Canon non-mydriatic retinal camera CR series (CR-2 plus AF and CR-2 AF) is intended to be used for taking digital images of the retina of the human eye without mydriatic. The CR-2 plus AF has the following photography modes: color, red-free, cobalt digital and fundus autofluorescence (FAF). The CR-2 AF has the following photography modes: color, red-free, cobalt digital and additional infrared photography for anterior segment.
Device Story
Canon non-mydriatic retinal camera CR series (CR-2 AF and CR-2 Plus AF) captures digital retinal images; 45-degree field of view; autofocus; automatic shooting; automatic switching from anterior segment to retinal imaging. CR-2 Plus AF includes color, red-free, cobalt, and fundus autofluorescence (FAF) modes; uses Xenon tube light source. CR-2 AF includes color, red-free, cobalt, and infrared anterior segment photography; uses white LED light source. Operated by clinicians in clinical settings. Software (RICS or CU) manages image browsing, processing, storage, and DICOM/JPEG export. Output viewed by healthcare providers to assist in ophthalmic assessment. Benefits include non-mydriatic imaging, reducing patient discomfort and procedure time.
Clinical Evidence
Bench testing only. Includes electrical safety (ANSI/AAMI ES 60601-1), EMC (IEC 60601-1-2), usability (IEC 60601-1-6), and ophthalmic instrument standards (ISO 15004-1, ISO 10940, ANSI Z80.36). Biocompatibility evaluated per ISO 10993. Software validated per FDA guidance.
Technological Characteristics
Ophthalmic camera; 45-degree field of view; 35mm working distance. Light sources: Infrared LED (observation), White LED (CR-2 AF flash), Xenon tube (CR-2 Plus AF flash). Connectivity: DICOM/JPEG export. Software: RICS or CU. Standards: ANSI/AAMI ES 60601-1, IEC 60601-1-2, IEC 60601-1-6, ISO 15004-1, ISO 10940, ANSI Z80.36, ISO 10993.
Indications for Use
Indicated for taking digital images of the human retina without mydriatic. Intended for prescription use.
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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July 23, 2020
Canon Inc. Akira Hirai General Manager 9-1, Imaikami-cho Nakahara-ku, Kawasaki, Kanagawa 211-8501 Japan
Re: K201122
Trade/Device Name: Canon non-mydriatic retinal camera CR series (Model CR-2 AF and CR-2 Plus AF) Regulation Number: 21 CFR 886.1120 Regulation Name: Ophthalmic Camera Regulatory Class: Class II Product Code: HKI Dated: June 18, 2020 Received: June 22, 2020
Dear Akira Hirai:
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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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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
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/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Elvin Ng Acting Assistant Director DHT1A: Division of Ophthalmic Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
# Indications for Use
510(k) Number
K201122
Device Name
Canon non-mydriatic retinal camera CR series (Model CR-2 AF and CR-2 Plus AF)
# Indications for Use (Describe)
Canon non-mydriatic retinal camera CR series (CR-2 plus AF and CR-2 AF) is intended to be used for taking digital images of the retina of the human eye without mydriatic. The CR-2 plus AF has the following photography modes: color, red-free, cobalt digital and fundus autofluorescence (FAF). The CR-2 AF has the following photography modes: color, red-free, cobalt digital and additional infrared photography for anterior segment.
| Type of Use (Select one or both, as applicable) | |
|------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| <span style="text-decoration: underline;"></span> Prescription Use (Part 21 CFR 801 Subpart D) | <span> <svg fill="none" height="16" viewbox="0 0 16 16" width="16" xmlns="http://www.w3.org/2000/svg"> <path d="M5.72727 10.8182L13 3.63636L12.3636 3L5.18182 10.1818L3.63636 8.63636L3 9.27273L5.72727 12L5.72727 10.8182Z" fill="black"></path> </svg> </span> |
| | Over-The-Counter Use (21 CFR 801 Subpart C) |
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#### 510(k) Summary
## Submitter
Canon Inc. 9-1, Imaikami-cho, Nakahara-ku, Kawasaki, Kanagawa 211-8501, Japan
#### Contact person
Mr. Akira Hirai Canon Inc. TEL: 81-3-3758-2111 FAX: 81-44-739-6695 Email: hirai.akira@mail.canon
#### Date prepared
July 21, 2020
Submission type Special 510(k)
## Name of Device
| Trade/Device Name: | Canon non-mydriatic retinal camera CR series (Model CR-2 AF and CR-2 Plus AF) |
|--------------------|-------------------------------------------------------------------------------|
| Regulation Number: | 21 CFR 886.1120 |
| Regulation Name: | Ophthalmic Camera |
| Regulatory Class: | Class II |
| Product Code: | HKI |
## Predicate Device
| K123208 | |
|--------------------|------------------------------------|
| Trade/Device Name: | Digital Retinal Camera CR-2 Plus A |
| Regulation Number: | 21 CFR 886.1120 |
| Regulation Name: | Ophthalmic Camera |
| Regulatory Class: | Class II |
| Product Code: | HKI |
#### Device Description
The Canon non-mydriatic retinal camera CR series is composed of two retinal cameras and its control software and is used for taking digital images of a human retina without mydriatic.
Two retinal cameras: The CR-2 Plus AF and CR-2 AF
- Both models take digital photographic retinal images of patient's eyes across an angle of view of 45 degrees, ● and have autofocus and automatic shooting of retinal image, and automatic switching from anterior segment image to retinal image.
- The CR-2 Plus AF camera is identical to the camera cleared under K123208. The photography mode includes color, red-free, cobalt and fundus autofluorescence (FAF).
- The CR-2 AF camera is modified version of the predicate CR-2 Plus AF (K123208). Most of the specifications are identical to the predicate; however, the photography mode does not include fundus autofluorescence (FAF) photography.
- . Both the CR-2 AF and the CR-2 Plus AF uses infrared light to observe the anterior segment, but CR-2 AF can save such an image.
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Two Software: Retinal image control software (RICS) and Non-myd RC Capture Utility software (CU) programs
- . RICS software program supports browsing, processing, and storage function of the images. It also supports the output of the images to the DICOM storage server, export in DICOM or JPEG format and output to a printer.
- CU software program is a simplified version of RICS, without most of the graphic user interface and the database. It allows user to capture and transfer the retinal images from the retinal camera to the PC.
Both RICS and CU software programs are compatible with both CR-2 AF and CR-2 Plus AF cameras.
# Indications for Use
Canon non-mydriatic retinal camera CR series (CR-2 plus AF and CR-2 AF) is intended to be used for taking digital images of the retina of the human eye without mydriatic. The CR-2 plus AF has the following photography modes: color, red-free, cobalt digital and fundus autofluorescence (FAF). The CR-2 AF has the following photography modes: color, red-free, cobalt digital and additional infrared photography for anterior segment.
The Indication for Use for predicate device, Digital Retinal Camera CR-2 Plus AF is the follows:
"The Digital Retinal Camera CR-2 Plus AF is intended to be used for taking digital images of the retina of the human eye without a mydriatic. The CR-2 Plus AF has the following photography modes: color, red free, cobalt digital and fundus autofluorescence (FAF)."
It appears the intended for use of Canon non-mydriatic retinal camera CR series and predicate device is identical.
# Discussion of Substantial Equivalence
The CR-2 AF is modified from the predicate CR-2 Plus AF (K123208) and most of the specifications are identical to the predicate CR-2 Plus AF, the major differences are in the following aspects:
- The photography mode: The CR-2 AF has the following photography modes: color, red-free, cobalt . and infrared photography for anterior segment. The CR-2 AF doesn't have the fundus autofluorescence photography (FAF) mode while the CR-2 Plus AF (K123208) has.
- . The light source: The CR-2 Plus AF (K123208) needs to equip a large power supply box, capacitor and Xenon tube for the FAF photography because the FAF photography needs high light intensity for photographing images but the CR-2 AF doesn't have FAF photography feature and therefore the CR-2 AF adopts a White LED as a light source, whose output is lower than that of Xenon tube.
It is verified that there is no new risk associated with the light source change. The light hazard protection evaluation of CR-2 AF was evaluated to meet the eye safety limits of the Group 1 instrument based on ANSI Z80.36:2016 - Ophthalmics - Light Hazard Protection for Ophthalmic Instruments.
- The graphic user interface: Software CU is derived from the RICS by modifying the graphic user interface and removing the database from the RICS. CU can save the retinal images to the designated folder to transfer the images to the 3rd party software.
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Therefore, the above differences between the proposed device device do not affect the basic design principle, usage, effectiveness and safety of use of the subject device.
| | Differences between both retinal camera models are shown in Table below. | | |
|--|--------------------------------------------------------------------------|--|--|
| | | | |
| | | Proposed | Predicate |
|-------------------------------|------------------------------------|----------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Device Name | | CR-2 AF | CR-2 Plus AF |
| 510(k) Submitter<br>[Number] | | Canon Inc.<br>K201122 | Canon Inc.<br>[K123208] |
| Product Code | | HKI | HKI |
| Indications for Use | | The CR-2 AF is intended to be used for taking<br>digital images of the retina of the human eye<br>without mydriatic. | The CR-2 Plus AF is intended to be used for<br>taking digital images of the retina of the<br>human eye without mydriatic.<br>The CR-2 Plus AF has the following<br>photography modes: color, red free, cobalt<br>digital and fundus autofluorescence (FAF). |
| Device design | | | |
| Light<br>source | Observation<br>Flash | Infrared LED<br>White LED | Infrared LED<br>Xenon tube |
| Angular field of view | | 45/43 ° (digital magnification)<br>(35°when S.P switch is ON) | 45/43 ° (digital magnification)<br>(35°when S.P switch is ON) |
| Actual image size | | cp13.7 mm (on sensor array) | cp13.7 mm (on sensor array) |
| | Min. diameter of pupil<br>required | cp4mm<br>(cp3.3mm when S.P switch is ON) | cp4mm<br>(cp3.3mm when S.P switch is ON) |
| | Working distance (WD) | 35mm | 35mm |
| Focusing and<br>Photographing | | Focusing by aligning the split lines<br>automatically and photographing<br>automatically | Focusing by aligning the split lines<br>automatically and photographing<br>automatically |
| Switching function | | Automatically Switching function from<br>anterior segment to fundus after anterior<br>segments is aligned. | Automatically Switching function from<br>anterior segment to fundus after anterior<br>segments is aligned. |
| Photography mode | | color, red free, cobalt digital and infrared for<br>anterior segment | color, red free, cobalt digital and fundus<br>autofluorescence (FAF) |
| Anterior segment | | Observation and capture | Observation |
| Eye fixation lamp | | Internal (during observation of eye front<br>image and retinal image),<br>External | Internal (during observation of eye front<br>image and retinal image),<br>External |
| External dimensions | | W305×D500×H473mm | W305×D500×H513mm |
| Weight | | Approx.15kg | Approx.19.9kg |
| Control software | | Selectable from the followings:<br>Retinal imaging control software;<br>Non-myd RC Capture Utility | Retinal imaging control software |
## Performance Data
Non-clinical tests including Electrical safety, Electromagnetic Compatibility, Performance testing, and Software Verification and Validation were conducted to evaluate safety and effectiveness of the CR-2 AF. The CR-2 AF complies with the Recognized Consensus Standard, specifically ANSI/AAMI ES 60601-1. IEC 60601-1-2. IEC 60601-1-6. ISO 15004-1, ISO 10940 and ANSI Z80.36. A qualitative assessment of the function of the anterior segment infrared image for CR-2 AF camera has been performed. The contact parts with patient in the CR-2 AF are the same materials as those used in the predicate device CR-2 Plus AF (K123208) and have been evaluated according to ISO10993 series that is concluded to have no new biocompatibility concern. The software was validated according to the FDA Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices (May 2005).
# Conclusion
Based on the performance data, identical intended use and functional technological characteristics and the similarities in functional design, the proposed CR-2 AF is substantially equivalent to the CR-2 Plus AF (K123208) and does not raise any new questions regarding safety and effectiveness.
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