Operator Manual.
- · Heine Omega 500 BIO instructions are included.
- · Zero-diopter and Two-diopter lenses are included.
Other available options include:
- · Extension cord for plug-in transformer
- · Wall-mounted charging cradle
## Key Functional Components
The TruFocus LIO Premiere contains the following hardware components:
- Adjustable headband
- Headband-mounted rechargeable battery
- Headband-mounted optics unit
- · Fiber-optic cable with connector (resistive or RFID)
- · Zero-diopter and Two-diopter lenses
- Plug-in transformer and extension cord
- · Wall-mounted charging cradle
- · Replaceable LED illumination bulb
- · Standard carry case
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# Comparison of Technological Characteristics with the Predicate Device
The TruFocus LIO Premiere subject device is substantially equivalent to the TruFocus LIO Premiere predicate device (cleared by FDA in K170718 on May 3, 2017). The intended use, mechanism of action, and key components remain the same. There were no changes in the technological characteristics. A comparison of the significant technological characteristics, which are identical, is provided in the table below:
| Characteristic | Iridex TruFocus LIO Premiere<br>Laser Indirect Ophthalmoscope<br>(Subject Device) | Iridex TruFocus LIO Premiere<br>Laser Indirect Ophthalmoscope<br>(Predicate device cleared by K170718) |
|-------------------------|---------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------|
| Type/Design | Indirect Ophthalmoscope Binocular<br>(Headband mounted) | Indirect Ophthalmoscope Binocular<br>(Headband mounted) |
| Treatment<br>Wavelength | 532nm, 577nm, 810nm | 532nm, 577nm, 810nm |
| Eye Filter OD | 6 @ 532 nm & 577nm, 2 @ 810 nm | 6 @ 532 nm & 577nm, 2 @ 810 nm |
| Working<br>Distance | 370mm +/- 10mm | 370mm +/- 10mm |
| Fiber Length | 13'8" | 13'8" |
| Aerial Spot Size | Standard LIO spot size: 1.1mm<br>(0.043in) ±10%<br>Large LIO spot size: 4.0mm (0.157in)<br>±10% | Standard LIO spot size: 1.1mm<br>(0.043in) ±10%<br>Large LIO spot size: 4.0mm (0.157in)<br>±10% |
| Illumination<br>Source | LED Illumination light source standard<br>with optional Halogen bulb | LED Illumination light source standard<br>with optional Halogen bulb |
| Cooling System | Air Cooled | Air Cooled |
| Electrical | Heine rechargeable battery. Operates<br>on 100-240VAC, 50/50Hz. Optional<br>wall plug in charger. | Heine rechargeable battery. Operates<br>on 100-240VAC, 50/50Hz. Optional<br>wall plug in charger. |
| Weight | ≤ 1000gm (2.2 lbs.) with battery<br>installed | ≤ 1000gm (2.2 lbs.) with battery<br>installed |
# Description of Changes
The Operator Manual (Instructions For Use) has been updated in order to (a) provide additional illustrations and clarification of the various adjustment controls, (b) clarify the patient treatment instructions showing how to position the illumination and aiming beams within the binocular field of view and how to position the condenser lens along the axis of the aiming beam, and (c) establish a separate section to provide instructions for use of the binocular indirect ophthalmoscope (BIO) mode.
The submission also describes minor changes including a dimensional increase of a portion of the fiber optic cable assembly to improve attachment to molded clips at the top of the headband, an improved manufacturing process and new adhesive to enhance the bond reliability of the glass dust cover and cover frame used to shield the optics, and improvements to the aiming beam adjustment control cam surface finish resulting in a smoother actuation "feel" to the user.
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Image /page/10/Picture/0 description: The image contains the logo for IRIDEX. To the left of the company name is a circular logo with a blue border. Inside the border is a white design that resembles a snowflake or a stylized flower with three intersecting lines.
K181662
## Risk Analysis
A risk analysis was used to assess the impact of the cumulative effect of each device modification and the proposed modifications to the Operator Manual. The risk assessment methods comply with EN ISO 14971:2012 "Medical devices – Application of risk management to medical devices." The device and labeling changes described in this 510(k) submission were assessed for risk by reviewing the current Risk Management documentation for the TruFocus LIO Premiere device. The Hazard Analysis was reviewed and it was determined that no new hazards were introduced. The FMEA documents were reviewed to determine whether any risks were increased, reduced, or whether new risks were introduced as a result of the change (i.e., any difference in the occurrence or detectability of potential failure modes, or any new failure modes/potential causes). This assessment was performed by a qualified cross-functional team. The potential hazards were found to be sufficiently mitigated through the modified user instructions, device design, and change verification and validation to an acceptable level of risk. The potential benefits to patients outweigh the low residual risk of the modifications to the device and labeling.
## Performance Data
In addition to verification and validation testing of the individual device changes, performance testing was conducted to validate the cumulative effect of device modifications and changes to the Operator Manual (the user instructions). A test procedure was developed to subject a sample size of 25 modified TruFocus LIO Premiere devices to a "simulated use" validation test following the modified Operator Manual. This test was designed to verify that when following the updated operator manual, the user could properly align and operate the device (e.g., the illumination and aiming/treatment beams would pass through the 20-diopter condensing lens and concentrically enter the simulated pupil plane using a pupil size of 6 mm in diameter, and achieve proper alignment of the internal illumination and aiming/treatment beam mirrors as well as illumination and aiming beam travel within the binocular field of view by using the adjustment control knobs). All units passed the simulated use test.
#### Conclusions
The modified TruFocus LIO Premiere device is as safe and effective as, and is substantially equivalent to, the predicate device.
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2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.