ZEPTO Precision Capsulotomy System

{0}------------------------------------------------ Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left, there is a symbol representing the Department of Health & Human Services-USA. To the right of the symbol, there is the FDA logo in blue, with the words "U.S. FOOD & DRUG" on the first line and "ADMINISTRATION" on the second line. The logo is simple and professional, reflecting the FDA's role in regulating food and drugs. December 14, 2021 Centricity Vision, Inc. Neal Hartman Vice President, Regulatory Affairs/Quality Assurance 1939 Palomar Oaks Way, Suite A Carlsbad, CA 92011 Re: K210827 Trade/Device Name: ZEPTO Precision Capsulotomy System Regulation Number: 21 CFR 886.4100 Regulation Name: Radiofrequency Electrosurgical Cautery Apparatus Regulatory Class: Class II Product Code: PUL Dated: November 3, 2021 Received: November 5, 2021 Dear Neal Hartman: 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. {1}------------------------------------------------ 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 (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/combination-products/guidance-regulatory-information/postmarketing-safetyreporting-combination-products); 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 titled "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-devices/medical-device-safety/medical-devicereporting-mdr-how-report-medical-device-problems. For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medical-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. for Tieuvi Nguyen, Ph.D. Director DHT1A: Division of Ophthalmic Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health Enclosure {2}------------------------------------------------ ## Indications for Use 510(k) Number (if known) K210827 Device Name ZEPTO Precision Capsulotomy System #### Indications for Use (Describe) ZEPTO Precision Capsulotomy System is indicated for use in performing anterior capsulotomy during cataract surgery. 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) #### CONTINUE ON A SEPARATE PAGE IF NEEDED. This section applies only to requirements of the Paperwork Reduction Act of 1995. #### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.* The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to: > Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov "An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number." {3}------------------------------------------------ Image /page/3/Picture/0 description: The image shows a circular design composed of many small, dark blue, rectangular shapes. These shapes are arranged in a radial pattern, emanating from a central, white circle. The overall effect is reminiscent of a stylized sun or a complex, geometric flower. # Centricity Vision ## K210827 – 510(K) SUMMARY ## Submitter Information | Company Name: | Centricity Vision, Inc. | |--------------------|-------------------------------------------------------------------------------------------------------| | Company Address: | 1939 Palomar Oaks Way, Suite A<br>Carlsbad, CA 92011 | | Company Phone: | (760) 456-5015 | | Company Facsimile: | (760) 579-6116 | | Contact Person: | Neal Hartman<br>Vice President, Regulatory Affairs/Quality Assurance<br>nhartman@centricityvision.com | | Date: | November 22, 2021 | ### Device Identification | Device Trade Name: | ZEPTO Precision Capsulotomy System | |-------------------------|--------------------------------------------------------------------| | Common Name: | Capsulotomy Device | | Classification Name(s): | Apparatus, Cutting, Radiofrequency, Electrosurgical,<br>AC-Powered | | Regulation(s): | 886.4100 | | Device Class: | Class II | | Product Code(s): | PUL | | Advisory Panel: | Ophthalmic | #### ldentification of Predicate Devices The Subject Device is substantially equivalent to the following device: | Device Name | Classification Regulation | Product<br>Code | 510(K)<br>Number | Clearance<br>Date | |-------------|-------------------------------------------------------------------------------|-----------------|------------------|-------------------| | ZEPTO | 886.4100 - Apparatus, Cutting,<br>Radiofrequency, Electrosurgical, AC-Powered | PUL | K170655 | 6/2/2017 | {4}------------------------------------------------ |--|--|--|--|--| #### Device Description The Subject Device consists of a Power Console. Disposable Handbiece, and a disposable Fluid Isolator. The Disposable Handpiece's power cord connector is connected to the front panel of the Power Console to provide power for the capsulotomy procedure. The suction tubing from the Disposable Handpiece is connected to the Fluid Isolator. The Fluid Isolator is then connected to the Power Console's front panel to provide suction during the treatment to a suction cup containing the cutting element. The functional portion used for capsulotomy is the capsulotomy tip located at the distal end of the Disposable Handpiece, which consists of a circular, silicone suction cup, and circular cutting element. Energy pulses are delivered to the cutting element to create the capsulotomy. Prior to conducting the capsulotomy, the Disposable Handpiece's suction line is primed Balanced Salt Solution (BSS). The capsulotomy tip is elongate by sliding the finger slider distally, this allows it to be easy inserted into the anterior chamber through the corneal incision. Once inserted into the anterior chamber the finger slider is pulled back to return the suction cup/cutting element to their original circular shapes. After centering the cutting element at the desired location on the anterior capsule, suction is initiated on the Power Console, which provides vacuum at the capsulotomy tip to properly seat the cutting element to anterior capsule. Once suction is achieved, enerqy is initiated on the Power Console. A series of electrical pulses lasting a total of 4 milliseconds is delivered to the cutting element causing rapid phase transition of water molecules trapped between the bottom edge of the cutting element and the anterior capsule. The rapid volume expansion results in the capsule cutting action. Suction is then vented to atmosphere. The capsulotomy is nominally 5mm. A nurse assistant will, upon command from the physician, introduce a small amount of BSS into the suction cup to allow for a gentle release of the suction cup from the capsule, and to allow the free-floating capsule button to stay behind in the anterior chamber for manual removal with forceps. This is done by advancing the fluid displacement syringe {5}------------------------------------------------ forward. Upon completion of the capsulotomy, the capsulotomy tip is removed from the anterior chamber of the eye through the corneal incision. The Disposable Handpiece with Fluid Isolator is packaged in a sterile barrier thermoform trav. The contents in the sterile barrier are sterile via Ethylene Oxide (EO) sterilization. #### Indications for Use ZEPTO Precision Capsulotomy System is indicated for use in performing anterior capsulotomy during cataract surgery. | Comparison Feature | Subject Device | Predicate Device | |----------------------------------|---------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------| | Device name | ZEPTO Precision Capsulotomy System | ZEPTO | | Manufacturer | Centricity Vision, Inc | Centricity Vision, Inc. (Previously known as Mynosys Cellular Devices, Inc.) | | Device classification | 2 | 2 | | Indications for Use | ZEPTO Precision Capsulotomy System is indicated for use in performing anterior capsulotomy during cataract surgery. | Zepto is indicated for use in performing anterior capsulotomy during cataract surgery. | | System components | Power Console Disposable Handpiece Disposable Fluid Isolator | Power Console Disposable Handpiece Disposable Fluid Isolator | | Patient contact system component | Capsulotomy Tip of the Disposable Handpiece | Capsulotomy Tip of the Disposable Handpiece | | Single-use | Disposable Handpiece Disposable Fluid Isolator | Disposable Handpiece Disposable Fluid Isolator | | Sterile | Disposable Handpiece Disposable Fluid Isolator | Disposable Handpiece | | Method of sterilization, SAL | Ethylene Oxide, SAL 10-6 | Ethylene Oxide, SAL 10-6 | | Packaging, Sterile Barrier | Thermoform Tray/Tyvek Lidding Stock | Tyvek Pouch | | System control component | Power Console | Power Console | | Electrical | 100-240 volts AC, 50-60Hz, 1.66 amps | 100-240 volts AC, 50-60Hz, 1.66 amps | | Energy Type | Rectified RF Pulsed - DC | Rectified RF Pulsed - DC | | Induction of Tensile Stress | By Suction Pressure | By Suction Pressure | | Control Method | Front Panel Footswitch (Wired or Wireless) | Front Panel | | Cutting Element | Circular | Circular | | Comparison Feature | Subject Device | Predicate Device | | Device name | ZEPTO Precision Capsulotomy<br>System | ZEPTO | | Shape | | | | Capsulotomy Size | 5.0mm (nominal) | 5.0mm (nominal) | #### Comparison of Technological Characteristics of Predicate and Subject Devices {6}------------------------------------------------ ### Summary of Testing Performed A program of design verification and validation testing was performed that includes the following: - Biocompatibility ● - Sterility and EO Residual - Packaging Integrity (i.e., Sterile Barrier) ● - Transportation ● - Electromagnetic Compatibility and Electrical Safety - Stability/Shelf-Life - Performance/Functionality/Safety ● - . Software - Simulated Use (Human Factors Evaluation) ● Results of the evaluations demonstrate that the Subject Device met the safety and performance requirements as it relates to its indication for use. #### Conclusions Drawn from Nonclinical Evaluation The results of the evaluation demonstrate that the Subject Device is substantially equivalent to the Predicate Devices as it pertains to the indications for use and device performance.