CIRRUS HD-OCT WITH RETINAL NERVE FIBER LAYER AND MACULAR NORMATIVE DATABASES, MODEL 4000
K083291 · Carl Zeiss Meditec, Inc. · OBO · May 5, 2009 · Ophthalmic
Device Facts
Record ID
K083291
Device Name
CIRRUS HD-OCT WITH RETINAL NERVE FIBER LAYER AND MACULAR NORMATIVE DATABASES, MODEL 4000
Applicant
Carl Zeiss Meditec, Inc.
Product Code
OBO · Ophthalmic
Decision Date
May 5, 2009
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 886.1570
Device Class
Class 2
Attributes
Real-World Evidence
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K083291 · May 5, 2009
CIRRUS HD-OCT WITH RETINAL NERVE FIBER LAYER AND MACULAR NORMATIVE DATABASES, MODEL 4000
Carl Zeiss Meditec, Inc.
Normative database of 284/282 subjects; Published clinical literature (Vizzeri et al., 2009)
The normative database was used to establish reference ranges for retinal nerve fiber layer and macular thickness. Published literature was used to support the repeatability and reproducibility of the device measurements in normal and patient eyes.
Cirrus RNFL and Macula Normative Databases; Normative database development
284 subjects (RNFL) and 282 subjects (Macula), aged 19-84; Sample Size: 566 total; Number of Sites: 7
Not applicable for this study
Retinal nerve fiber layer and macular thickness normative values
Independent study (Vizzeri et al.); Observational clinical study
Normal subjects and patient eyes
Not applicable for this study
Repeatability standard deviation
Indications for Use
The Cirrus™ HD-OCT with Retinal Nerve Fiber Layer and Macular Normative Databases is indicated for in-vivo viewing, axial cross-sectional, and threedimensional imaging and measurement of anterior and posterior ocular structures. The Cirrus™ HD-OCT is a non-contact, high resolution tomographic and biomicroscopic imaging device. It is indicated for in-vivo viewing, axial cross-sectional, and three-dimensional imaging and measurement of anterior and posterior ocular structures, including cornea, retinal nerve fiber layer, macula, and optic disc. The Cirrus HD-OCT with Retinal Nerve Fiber Layer (RNFL) and Macular Normative Database is a quantitative tool for the comparison of retinal nerve fiber layer and the macula in the human retina to a database of known normal subjects. It is intended for use as a diagnostic device to aid in the detection and management of ocular diseases including, but not limited to, macular holes, cystoid macular edema, diabetic retinopathy, age-related macular degeneration, and glaucoma.
Device Story
Computerized, non-contact, high-resolution tomographic imaging instrument; employs low-coherence interferometry to acquire cross-sectional ocular images. Used in clinical settings by eye care professionals. Device processes raw optical data to generate cross-sectional tomograms and 3D images of anterior/posterior ocular structures. Includes automated segmentation algorithms for retinal layers (ILM, RPE) and normative databases for quantitative comparison of RNFL and macular thickness. Output displayed to clinicians to aid diagnosis and management of retinal pathologies and glaucoma. Benefits include non-invasive visualization and objective, quantitative assessment of ocular structures.
Clinical Evidence
Bench testing and clinical evaluation performed. Repeatability/reproducibility studies on 32 normal subjects showed RNFL measurement SDs of 1.33-3.42 µm. Retinal segmentation accuracy evaluated in 370 subjects across six pathology groups (AMD, DR, VRI, etc.); segmentation agreement with manual grading was high (85.7%-100% depending on layer/pathology). Agreement with Stratus OCT showed Pearson correlation of 0.953 for RNFL, though measurements are not interchangeable due to different segmentation strategies. Central corneal thickness repeatability/reproducibility also assessed.
Technological Characteristics
Non-contact, low-coherence interferometry imaging system. Measures anterior and posterior ocular structures. Includes normative databases for RNFL and macula (age-adjusted). Software-based segmentation of ILM and RPE layers. Standalone instrument form factor.
Indications for Use
Indicated for in-vivo viewing, axial cross-sectional, and 3D imaging/measurement of anterior and posterior ocular structures (cornea, RNFL, macula, optic disc) in humans. Used as a diagnostic aid for detection and management of ocular diseases including macular holes, cystoid macular edema, diabetic retinopathy, age-related macular degeneration, and glaucoma. Includes normative database comparison for RNFL and macula.
Regulatory Classification
Identification
An ophthalmoscope is an AC-powered or battery-powered device containing illumination and viewing optics intended to examine the media (cornea, aqueous, lens, and vitreous) and the retina of the eye.
Special Controls
*Classification.* Class II (special controls). The device, when it is an AC-powered opthalmoscope, a battery-powered opthalmoscope, or a hand-held ophthalmoscope replacement battery, 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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K083291
### 510(K) SUMMARY
### 510(k) SUMMARY (per 21 CFR §807.92)
MAY - 5 2009
### Cirrus HD-OCT with Retinal Nerve Fiber Layer and Macular Normative Databases
### GENERAL INFORMATION
| Manufacturer: | Carl Zeiss Meditec, Inc.<br>5160 Hacienda Drive<br>Dublin, California 94568<br>(925) 557-4616 (phone)<br>(925) 557-4259 (fax)<br>Est. Reg. No. 2918630 |
|-------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Judith A. Brimacombe, MA<br>Director, Regulatory/Clinical Affairs<br>Carl Zeiss Meditec Inc.<br>5160 Hacienda Drive<br>Dublin, California 94568<br>(925) 557-4616 (phone)<br>(925) 557-4259 (fax) |
| Classification name: | Tomography, Optical Coherence; Ophthalmoscope |
| Classification: | Class II (acc. 21 CFR 886.1570) |
| Product Code: | OBO |
| Trade/Proprietary name: | Cirrus HD-OCT with Retinal Nerve Fiber Layer (RNFL)<br>and Macular Normative Databases |
| PREDICATE DEVICES | |
| Company:<br>Device: | Carl Zeiss Meditec, Inc.<br>Cirrus™ HD-OCT (K063378) |
| Company:<br>Device: | Carl Zeiss Meditec, Inc.<br>StratusOCT™ with Retinal Nerve Fiber Layer (RNFL) &<br>Macula Normative Database (K033123) |
| Company:<br>Device: | Carl Zeiss Meditec, Inc.<br>Visante OCT (K051789) |
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### INTENDED USE
The Cirrus™ HD-OCT with Retinal Nerve Fiber Layer and Macular Normative Databases is indicated for in-vivo viewing, axial cross-sectional, and threedimensional imaging and measurement of anterior and posterior ocular structures.
### INDICATIONS FOR USE
The Cirrus™ HD-OCT is a non-contact, high resolution tomographic and biomicroscopic imaging device. It is indicated for in-vivo viewing, axial crosssectional, and three-dimensional imaging and measurement of anterior and posterior ocular structures, including cornea, retinal nerve fiber layer, macula, and optic disc. The Cirrus HD-OCT with Retinal Nerve Fiber Layer (RNFL) and Macular Normative Database is a quantitative tool for the comparison of retinal nerve fiber layer and the macula in the human retina to a database of known normal subjects. It is intended for use as a diagnostic device to aid in the detection and management of ocular diseases including, but not limited to, macular holes, cystoid macular edema, diabetic retinopathy, age-related macular degeneration, and glaucoma.
### DEVICE DESCRIPTION
The Cirrus™ HD-OCT is a computerized instrument that acquires and analyzes crosssectional tomograms of anterior and posterior ocular structures (including cornea, retina, retinal nerve fiber layer, macula, and optic disc). It emplovs non-invasive, non-contact, low-coherence interferometry to obtain these high-resolution images. Using this non-invasive optical technique. Cirrus HD-OCT produces high-resolution cross-sectional tomograms of the eye without contacting the eye.
#### SUBSTANTIAL EQUIVALENCE
It is the opinion of Carl Zeiss Meditec, Incorporated that the Cirrus HD-OCT with Retinal Nerve Fiber Layer and Macular Normative Databases is substantially equivalent to the Cirrus HD-OCT, Stratus OCT with RNFL and Macula Normative Databases and to the Visante OCT. The indications for use for the Cirrus HD-OCT with Retinal Nerve Fiber Layer and Macular Normative Databases is similar to the indications for the predicate devices cited in this application. A technological comparison and clinical testing demonstrate that the Cirrus HD-OCT with Retinal Nerve Fiber Layer (RNFL) and Macular Normative Database is functionally equivalent to the predicate devices.
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Evaluation performed on the Cirrus HD-OCT with Retinal Nerve Fiber Layer and Macular Normative Databases supports the expanded indications for use statement and demonstrates that the device is substantially equivalent to the predicate devices and does not raise new questions regarding safety and effectiveness.
### CLINICAL EVALUATION
Clinical data was collected and evaluated to support the indications for use statement for the Cirrus HD-OCT with Retinal Nerve Fiber Layer and Macular Normative Databases and to demonstrate substantial equivalence to the Cirrus HD-OCT, the Stratus OCT with RNFL and Macula Normative Databases as well as to the Visante OCT. Three of these studies are summarized below.
### RNFL Repeatability and Reproducibility
An in-house study was performed on 32 normal subjects to determine the inter-visit and inter-instrument repeatability of Cirrus RNFL thickness measurements. The repeatability and reproducibility (including effects of multiple visits and multiple instruments), along with mean thickness, are shown in the table below. Similar results were also found in an independent study, with a repeatability standard deviation of 1.3 um in normal subjects and 1.2 um in patient eves'.
Table 1. Mean thickness. Repeatability and Reproducibility of Cirrus RNFL measurements for five sectors, including the overall average thickness, four quadrants (temporal, superior, nasal, and inferior), measured on 32 normal subjects.
| | Mean<br>Thickness<br>(μm) | Repeatability<br>SD<br>(μm) | Reproducibility<br>SD<br>(μm) | Repeatability<br>Limita<br>(μm) | Reproducibility<br>Limitb<br>(μm) |
|----------|---------------------------|-----------------------------|-------------------------------|---------------------------------|-----------------------------------|
| Average | 93.0 | 1.33 μm | 1.35 μm | 3.72 μm | 3.78 μm |
| Temporal | 64.6 | 2.03 μm | 2.05 μm | 5.68 μm | 5.74 μm |
| Superior | 118.8 | 3.42 μm | 3.45 μm | 9.58 μm | 9.66 μm |
| Nasal | 68.6 | 2.19 μm | 2.24 μm | 6.13 μm | 6.27 μm |
| Inferior | 123.6 | 3.01 μm | 3.14 μm | 8.43 μm | 8.79 μm |
a. Repeatability Limit is the upper 95% limit for the difference between repeated results. Per ISO 5725-1 and ISO 5725-6, Repeatability Limit = 2.8 x Repeatability SD.
b. Reproducibility Limit is the upper 95% limit calculated for the difference between results repeated with different operators on different instruments. Each subject was imaged by a single operator twice during a single visit on five instruments (Phase 1) or three times each during three visits on a single instrument (Phase 2). Per ISO 5725-1 and ISO 5725-6, Reproducibility limit = 2.8 x Reproducibility SD.
<sup>4</sup> Vizzeri, G, Weinreb, RN, Gonzalez-Garcia, AO, Bowd, C, Medeiros, F, Sample, PA, Zangwill, LM: Agreement between spectral-domain and time-domain OCT for measuring RNFL thickness, Br J Ophthalmol, March 2009.
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### RNFL Agreement with Stratus OCT
A recent study of normal subjects and patients (N = 130) found that although there were differences between Stratus and Cirrus, the Pearson correlation coefficient for the average RNFL thickness was 0.953, indicating good correlation. However, they also found differences between Cirrus and Stratus RNFL measurements. Cirrus measured thicker than Stratus for thinner RNFL values, and measured thinner than Stratus for thicker (more normal) RNFL values. Measurements from the two systems should not be used interchangeably.
### Retinal Segmentation Accuracy
A study was conducted at four sites to evaluate the accuracy and precision of the Cirrus HD-OCT retinal thickness segmentation algorithms and to evaluate the agreement between the resulting measurements and similar measurements made on Stratus OCT.
Both eyes of 370 subjects were scanned, with one eye being chosen as the study eye based on eligibility guidelines. Subjects were classified into the six groups based on the primary diagnosis causing the most pathologic abnormalities in the study eve as follows:
Group 1 - age-related macular degeneration (AMD),
Group 2 - diabetic retinopathy (DR).
Group 3 - vitreoretinal interface abnormalities (including macular holes),
Group 4 - other retinal pathology.
Group 5 - macular edema for which treatment was planned,
Group 6 - no retinal pathology.
Any subjects with a primary diagnosis that placed them within Groups 1 through 4. for whom treatment of macular edema was scheduled, were categorized into Group 5.
Two 200 x 200 scans and two 512 x 128 scans of the study and fellow eyes were acquired using the Cirrus SD-OCT instrument during a single visit. Retinal thickness in every subfield was calculated (based on the ETDRS 6 mm grid centered on the fovea).
The Cirrus inner limited membrane (ILM) and retinal pigment epithclium (RPE) segmentations were deemed accurate if software-segmentations and handsegmentations agreed for 100% of the A-scans that were evaluated, where agreement was defined as being within 16 um for the central 1mm of the scan and within 32 um
<sup>2</sup> O.J. Knight, R.T. Chang, W.J. Feuer, D.L. Budenz, "Comparison of Retinal Nerve Fiber Laver Measurements Using Stratus OCT and Cirrus Spectral Domain OCT," Poster 4628, ARVO 2008
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elsewhere in the scan. The accuracy of segmentation was found to depend on layer (RPE or ILM) and disease category, and is summarized below in Tables 2 and 3.
| Category | | 200x200 | 512x218 | |
|--------------------------|-------------------|----------------|-------------------|----------------|
| | n/N (%) | 95% CI | n/N (%) | 95% CI |
| AMD | 60/70<br>(85.7%) | (77.5%, 91.3%) | 62/72<br>(86.1%) | (78.1%, 98.5%) |
| Diabetic<br>Retinopathy | 40/42<br>(95.2%) | (86.6%, 98.4%) | 41/42<br>(97.6%) | (90.0%, 99.5%) |
| VRI Disorder | 27/28<br>(96.4%) | (85.5%, 99.2%) | 25/28<br>(89.3%) | (76.0%, 95.5%) |
| Other Retinal<br>Disease | 44/51<br>(86.3%) | (76.5%, 92.4%) | 46/52<br>(88.5%) | (79.2%, 93.9%) |
| Macular Edema | 27/28<br>(96.4%) | (85.5%, 99.2%) | 27/29<br>(93.1%) | (82.2%, 97.7%) |
| No Retinal<br>Disease | 37/37<br>(100.0%) | (93.2%, 100%) | 40/40<br>(100.0%) | (93.7%, 100%) |
### Table 2. Accuracy of segmentations for RPE layer by pathology category
| Table 3. Accuracy of segmentations for II M layer by pathology category | | | | |
|-------------------------------------------------------------------------|-------------------|----------------|-------------------|----------------|
| Category | 200x200 | | 512x218 | |
| | n/N (%) | 95% CI | n/N (%) | 95% CI |
| AMD | 68/70<br>(97.1%) | (91.7%, 99.1%) | 73/74<br>(98.6%) | (94.2%, 99.7%) |
| Diabetic<br>Retinopathy | 40/42<br>(95.2%) | (86.6%, 98.4%) | 40/42<br>(95.2%) | (86.6%, 98.4%) |
| VRI Disorder | 26/28<br>(92.9%) | (80.6%, 97.6%) | 26/27<br>(96.3%) | (85.0%, 99.2%) |
| Other Retinal<br>Disease | 50/51<br>(98.0%) | (91.7%, 99.6%) | 51/52<br>(98.1%) | (91.8%, 99.6%) |
| Macular Edema | 28/28<br>(100.0%) | (91.2%, 100%) | 28/29<br>(96.6%) | (85.9%, 99.2%) |
| No Retinal<br>Disease | 37/37<br>(100.0%) | (93.2%, 100%) | 40/40<br>(100.0%) | (93.7%, 100%) |
### Retinal Segmentation Precision
The repeatability of Cirrus HD-OCT retinal thickness measurements varied with pathology. Table 4 shows the repeatability standard deviation for each disease category for the central subfield average thickness. Repeatability can be improved by
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ensuring that two scans are registered to each other, as when the Macular Change Analysis is used. Repeatability can also be improved using the Macular Thickness Analysis when the fovea is correctly identified and used as the reference point for subfield average thickness calculations. These repeatability improvements are also shown in Table 4.
Table 4. Repeatability Standard Deviation" in micrometers for central subfield macular thickness (CSMT) measurements on the 200x200 scan using Macular Thickness Analysis (MTA), MTA with the ability to adjust the fovea position, and Macular Change Analysis (MCA), which uses registration and fovea placement. The total number of subjects for each disease category, and their means and standard deviations (SD) are also shown for reference.
| Category | N | Mean ± SD<br>CSMT (µm)<br>for Cirrus 4.0<br>MTA | Central Subfield Macular Thickness<br>Repeatability<br>Standard Deviation (µm) | | |
|--------------|----|-------------------------------------------------|--------------------------------------------------------------------------------|----------------------------------------------|------------------------------------------------------------------|
| | | | Cirrus 3.0<br>MTA | Cirrus 4.0<br>MTA with<br>Fovea<br>Placement | Cirrus 4.0<br>MCA with<br>Registration<br>and Fovea<br>Placement |
| AMD | 77 | $255 \pm 65$ | 17.5 | 6.3 | 8.7 |
| DR | 51 | $335 \pm 109$ | 16.8 | 9.8 | 8.1 |
| VRI Disorder | 44 | $360 \pm 128$ | 14.4 | 5.4 | 4.3 |
| Other | 62 | $303 \pm 114$ | 10.1 | 7.5 | 4.5 |
| ME | 41 | $339 \pm 141$ | 13.5 | 7.9 | 7.0 |
| No Disease | 44 | $256 \pm 21$ | 4.8 | 2.2 | 2.5 |
a. Repeatability Limit is the upper 95% limit for the difference between repeated results. For this study, two scans were acquired per subject during a single visit on a single system by a single operator at one of four sites. Per ISO 5725-1 and ISO 5725-6, Repeatability limit = 2.8 x Repeatability SD.
### Retinal Thickness Measurements: Agreement with Stratus
The segmentation algorithms in Cirrus HD-OCT and Stratus OCT are designed to search for different layers. Specifically, Stratus OCT locates the top of the bright reflective layer that is now known to represent the junction between inner and outer segments of the photoreceptors as the lower boundary of the retinal for its thickness calculations; Cirrus locates the brightest layer in the retinal pigment epithelium (RPE)/outer segment complex, which is thought to correspond to the RPE.
Because of this difference in segmentation strategy, there is a mean difference in the retinal thickness found by each instrument. Because the integrity of the layers sought varies with pathology, the mean difference between instruments varies with pathology, as can be seen in Table 5. Even after the mean difference has been accounted for, there is a residual difference that can be seen in the standard deviation of the difference reported in the last column of Table 5. Because of the residual
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difference, for an individual patient, it is better to compare scans between Stratus and Cirrus qualitatively, looking for changes in retinal morphology, rather than making decisions based on quantitative evaluation.
Table 5. Difference between Cirrus HD-OCT and Stratus OCT for the Central Subfield Mean Thickness for each of six categories of pathology
| Category | N | Mean (SD) Difference Cirrus – Stratus (µm) | Cirrus | Stratus | Difference |
|-------------------------|----|--------------------------------------------|---------------|---------------|-------------|
| AMD | 63 | | 271.3 (60.6) | 217.7 (54.2) | 53.6 (35.0) |
| Diabetic<br>Retinopathy | 39 | | 356.6 (118.7) | 316.6 (135.8) | 40.0 (47.1) |
| VRI Disorder | 45 | | 386.3 (128.0) | 342.5 (125.0) | 43.8 (35.9) |
| Other | 53 | | 310.6 (99.5) | 268.9 (101.6) | 41.7 (47.1) |
| Macular Edema | 35 | | 351.1 (140.3) | 305.7 (127.9) | 45.5 (45.3) |
| Normal | 48 | | 256.1 (18.6) | 196.7 (18.6) | 59.4 (11.7) |
### RNFL and Macula Normative Databases
The Cirrus RNFL and Macula normative databases were developed utilizing 284 subjects (aged 19-84) and 282 subjects (aged 19-84): respectively, collected from seven sites. The normative databases have a similar gender distribution (134 males. 150 females and 133 males, 149 females; respectively). Ethnicity breakdown of the Cirrus RNFL and Macula normative databases is as follows: 43% Caucasians, 24% Asians, 18% African American, 12% Hispanic, 1% Indian, and 6% mixed ethnicity. Note that Cirrus RNFL and Macula normative databases are adjusted only by age, not by axial length, refraction, optic disc area, signal strength or any other parameter.
Results revealed that the mean difference in the average thickness between any two race groups is within 6 um Caucasians have thinner mean average thickness, superior quadrant average, and inferior quadrant average. Asians seem to have thinner mean nasal quadrant average and thicker temporal quadrant average. The largest difference in the RNFL thickness between two race groups is for the temporal quadrant average between Asian and African American, with a difference of 16 um. The normative limits do not take into account differences that may be present due to ethnicity.
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### Central Corneal Thickness Measurements
A study was conducted to determine repeatability and reproducibility of the Cirrus HD-OCT instrument measurements of central comeal thickness (CCT). Phase I of the study enrolled 28 subjects and was designed to determine inter-device variability. wherein each subject was imaged 3 times during a single visit on each of three Cirrus OCT instruments by one operator. Phase II enrolled 22 subjects and was designed to determine inter-operator variability, wherein cach subject was imaged three times during a single visit by each of three operators. Phases I and II enrolled different subjects.
The Cirrus HD-OCT repeatability and reproducibility are shown in Table 6. Mean thickness of each phase and overall (Phase I and II combined) are also shown. Since the random error variability from Phase II of the study was larger than that from Phase I, the variance components from Phase II were used to estimate the random measurement variability and the repeatability standard deviation.
| | | Table 6. Repeatability and reproducibility of central corneal thickness measurements |
|--|--|--------------------------------------------------------------------------------------|
|--|--|--------------------------------------------------------------------------------------|
| Cirrus HD-OCT<br>Repeatabilitya | Cirrus HD-OCT<br>Reproducibilityb | Mean Thickness | | | | |
|---------------------------------|-----------------------------------|----------------|----------------|-----------------|------------------|-----------------|
| SD<br>(μm) | Limits<br>(μm) | SD<br>(μm) | Limits<br>(μm) | Phase I<br>(μm) | Phase II<br>(μm) | Overall<br>(μm) |
| 4.08 | 11.42 | 4.23 | 11.84 | 544.25 | 532.25 | 538.25 |
a. Repeatability Limit is the upper 95% limit for the difference between repeated results. Per ISO 5725-1 and ISO 5725-6, Repeatability Limit = 2.8 x Repeatability SD.
b. Reproducibility Limit is the upper 95 % limit calculated for the difference between results repeated using different operators. Lach subject was imaged three times during a single visit by each of three operators. Per ISO 5725-1 and ISO 5725-6, Reproducibility Limit = 2.8 x Reproducibility SD.
### Difference in Central Corneal Thickness Measurement between Cirrus HD-OCT and Ultrasound Pachymetry
A study was conducted to determine the difference in central corneal thickness measurement between Cirrus HD-OCT and ultrasound pachymctry. A total of 50 eyes were enrolled at one site and measured by a single operator for each device. The results of this study, provided in Table 7, show that the mean difference in central corneal thickness measurements between Cirrus HD-OCT and ultrasound pachymetry is -9.06. The negative difference indicates that the Cirrus CCT measurement is thinner than the ultrasound CCT measurement. OCT devices in gencral measure thinner than ultrasound pachymetry. The Visante OCT user
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manual reports that Visante OCT measurements are thinner, on average, by 15.1 microns as compared to ultrasound pachymetry.
### Table 7. Difference in Central Corneal Thickness Measurement between Cirrus HD-OCT and Ultrasound Pachymetry
| | Mean<br>Difference | SD | 95% CI of the<br>Difference | |
|-----------------------------------------------------|--------------------|------|-----------------------------|-------|
| | | | Lower | Upper |
| Cirrus CCT-<br>Ultrasound<br>pachymetry CCT<br>(μm) | -9.06 | 5.63 | -10.66 | -7.46 |
### SUMMARY
As described in this 510(k) Summary, all testing deemed necessary was conducted on the Cirrus HD-OCT with Retinal Nerve Fiber Layer and Macular Normative Databases to ensure that the device is safe and effective for its intended use when used in accordance with its Instructions for Use.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/9/Picture/1 description: The image shows the seal of the Department of Health & Human Services, USA. The seal features a stylized eagle with its wings spread, symbolizing protection and service. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES, USA" are arranged in a circular pattern around the eagle.
MAY - 5 2009
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Public Health Service
Carl Zeiss Meditec, Inc. c/o Judith A. Brimacombe Director, Clinical & Regulatory Affairs Carl Zeiss Meditec, Inc. 5160 Hacienda Blvd. Dublin, CA 94568
Re: K083291
Trade/Device Name: Cirrus HD-OCT with Retinal Nerve Fiber Layer and Macular Normative Databases, Model 4000
Regulation Number: 21 CFR 886.1570 Regulation Name: Ophthalmoscope Regulatory Class: II Product Code: OBO Dated: April 15, 2009 Received: April 16, 2009
Dear Ms. Brimacombe:
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. 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.
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 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); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Center for Devices and Radiological Health's (CDRH's) Office of Compliance at (240) 276-0115. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please contact the CDRH/Office of Surveillance and Biometrics/Division of Postmarket Surveillance at 240-276-3464. For more information regarding the reporting of adverse events, please go to http://www.fda.gov/cdrh/mdr/.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely yours,
Malvina B. Egleston, mD.
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 STATEMENT
#### INDICATIONS FOR USE STATEMENT
510(k) Number (if known): K083291
Device Name: Cirrus HD-OCT with Retinal Nerve Fiber Layer (RNFL) and Macular Normative Databases
Indications for Use:
The Cirrus™ HD-OCT is a non-contact, high resolution tomographic and biomicroscopic imaging device. It is indicated for in-vivo viewing, axial cross-sectional, and threedimensional imaging and measurement of anterior and posterior ocular structures, including cornea, retinal nerve fiber layer, macula, and optic disc. The Cirrus HD-OCT with Retinal Nerve Fiber Layer (RNFL) and Macular Normative Databases is a quantitative tool for the comparison of retinal nerve fiber layer and the macula in the human retina to a database of known normal subjects. It is intended for use as a diagnostic device to aid in the detection and management of ocular diseases including, but not limited to, macular holes, cystoid macular edema, diabetic retinopathy, agerelated macular degeneration, and glaucoma.
Prescription Use x (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Daryl L. Kaufman
(Division Sign-Off) Division of Ophthalmic and Ear, Nose and Throat Devices
510(k) Number K083291
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Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
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.