K182263 · Natus Medical Incorporated · HKI · Sep 7, 2018 · Ophthalmic
Device Facts
Record ID
K182263
Device Name
RetCam 3 ; RetCam Shuttle ; RetCam Portable
Applicant
Natus Medical Incorporated
Product Code
HKI · Ophthalmic
Decision Date
Sep 7, 2018
Decision
SESE
Submission Type
Special
Regulation
21 CFR 886.1120
Device Class
Class 2
Attributes
Pediatric
Indications for Use
General ophthalmic imaging including retinal, corneal, and external imaging. -Photodocumentation of pediatric ocular diseases including retinopathy of prematurity (ROP). -Screening for Type 2 pre-threshold retinopathy of prematurity (ROP) (zone 1, stage 1 or 2, without plus disease, or zone 2, stage 3, without plus disease) or treatment-requiring ROP, defined as Type 1 ROP (zone 1, any stage, with plus disease; zone 1, stage 3 without plus disease; or zone 2, stage 2 or 3, with plus disease) or threshold ROP (at least 5 contiguous or 8 non-contiguous clock hours of stage 3 in zone 1 or 2, with plus disease)* in 35-37 week postmenstrual infants.
Device Story
RetCam Ophthalmic Imaging Systems capture color images of retina, cornea, and external eye structures. System uses digital camera in handpiece with multiple field-of-view lenses; halogen light source provides illumination. Images processed, stored, viewed, and exported via onboard computer (RetCam 3) or laptop (RetCam Shuttle/Portable). Operated by clinicians in clinical settings. Footswitch or keyboard controls light intensity, focus, and image capture. Output allows clinicians to document and screen for pediatric ocular diseases, specifically ROP, facilitating clinical diagnosis and treatment decisions.
Clinical Evidence
Bench testing only. No clinical data presented. Testing included image comparison, optics verification/validation, and ISTA testing. Compliance with IEC 60601-1 and IEC 60601-1-2 confirmed.
Technological Characteristics
Digital ophthalmic imaging system; halogen illumination; handpiece with coated glass lenses; plastic/aluminum housing. Connectivity: DICOM (NEMA PS 3.1-3.20). Software: moderate level of concern. Standards: IEC 60601-1:2005, IEC 60601-1-2:2007/(R)2012.
Indications for Use
Indicated for general ophthalmic imaging (retinal, corneal, external) and photodocumentation of pediatric ocular diseases, including retinopathy of prematurity (ROP), in 35-37 week postmenstrual infants.
Regulatory Classification
Identification
An ophthalmic camera is an AC-powered device intended to take photographs of the eye and the surrounding area.
Special Controls
*Classification.* Class II (special controls). The device, when it is a photorefractor or a general-use ophthalmic camera, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 886.9.
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September 7, 2018
Natus Medical Incorporated Brian Ackley Manager, Ouality and Regulatory Affairs 1183 Quarry Lane. Suite A Pleasanton, CA 94566
Re: K182263
Trade/Device Name: RetCam 3; RetCam Shuttle; RetCam Portable Regulation Number: 21 CFR 886.1120 Regulation Name: Ophthalmic camera Regulatory Class: Class II Product Code: HKI Dated: August 16, 2018 Received: August 22, 2018
Dear Brian Ackley:
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/cdrl/cfdocs/cfpm/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.
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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 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 devicerelated 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.htm); good manufacturing practice requirements as set forth in the quality systems (OS) 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 medical devices and radiation-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 yours,
## Bradley S. Cunningham -A
for Malvina B. 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) K182263
### Device Name
RetCam Ophthalmic Imaging Systems RetCam 3 Ophthalmic Imaging System RetCam Shuttle Ophthalmic Imaging System, RetCam Portable Ophthalmic Imaging System
Indications for Use (Describe)
General ophthalmic imaging including retinal, corneal, and external imaging.
-Photodocumentation of pediatric ocular diseases including retinopathy of prematurity (ROP).
-Screening for Type 2 pre-threshold retinopathy of prematurity (ROP) (zone 1, stage 1 or 2, without plus disease, or zone 2, stage 3, without plus disease) or treatment-requiring ROP, defined as Type 1 ROP (zone 1, any stage, with plus disease; zone 1, stage 3 without plus disease; or zone 2, stage 2 or threshold ROP (at least 5 contiguous or 8 non-contiguous clock hours of stage 3 in zone 1 or 2, with plus disease)* in 35-37 week postmenstrual infants.
*References:
1. Cryotherapy for Retinopathy of Prematurity Cooperative Group. Multicenter trial of cryotherapy for retinopathy of prematurity: preliminary results. Archives of Ophthalmology 1988; 106(4):471-479.
2. Early Treatment for Retinopathy of Prematurity Cooperative Group. Revised indications for the treatment of retinopathy of prematurity: results of the Early Treatment for Retinopathy Randomized Trial. Archives of Ophthalmology 2003; 121(12):1684-1694.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------|---------------------------------------------|
| Prescription Use (Part 21 CFR 801 Subpart D) | Over-The-Counter Use (21 CFR 801 Subpart C) |
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## 510(k) Summary RetCam Ophthalmic Imaging Systems
| Submitter Name: | Natus Medical Inc. |
|---------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Submitter Address: | 1183 Quarry Lane, Suite A<br>Pleasanton, CA 94566 USA |
| Contact Person: | Brian Ackley |
| Phone Number: | 925-201-1680 |
| Fax Number: | 925-251-0078 |
| Date Prepared: | August 16, 2018 |
| Device Trade Names: | RetCam Ophthalmic Imaging Systems<br>RetCam 3 Ophthalmic Imaging System<br>RetCam Shuttle Ophthalmic Imaging System<br>RetCam Portable Ophthalmic Imaging System |
| Device Common Name: | Ophthalmic Imaging System |
Product Code: HKI
Classification: Ophthalmic Imaging Systems have been classified as Class II according to 21 C.F.R. § 886.1120
Predicate Device: RetCam Ophthalmic Imaging Systems, K090326
## Device Description:
RetCam Ophthalmic Imaging Systems utilize a digital camera in a handpiece (with multiple field of view lenses) to capture color ophthalmic images including retinal, corneal, and external images. An on board computer (RetCam 3 Ophthalmic Imaging System) or laptop computer (RetCam Shuttle Ophthalmic Imaging System and RetCam Portable Ophthalmic Imaging System) is used to store, view, retrieve, and export the digital ophthalmic images. A standard Halogen light source is used in all RetCam Ophthalmic Imaging Systems to provide illumination to the eye through the handpiece. An optional Fluorescein light source is also available on the RetCam 3 Ophthalmic Imaging System.
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Light intensity, camera focus, and image capture are controlled by the use of the footswitch on all RetCam Ophthalmic Imaging Systems and can also be controlled by a keyboard on the RetCam 3 Ophthalmic Imaging System console. A console monitor is provided with the RetCam 3 Ophthalmic Imaging System for viewing images. The laptop monitor is used with the RetCam Shuttle Ophthalmic Imaging System and RetCam Portable Ophthalmic Imaging System. Proprietary software is installed on the computers to capture, store, view, retrieve, and export ophthalmic images.
## Intended Use/Indications for Use:
- General ophthalmic imaging including retinal, corneal, and external imaging.
- . Photodocumentation of pediatric ocular diseases including retinopathy of prematurity (ROP)
- . Screening for Type 2 pre-threshold retinopathy of Prematurity (ROP) (zone1, stage 1 or 2, without plus disease, or zone 2 stage 3 without plus disease) or treatmentrequiring ROP, defined as Type 1 ROP (zone 1, any stage, with plus disease; zone 1, stage 3 without plus disease; or zone 2, stage 2 or 3, with plus disease) or threshold ROP (at least 5 contiguous or 8 non-contiguous clock hours of stage 3 in zone 1 or 2, with plus disease)* in 35-37 week postmenstrual infants.
## * References:
1. Cryotherapy for Retinopathy of Prematurity Cooperative Group. Multicenter trial of cryotherapy for retinopathy of prematurity: preliminary results. Archives of Ophthalmology 1988; 106(4): 471-479.
2. Early Treatment for Retinopathy of Prematurity Cooperative Group. Revised indications for the treatment of retinopathy of prematurity: results of the Early Treatment for Retinopathy of Prematurity Randomized Trial. Archives of Ophthalmology 2003; 121(12):1684-1694.
## Performance Data:
The modified/subject devices are modified versions of the previously cleared RetCam Ophthalmic Imaging Systems cleared under K090326 (predicate).
The modifications were made to upgrade the camera (due to obsolescence), add DICOM communication features, and update the software to support the modifications. The fundamental scientific technology and indications for use for the modified/subject devices are unchanged.
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The modified/subject RetCam Ophthalmic Imaging Systems have been tested and found to comply with the following recognized consensus standards:
- IEC 60601-1:2005, (MOD) Medical electrical equipment Part 1: General requirements ● for basic safety and essential performance
- . IEC 60601-1-2:2007/(R) 2012 Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances - Requirements and tests
- DICOM (Digital Imaging and Communications in Medicine) -Developed by the . American College of Radiology and the National Electrical Manufacturers Association. NEMA PS 3.1-3.20 (2016)
Natus Medical Inc. followed the FDA guidance document, "Guidance for the content of Premarket Submissions for Software Contained in Medical Devices May 11, 2005," to classify the RetCam Ophthalmic Imaging Systems software as a "moderate level of concern." The software was verified and validated, and the software verification and validation documents were prepared and presented in accordance with FDA's guidance document. Additionally, the modified/subject RetCam Ophthalmic Imaging Systems have been tested internally and met defined acceptance criteria. The tests included:
-Image Comparison Test -Optics verification and Validation Test -ISTA Test
## Substantial Equivalence:
The modified/subject RetCam Ophthalmic Imaging Systems: RetCam 3 Ophthalmic Imaging System, RetCam Shuttle Ophthalmic Imaging System, and RetCam Portable Ophthalmic Imaging System
have the following similarities to the predicate RetCam Ophthalmic Imaging Systems cleared under 510(k) K090326:
- have the same indications for use, ●
- has the same fundamental scientific technology .
- uses the same operating principle ●
- . incorporates the same basic design, and
- incorporates the same materials
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# natus.
| Feature | Modified/Subject DEVICE<br>RetCam Ophthalmic Imaging Systems | PREDICATE DEVICE<br>RetCam Ophthalmic Imaging Systems<br>(K090326) | Similarities or<br>Differences |
|---------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------|
| Indications for Use | -General ophthalmic imaging including<br>retinal, corneal, and external imaging.<br>-Photodocumentation of pediatric ocular<br>diseases including retinopathy of<br>prematurity (ROP)<br>-Screening for Type 2 pre-threshold<br>retinopathy of Prematurity (ROP) (zone1,<br>stage 1 or 2, without plus disease, or zone<br>2 stage 3 without plus disease) or<br>treatment-requiring ROP, defined as Type<br>1 ROP (zone 1, any stage, with plus<br>disease; zone 1, stage 3 without plus<br>disease; or zone 2, stage 2 or 3, with plus<br>disease) or threshold ROP (at least 5<br>contiguous or 8 non-contiguous clock<br>hours of stage 3 in zone 1 or 2, with plus<br>disease)* in 35-37 week postmenstrual<br>infants. | -General ophthalmic imaging including<br>retinal, corneal, and external imaging.<br>-Photodocumentation of pediatric ocular<br>diseases including retinopathy of<br>prematurity (ROP)<br>-Screening for Type 2 pre-threshold<br>retinopathy of Prematurity (ROP) (zone1,<br>stage 1 or 2, without plus disease, or zone<br>2 stage 3 without plus disease) or<br>treatment-requiring ROP, defined as Type<br>1 ROP (zone 1, any stage, with plus<br>disease; zone 1, stage 3 without plus<br>disease; or zone 2, stage 2 or 3, with plus<br>disease) or threshold ROP (at least 5<br>contiguous or 8 non-contiguous clock<br>hours of stage 3 in zone 1 or 2, with plus<br>disease)* in 35-37 week postmenstrual<br>infants. | No changes |
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## natus.
| Feature | Modified/Subject DEVICE<br>RetCam Ophthalmic Imaging Systems | PREDICATE DEVICE<br>RetCam Ophthalmic Imaging Systems<br>(K090326) | Similarities or<br>Differences |
|------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------|
| Principle of Operation | Digital camera in a handpiece with<br>multiple field of view lenses used to<br>capture color ophthalmic images.<br><br>An on board computer (RetCam 3) or<br>laptop computer (RetCam Shuttle and<br>RetCam Portable) is used to store, view,<br>retrieve, and export the digital ophthalmic<br>images.<br><br>A standard Halogen light source is used<br>in all RetCam configurations to provide<br>illumination to the eye through the<br>handpiece. | Digital camera in a handpiece with<br>multiple field of view lenses used to<br>capture color ophthalmic images.<br><br>An on board computer (RetCam 3) or<br>laptop computer (RetCam Shuttle and<br>RetCam Portable) is used to store, view,<br>retrieve, and export the digital ophthalmic<br>images.<br><br>A standard Halogen light source is used in<br>all RetCam configurations to provide<br>illumination to the eye through the<br>handpiece. | No changes |
| Technological Characteristics | | | |
| Eye contact materials | Biocompatible | Biocompatible | No changes |
| Lenses | Coated glass | Coated glass | No changes |
| Handpiece Assembly Shell<br>design | Plastic Shell -2.7 lbs | Plastic Shell -2.7 lbs | No changes |
| Portable Console | | | |
| -RetCam 3 | Plastic Housing -197 lbs | Plastic Housing -197 lbs | No changes |
| -RetCam Shuttle | Aluminum Housing -65 lbs | Aluminum Housing -65 lbs | No changes |
| -RetCam Portable | Plastic Carrying Case -36 lbs or Carrying<br>case -23 lbs | Plastic Carrying Case -36 lbs or Carrying<br>case -23 lbs | No changes |
In summary, the modified/subject RetCam Ophthalmic Imaging Systems:
RetCam 3 Ophthalmic Imaging System,
RetCam Shuttle Ophthalmic Imaging System, and
RetCam Portable Ophthalmic Imaging System
described in this submission are substantially equivalent to the predicate device.
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