K161835 · Myoscience, Inc. · GXH · Mar 24, 2017 · Neurology
Device Facts
Record ID
K161835
Device Name
iovera system
Applicant
Myoscience, Inc.
Product Code
GXH · Neurology
Decision Date
Mar 24, 2017
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 882.4250
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The iovera? system is used to destroy tissue during surgical procedures by applying freezing cold. It can also be used to produce lesions in peripheral nervous tissue by the application of cold to the selected site for the blocking of pain. It is also indicated for the relief of pain and symptoms associated with osteoarthritis of the knee for up to 90 days. The iovera" system is not indicated for treatment of central nervous system tissue.
Device Story
Portable cryogenic surgical device; uses nitrous oxide (N2O) cartridge to cool single-patient-use stainless steel Smart Tip via Joule-Thomson effect/latent heat of vaporization. Handpiece controls cryogen flow to create localized tissue freezing/nerve lesions. Used by clinicians in clinical settings; may be used with off-the-shelf nerve stimulators for precise targeting. Handpiece provides LED feedback during preparation/use. Device destroys unwanted tissue or blocks peripheral nerves to provide pain relief. Benefits include non-systemic, targeted pain management for knee osteoarthritis.
Clinical Evidence
Multi-center, prospective, randomized, double-blind, sham-controlled trial (N=180; 121 treatment, 59 sham). Subjects had Grade II/III knee osteoarthritis. Primary endpoint: superiority in Total WOMAC scale reduction at Day 30 (p=0.001). Treatment group showed 55% improvement vs 33% in sham. Secondary endpoints met: superiority at Day 60 and clinically significant pain relief (30% reduction in WOMAC pain) through 90 days. No serious device/procedure-related adverse events reported.
Technological Characteristics
Cryogenic surgical unit; N2O coolant in pressurized cylinder; reusable battery-powered handpiece; single-use stainless steel Smart Tip (6-55mm length, 25-30 gauge); EO sterilized; Joule-Thomson cooling principle; charging dock; integrated sensors for monitoring delivery and cooling rate.
Indications for Use
Indicated for patients requiring tissue destruction during surgery, peripheral nerve lesioning for pain blocking, and relief of pain/symptoms associated with knee osteoarthritis for up to 90 days. Contraindicated for central nervous system tissue.
Regulatory Classification
Identification
A cryogenic surgical device is a device used to destroy nervous tissue or produce lesions in nervous tissue by the application of extreme cold to the selected site.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
March 24, 2017
Myoscience, Inc. Tracey Henry General Manager 46400 Fremont Blvd Fremont, California 94538
Re: K161835
Trade/Device Name: ioveraº System Regulation Number: 21 CFR 882.4250 Regulation Name: Cryogenic Surgical Device Regulatory Class: Class II Product Code: GXH Dated: February 17, 2017 Received: February 23, 2017
Dear Ms. Henry:
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. 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 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 devicerelated 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 Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. 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 the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours,
Michael J. Hoffmann -S
for
Carlos L. Peña. PhD, MS Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K161835
Device Name ioveraº system
Indications for Use (Describe)
The iovera? system is used to destroy tissue during surgical procedures by applying freezing cold. It can also be used to produce lesions in peripheral nervous tissue by the application of cold to the selected site for the blocking of pain. It is also indicated for the relief of pain and symptoms associated with osteoarthritis of the knee for up to 90 days. The iovera" system is not indicated for treatment of central nervous system tissue.
| Type of Use (Select one or both, as applicable) | |
|----------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------|
| <span style="font-family: DejaVu Sans, sans-serif">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) | <span style="font-family: DejaVu Sans, sans-serif">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) |
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## Section 5: 510(k) Summary
#### Device Information:
| Category | Comments |
|---------------------------------------|-------------------------------------------------------------------------------------------------------------|
| Sponsor / Submitter: | Myoscience, Inc<br>46400 Fremont Blvd<br>Fremont, CA 94538<br>Ph: 510.933.1500<br>Fax: 410.933.1501 |
| Correspondent Contact<br>Information: | Tracey Henry<br>General Manager, Myoscience, Inc<br>Telephone: 510.933.1510<br>Email: thenry@myoscience.com |
| Device Common Name: | Cryogenic surgical device |
| Device Classification & Code: | Class II, GXH |
| Device Classification Name: | Cryosurgical unit and accessories (21 CFR 882.4250) |
| Device Trade Name: | iovera° system |
#### a. Predicate Device Information:
| 510(k) Number | Product | Sponsor |
|---------------|-----------------|-----------------|
| K142866 | iovera o system | Myoscience, Inc |
#### b. Date Summary Prepared
15 February 2017
#### c. Description of Device
The ioveras system is a portable cryogenic surgical device used to destroy tissue and/or produce lesions in nervous tissue creating a nerve block through application of extreme cold to the selected site. The device is based on introduction of a Smart Tip internally cooled by the cryogenic fluid (nitrous oxide, N2O) to a selected area. The Smart Tip is cooled by the Joule-Thomson Effect and/or Latent Heat of Vaporization. The ioveraº system may be used in conjunction with a standard off-the-shelf nerve stimulator device in applications where precise nerve location is desired.
#### Device Design
The device is comprised of four main components:
- 1. A reusable Handpiece
- 2. A Charging Dock
- 3. An assortment of single-patient use Smart Tips
- 4. A Cartridge (Nitrous Oxide)
The iovera Handpiece is battery powered and provides feedback to the user during device preparation and use. The Handpiece connects to both the Cartridge and to the Smart Tip. The user activates a treatment cycle through a control on the Handpiece, which starts and stops the treatment. The Handpiece also contains LEDs for providing feedback to the user when the device is ready to use. The Charging Dock stores the Handpiece between uses and provides power for charging the battery.
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An assortment of Smart Tips is available for the iovera system. All Smart Tip needles are made of stainless steel and have a closed-end that fully contains the cryogen so that it does not enter the target tissue. The Smart Tip is the only patient contacting component of the iovera° system. The user removes the Smart Tip from the sterile packaging and attaches it to the Handpiece.
The ioveras system uses a commercially available nitrous oxide cylinder. The Cartridge is filled with pure N2O.
### Device Functionality/Scientific Concepts
The device functionality is based on the user introducing the Smart Tip to the selected treatment area; unwanted tissue or the target nervous tissue. The user then initiates the flow of cryogen by pressing the on/off button. Liquid cryogen flows from the Handpiece into the closed-end Smart Tip. The Smart Tip is cooled by the Joule-Thomson Effect and/or Latent Heat of Vaporization; as the liquid cryogen expands into a gas, the temperature drops around the external surface of the Smart Tip causing the surrounding tissue to freeze. The treatment is completed after a preprogrammed amount of time at which time the user can safely remove the Smart Tip.
### d. Indications for Use
The iovera system is used to destroy tissue during surgical procedures by applying freezing cold. It can also be used to produce lesions in peripheral nervous tissue by the application of cold to the selected site for the blocking of pain. It is also indicated for the relief of pain and symptoms associated with osteoarthritis of the knee for up to 90 days. The iovera system is not indicated for treatment of central nervous system tissue.
The Indications for Use statement for the subject device has been expanded to include "for the relief of pain and symptoms associated with osteoarthritis of the knee." This additional wording adds specificity to the already cleared indication. Clinical data demonstrate that this specific use does not affect the safety or effectiveness of the iovera system when used as labeled. There were no new questions of safety or effectiveness raised.
#### e. Comparison of Technological Characteristics with the Predicate Device
There are no differences in technological characteristics, as summarized below, and therefore no new or different questions of safety and effectiveness for the subject device are raised.
| Technological Characteristics | |
|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------|
| Predicate Device (K142866) | Subject Device |
| Cryogenic device | Same |
| Nitrous oxide coolant, pressurized cylinder | Same |
| Reusable handpiece, battery powered | Same |
| Single use tip for subdermal cooling, EO sterilized | Same |
| Charging dock | Same |
| Sensors, monitor nitrous oxide deliver and rate of cooling | Same |
| Smart Tip Needle Length: 6 – 55mm (0.2 – 2.2 in) Size: Ø.31 – .72mm (25 – 30 gauge) Patient contacting materials:<br>Closed sharp cutting and blunt tip Stainless Steel needle | Same |
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## f. Performance Data
The following performance data were provided in support of the substantial equivalence determination.
| Bench Testing | No bench testing was necessary for the expanded indications for use. |
|--------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Preclinical<br>Testing<br>Submitted: | No preclinical testing was deemed necessary for the expanded indications for<br>use. |
| Clinical Testing<br>Submitted: | Clinical testing demonstrating the safety and effectiveness of the iovera°<br>system for the relief of pain and symptoms associated with osteoarthritis<br>of the knee was submitted. |
| | Study Design:<br>This was a multi-center, prospective, randomized, double-blind, sham-<br>treatment controlled trial. The treating Investigator and Subject were blinded<br>to study treatment. Each Subject was followed a minimum of 120 days post-<br>treatment. Eligible subjects were diagnosed with Grade II or III osteoarthritis<br>of the knee (Kellgren-Lawrence classification grading scale) and washed out<br>of all pain medication. A local anesthetic was used to create a diagnostic<br>block of the infrapatellar branch of the saphenous nerve, as assessed by a<br>50% decrease in VAS pain upon standing from a seated position or walking<br>up stairs, to confirm that the subject was a candidate for treatment. |
| | 121 subjects were treated with the iovera system and 59 subjects were<br>treated with a sham device, with ages ranging from 36 to 75 years. Data<br>from all 180 subjects enrolled were collected and analyzed. The primary<br>endpoint (superiority of the iovera° treatment over sham treatment for<br>reducing pain and symptoms due to osteoarthritis in the knee as assessed by<br>the Total WOMAC scale from baseline to Day 30) was met, p=0.001.<br>Subjects treated with the iovera° system reported substantially more pain and<br>symptom relief as subjects treated with the sham device (55% improvement<br>versus 33% improvement). |
| | Secondary endpoints were also met, including statistically significant<br>superiority of iovera° treatment over sham treatment for relief of pain and<br>symptoms due to osteoarthritis of the knee on the Total WOMAC scale<br>(pain, stiffness, function) at Day 60 and a statistically significant number of<br>patients reported clinically significant pain relief (30% reduction in<br>WOMAC pain score) through 90 days after treatment with the iovera°<br>system. |
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| | | Iovera<br>treatment<br>group<br>N=121 | Sham<br>control<br>group<br>(n=59) |
|------------------------------------------------------------------------------------------------------------------------|---------|---------------------------------------|------------------------------------|
| Reduction in pain and<br>symptoms on Total WOMAC<br>scale 30 days post-treatment | | -73.311 | -42.18 |
| Percentage of patients<br>reporting 30% improvement<br>in pain and symptoms on<br>Total WOMAC scale post-<br>treatment | 30 days | 74.58% | 44.83% |
| | 60 days | 76.79% | 56.90% |
| | 90 days | 80.18% | 54.39% |
1 LS Means and p-value were obtained by fitting an ANCOVA model with treatment as factor and WOMAC baseline score as a covariate.
There were no serious device-related or procedure-related adverse events. All device-related adverse events were as anticipated per the device labeling. A summary of adverse reactions, including site-specific reactions and/or known effects from cryoanalgesia (e.g., bruising, swelling, redness) which lasted longer than 30 days follows.
| Adverse reactions | Iovera | Sham |
|-----------------------------------------|------------|-----------|
| | N=121 | N=59 |
| Numbness | 18 (14.8%) | 1 (1.7%) |
| Tenderness upon palpation | 14 (11.6%) | 8 (13.6%) |
| Local pain | 8 (6.6%) | 4 (6.8%) |
| Altered sensation/ localized dysethesia | 3 (2.5%) | 2 (3.4%) |
| Tingling | 3 (2.5%) | 1 (1.7%) |
| Swelling | 3 (2.5%) | 3 (5.1%) |
| Bruising | 3 (2.5%) | 2 (3.4%) |
| Itching | 2 (1.6%) | 0 |
| Vasovagal response | 1 (0.8%) | 0 |
| Knee pain | 1 (0.8%) | 2 (3.4%) |
| Redness/inflammation | 1 (0.8%) | 1 (1.7%) |
| Pain, aggravated | 0 | 1 (1.7%) |
#### g. Conclusion
Use of the already cleared ioveraº system in the Clinical Study described herein has shown that the device can be used safely and effectively, within its intended use, to provide relief for pain and symptoms associated with osteoarthritis of the knee. Substantial equivalence to the predicate device has been established, therefore, as there was no change to the intended use or the technological characteristics of the device, and data from the Clinical Study demonstrate safety and efficacy; the primary and secondary endpoints were met and there were no new questions of safety or effectiveness.
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
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.