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510(k) Data Aggregation

    K Number
    K183153

    Validate with FDA (Live)

    Date Cleared
    2019-07-08

    (236 days)

    Product Code
    Regulation Number
    878.4400
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Microwave Ablation System is intended for coagulation (ablation) of soft tissue. It is not intended for use in cardiac procedures.

    Device Description

    The Microwave Ablation System M150E is microwave-based system intended to deliver energy through an antenna inserted into soft tissue for the purpose of coagulating (ablation) of a defined volume of that tissue. The Microwave Ablation System utilizes a 2450MHz generator to deliver power to single microwave ablation antenna or double microwave ablation antennas. The Microwave Ablation Generator provides for user setting of ablation time and ablation power. The proposed device consists of Microwave Ablation Generator, Microwave Ablation Electrode Kits, Temperature Probe and Foot Switch.

    AI/ML Overview
    1. Table of Acceptance Criteria and Reported Device Performance:

    The document describes the device as a Microwave Ablation System. Rather than specific performance metrics like sensitivity/specificity for a diagnostic device, the acceptance criteria for this therapeutic device are based on demonstrating equivalent technical characteristics, safety, and performance to a predicate device.

    Acceptance Criteria / Performance ElementPredicate Device (Emprint™ Ablation System K133821)Proposed Device (Microwave Ablation System M150E)Result / Comparison
    Indications for UseIntended for use in percutaneous, laparoscopic, and intraoperative coagulation (ablation) of soft tissue, including partial or complete ablation of non-resectable liver tumors. Not intended for use in cardiac procedures.Intended for the coagulation (ablation) of soft tissues. Not intended for use in cardiac procedures.Equivalent
    Intended Purposecoagulation and ablation of tissuecoagulation and ablation of tissueEquivalent
    DesignSingle channel; cooling-water cycle, thermal ablation, TEMP probe, foot switch.Double channels; cooling-water cycle, thermal ablation, TEMP probe, foot switch. (Note: Double channel is a difference, but determined not to affect safety/performance.)Similar/Different
    Operating Temperature10°C-30°C5°C-40°CSimilar
    Operating Humidity20%~80% non condensation20%~80% non condensationEquivalent
    Output Parameters2450MHz±50MHz, 0-100W2450MHz±10MHz, 0-100WEquivalent
    Output Impedance50Ω nominal50Ω nominalEquivalent
    Voltage Supply100-240VAC 50-60 Hz100-240VAC 50-60 HzEquivalent
    Fuse Rating6.3 A, 250V6.3 A, 250VEquivalent
    Physicochemical PropertiesNot contain any medications, animal tissues or blood components, especially in contact with human tissue does not contain the above substances.Not contain any medications, animal tissues or blood components, especially in contact with human tissue does not contain the above substances.Equivalent
    Working PrincipleMicrowave energy delivered via antenna to coagulate tissue; transforms into heat, raising temperature to lose bioactivity.Same working principle.Equivalent
    Antenna Length (mm)CA15L1: 150; CA20L1: 200; CA30L1: 300SS-MWA-1526C: 150; SS-MWA-1531C: 150; SS-MWA-2026C: 200; SS-MWA-2031C: 200; SS-MWA-2526C: 250; SS-MWA-2531C: 250 (Note: Different lengths, but stated not to affect safety/performance in terms of depth of tumor position.)Different
    Emission Area Length (mm)CA15L1: 28; CA20L1: 28; CA30L1: 28SS-MWA-1526C: 26; SS-MWA-1531C: 31; SS-MWA-2026C: 26; SS-MWA-2031C: 31; SS-MWA-2526C: 26; SS-MWA-2531C: 31 (Note: Wider range, but stated not to affect safety/performance.)Different
    OD (mm)CA15L1: 2.40; CA20L1: 2.40; CA30L1: 2.40SS-MWA-1526C: 2.08; SS-MWA-1531C: 2.08; SS-MWA-2026C: 2.08; SS-MWA-2031C: 2.08; SS-MWA-2526C: 2.08; SS-MWA-2531C: 2.08 (Note: Thinner diameter to reduce trauma, determined not to affect ablation area or safety/performance.)Different
    Antenna MaterialNot explicitly stated for predicate in comparison table, but implied to be similar biocompatible material.304 stainless steel, biocompatible per ISO 10993-1.Similar
    Disposable/Single-useAntennas are disposable and single-use.Antennas are disposable and single-use.Equivalent
    SterilityAccessories sterilized with EO (SAL: 10-6).Accessories sterilized with EO (SAL: 10-6).Equivalent
    BiocompatibilityPatient-contacting materials are biocompatible.Patient-contacting materials are biocompatible.Equivalent
    Device Temperature MonitoringTemperature monitoring features used to ensure system safety.Temperature monitoring features used to ensure system safety.Equivalent
    Device CoolingPumped normal saline is used to cool the Emprint™ Antenna.Pumped normal saline is used to cool the antenna.Equivalent
    1. Sample size used for the test set and the data provenance:

      • Test Set Sample Size: Not applicable. The submission states, "Clinical studies were not required to demonstrate the substantial equivalence of the microwave ablation system and the predicated device." The testing primarily involved non-clinical bench and lab testing (e.g., electrical safety, EMC, performance, thermal effects, temperature monitoring, shelf life, package verification, sterilization validation, biocompatibility).
      • Data Provenance: Not applicable, as no clinical test set was used. The non-clinical testing data provenance is implied to be from the manufacturer's internal testing.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • Not applicable, as no clinical test set was used that required expert ground truth establishment in this type of 510(k) submission.
    3. Adjudication method for the test set:

      • Not applicable, as no clinical test set was used for adjudication.
    4. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:

      • Not applicable. This device is a therapeutic microwave ablation system, not a diagnostic imaging AI device that would involve human readers or AI assistance for interpretation.
    5. If a standalone (i.e. algorithm only without human-in-the loop performance) was done:

      • Not applicable in the context of diagnostic AI performance. The device is a physically operated medical system. However, software validation was performed, indicating the internal algorithms and software governing the device's operation were tested in a standalone manner (without human intervention in the algorithm's execution during ablation).
    6. The type of ground truth used:

      • For the non-clinical tests, the "ground truth" was established by adherence to recognized national and international standards (e.g., IEC 60601-1, IEC 60601-2-6, IEC 60601-1-2, ISO 11607-1, ISO 11135, ISO 10993), and engineering specifications for system performance, thermal effects, and temperature monitoring. These standards and specifications themselves represent a form of "ground truth" for acceptable device characteristics and safety.
    7. The sample size for the training set:

      • Not applicable, as this device does not involve machine learning or AI models that require a training set in the conventional sense. The "training" here refers to the device's design, development, and adherence to established engineering principles and standards.
    8. How the ground truth for the training set was established:

      • Not applicable, as no machine learning training set was used. The "ground truth" for the device's design and operational parameters was derived from existing medical device standards, predicate device characteristics, and established engineering and physiological principles related to microwave ablation.
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