Department of Health & Human Services
Department of Health & Human Services
Department of Health & Human Services
October 6, 2015
Re: K151613
Trade/Device Name: Ilab Polaris Multi-modality Guidance System
Regulation Number: 21 CFR 870.1425
Regulation Name: Programmable Diagnostic Computer
Regulatory Class: Class II
Product Code: DQK, DSK, IYO, ITX
Dated: September 3, 2015
Received: September 4, 2015
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 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.
Page 2 - Ms. Arlene Roche
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
S ce e y you
yours,
y s,
forB
Bram DD. Z
Zuckerman,
k M.D.
M
Director
Division of Cardiovascular Devices
Office of Device Evaluation
Center for Devices and Radiological Health
Enclosure
DEPARTMENT OF HEALTH AND HUMAN SERVICES Form Approved: OMB No. 0910-0120
Food and Drug Administration Expiration Date: January 31, 2017
Indications for Use See PRA Statement below.
Device Name
iLab™ Polaris Multi-Modality Guidance System
Intravascular ultrasound is indicated in patients who are candidates for transluminal interventional procedures such as
angioplasty and atherectomy.
The FFR modality of the iLab Polaris Multi-Modality Guidance System is intended for use in catheterization and related
cardiovascular specialty laboratories to compute, and display various physiological parameters based on the output from
one or more electrodes, transducers or measuring devices.
This modality is indicated to provide hemodynamic information for use in the diagnosis and treatment of patients that
undergo measurement of physiological parameters, Fractional Flow Reserve (FFR).
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:
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Food and Drug Administration
Office of Chief Information Officer
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PRAStaff@fda.hhs.gov
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information unless it displays a currently valid OMB number.”
FORM FDA 3881 (8/14) Page 1 of 1 PSC Publishing Services (301) 443-6740 EF
K151613
510(k) Summary
510(k) Summary
I. SUBMITTER
Phone: 510-440-7700
Fax: 510-440-7698
II. DEVICE
Classification Name:
21 CFR 870.1425 (Programmable Diagnostic Computer)
21 CFR 870.1110 (Blood Pressure Computer)
21 CFR 892.1560 (Ultrasonic Pulsed Echo Imaging System)
21 CFR 892.1570 (Diagnostic Ultrasonic Transducer)
Product Code:
DQK (Computer, Diagnostic, Programmable)
DSK (Computer, Blood-Pressure)
IYO (System, Imaging, Pulsed Echo, Ultrasonic)
ITX (Transducer, Ultrasonic, Diagnostic)
The iLab Polaris Multi-Modality Guidance System is a diagnostic device designed to provide
both intravascular ultrasound imaging (IVUS) and fractional flow reserve (FFR) modalities. Only
one modality can be used at a time and are independent of one another.
The IVUS modality allows the application of ultrasound technology to see from inside blood
vessels out through the surrounding blood column, enabling the physician to visualize the
coronary or peripheral vasculature. The IVUS functionality consists of two non-sterile compact
PC units (one for imaging processing and one for data acquisition) and two non-sterile display
monitors (for the integrated system -one primary and an optional secondary). It also consists of
a non-sterile Motordrive Unit (MDU), sterile bag which covers the MDU and a sterile disposable
sled. The iLab Polaris Multi-Modality Guidance System interfaces with BSC imaging catheters at
the Motordrive Unit (MDU), which provides the electro-mechanics for the rotating parts of the
imaging catheter, and the interface between the catheter and the console and BSC proprietary
software. The Motordrive Unit provides the rotation of the imaging catheter core required for
cross-sectional imaging. An electro-mechanical connector interface at the proximal end of the
imaging catheter makes the connection to the MDU. The MDU-catheter interface consists of an
integrated mechanical drive hub and electrical connection. The MDU is the primary control for
catheter positioning and movement through the vessel.
The FFR modality measures the pressure gradient across lesions to determine lesion severity
and thus, in conjunction with other tools help guide physicians in making treatment decisions.
FFR is defined as the ratio of pressure distal of a lesion (Pd) to the pressure proximal of a lesion
(Pa-aortic pressure) during maximum blood flow. Maximum blood flow is achieved by injection
of a vasodilator to open up the distal arteriole bed.
The FFR modality will also utilize the two non-sterile compact PC units (one displays the
physiological parameters and one for data acquisition) and two non-sterile display monitors (for
the integrated system -one primary and an optional secondary). In addition the FFR modality
consists of a Signal Processing Module (SPM- commercial name FFR Link), Bluetooth
Communication Module (BCM) and Hemodynamic Cable Kit.
The iLab Polaris Multi-Modality Guidance System console interfaces with BSC’s Pressure
Guidewire through the optical cable connector of the pressure guidewire, the FFR Link and the
Bluetooth Communication Module (BCM).
The Pressure Guidewire sensor is designed to output an optical signal that corresponds to the
pressure distal (Pd) of a lesion in a blood vessel. This optical signal is acquired and processed
by the FFR Link. The FFR Link also acquires and processes the patient’s aortic pressure signal
(Pa) obtained from a resistive bridge IBP transducer. The FFR Link processes, digitizes and
wirelessly streams by Bluetooth the aortic pressure (Pa) and distal pressure (Pd). These
wirelessly streamed pressure signals are received by the iLab Polaris Multi-Modality Guidance
System console through the BCM. BSC’s proprietary software processes the pressure signals
received via the BCM for display of Pa and Pd waveforms, Pa, Pd and Pd/Pa (FFR calculation)
for physician interpretation. Additionally the FFR Link provides an analog, BP-22 compliant,
signal which passes the IBP measurement, unchanged, to the catheterization lab’s
hemodynamic system.
The IVUS modality of the iLab Polaris Multi-Modality Guidance System is intended for
ultrasound examinations of intravascular pathology.
The FFR modality of the iLab Polaris Multi-Modality Guidance System is intended for use in
catheterization and related cardiovascular specialty laboratories to compute, and display various
physiological parameters based on the output from one or more electrodes, transducers or
measuring devices.
This modality is indicated to provide hemodynamic information for use in the diagnosis and
treatment of patients that undergo measurement of physiological parameters, Fractional Flow
Reserve (FFR).
The indication for use statements do not differ from those of the predicate devices.
Ultrasound is the technological principle for the IVUS modality of the subject device and its
predicate device. Therefore the technological characteristics are the same for the IVUS modality
of the subject device and its predicate device.
The following technological differences do exist for the FFR modality of the subject device and
its predicate device.
x The predicate device is an integrated single device whereas the subject device consists
of separate components
x Pressure wire interface is wired for the predicate device whereas the subject device
interfaces with the pressure wire wirelessly
x The predicate device is based on a piezoresistive effect to measure the distal pressure
whereas the subject device is based on optical interferometry to measure distal
pressure.
x Characteristics of pressure range, pressure accuracy and frequency response differ
between the predicate device and the subject device
The following performance data were provided in support of the substantial equivalence
determination:
Performance Testing-Bench
The following bench testing was performed to support substantial equivalence
Animal Study
The animal study evaluated acute pressure measurements (distal pressure) using the iLab
Polaris Multi-Modality Guidance System and Comet™ Pressure Guide Wire compared to
invasive blood pressure (aortic pressure) in the vasculature of the swine model. Two pigs were
used for the study.
The animal study successfully evaluated acute pressure measurements (distal pressure) using
the iLab Polaris Multi-Modality Guidance System and Comet Pressure Guide Wire compared to
invasive blood pressure (aortic pressure) in the vasculature of the swine model and the system
performed as intended.
The non-clincial data supports the safety of the subject device and the hardware and software
verification and validation demonstrate the iLab Polaris Multi-Modality Guidance System should
perform as intended in the specified use conditions. Where technological differences exists
between the subject device and predicate device no new questions of safety and effectiveness
were raised, the methods used to evaluate the different characteristics were based on FDA
recognized consensus standards and the data generated demonstrates substantial equivalence.