(60 days)
These electrodes are intended for use in minimally invasive surgical procedures where monopolar electrosurgical cutting and coagulation are desired. Irrigation and suction capabilities via the same handset are available as well.
The New Deantronics Laparoscopic Hollow Electrodes, sold as sterile packaged, and ready for use devices, are intended for use in minimally invasive surgical procedures where monopolar electrosurgical cutting and coagulation are desired. The laparoscopic electrodes are used in conjunction with a Valleylab™ E2750 Laparoscopic Handset and 5 mm (internal diameter) or larger trocar, electrosurgical generator, and patient return electrode. During the operation, the electrode tip and the insulated shaft are to be inserted through a trocar, then conductive shaft end is inserted into the nose of an electrosurgical pencil from which it receives the high frequency current and delivers the current onto a target tissue for cutting and coagulation in a laparoscopic procedure. These devices can be used in hospitals and are used by trained professionally only.
This document is a 510(k) Pre-market Notification for Laparoscopic Hollow Electrodes. It describes the device, its intended use, and compares it to predicate devices to establish substantial equivalence.
Here's a breakdown of the requested information based on the provided text.
1. Table of Acceptance Criteria and Reported Device Performance
The document states that "All the test results demonstrate the performance of New Deantronics Laparoscopic Hollow Electrodes meet the requirements of its pre-defined acceptance criteria and intended uses." However, specific quantitative acceptance criteria or detailed reported performance values for each test are not explicitly provided in this document. The document broadly states that the device "passed all" relevant tests and "met the requirements."
| Test Category | Acceptance Criteria (Not explicitly quantitative in this document) | Reported Device Performance |
|---|---|---|
| Bench Testing | Meet design specification, function as intended | "Meet the requirements of its pre-defined acceptance criteria and intended uses." |
| Suction & Aspiration testing | Adequate performance within a system | Adequate performance demonstrated |
| Thermal Effects on Tissue testing | Adequate performance within a system | Adequate performance demonstrated |
| Electrical Safety (IEC 60601-1, IEC 60601-2-2) | Compliance with standards | "Passed all electrical safety and EMC testing." |
| Electromagnetic Compatibility (EMC) (IEC 60601-1-2) | Compliance with standards | "Passed all electrical safety and EMC testing." |
| Shelf-Life Testing | Maintain functionality and sterility | "Established that the device and packaging remain functional and maintain sterility for 2 years." |
| Biocompatibility Testing (ISO 10993-1) | Not cause a biocompatibility reaction | "Demonstrates that the materials in the device will not cause a biocompatibility reaction when used as intended." |
2. Sample Size Used for the Test Set and Data Provenance
The document does not specify the sample sizes used for any of the bench, electrical safety, EMC, shelf-life, or biocompatibility tests. It also does not explicitly state the country of origin of the data or whether the studies were retrospective or prospective. These were all bench tests conducted by New Deantronics, presumably in their facilities in Taiwan, R.O.C., as per the sponsor information.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This information is not applicable as the evaluation involved physical, electrical, and material testing of a medical device, not a diagnostic or prognostic system requiring expert interpretation of results for ground truth establishment.
4. Adjudication Method for the Test Set
This information is not applicable for the same reasons as above. The tests performed are objective measurements against predefined standards or specifications.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
An MRMC comparative effectiveness study was not performed, nor is it applicable to this type of device (electrosurgical electrodes). The device is a tool used by a surgeon, not a diagnostic aid that would improve human reader performance.
6. Standalone Performance (Algorithm Only without Human-in-the Loop Performance)
This is not applicable as the device is a physical electrosurgical electrode and does not involve any algorithms or AI for its function.
7. Type of Ground Truth Used
The "ground truth" for the tests performed was established through objective engineering and material science standards and specifications.
- Bench Testing: Internal requirements, FDA guidance (Premarket Notification (510(k)) Submissions for Electrosurgical Devices for General Surgery).
- Electrical Safety & EMC: International standards (IEC 60601-1, IEC 60601-2-2, IEC 60601-1-2).
- Shelf-Life Testing: FDA guidance and internal requirements.
- Biocompatibility Testing: ISO 10993-1 and FDA guidance.
8. Sample Size for the Training Set
This is not applicable as the device does not employ machine learning or AI, and therefore does not have a "training set."
9. How the Ground Truth for the Training Set Was Established
This is not applicable as there is no training set for this device.
{0}------------------------------------------------
Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
February 19, 2019
New Deantronics Taiwan Ltd. % Craig Coombs President Coombs Medical Device Consulting, Inc 1193 Sherman St Alameda, California 94501
Re: K183594
Trade/Device Name: Laparoscopic Hollow Electrodes:
Curved Spatula Electrode, Retractable, Aspiration Hole, 28cm ; Laparoscopic Wire J-Hook Electrode, Retractable, Aspiration Hole, 28cm : Laparoscopic Wire L-Hook Electrode. Retractable. Aspiration Hole. 28cm: Laparoscopic Wire L-Hook Electrode, Retractable, Aspiration, 36cm ; Laparoscopic Flat L-Hook Electrode, Retractable, Aspiration Hole, 28cm ; Laparoscopic Straight Spatula Electrode, Hollow, 28cm ; Laparoscopic Curved Spatula Electrode, Hollow, 28cm; Laparoscopic Wire J-Hook Electrode, Hollow, 28cm ; Laparoscopic Wire L-Hook Electrode, Hollow, 28cm ; Laparoscopic Cylindrical Tip Electrode, Hollow, 28cm Regulation Number: 21 CFR 878.4400 Regulation Name: Electrosurgical Cutting and Coagulation Device and Accessories Regulatory Class: Class II Product Code: GEI Dated: December 20, 2018
Received: December 21, 2018
Dear Craig Coombs:
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.
{1}------------------------------------------------
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 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/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; good manufacturing practice requirements as set forth in the quality systems (QS) 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 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 comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). 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 (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Image /page/1/Picture/6 description: The image shows a digitally signed document. The document indicates that it was signed by Long H. Chen -S on February 19, 2019, at 15:19:41 -05'00'. The document is for Binita S. Ashar, M.D., M.B.A., F.A.C.S., who is the Director of the Division of Surgical Devices, Office of Device Evaluation.
Center for Devices and Radiological Health
Enclosure
{2}------------------------------------------------
Indications for Use
510(k) Number (if known) K183594
Device Name Laparoscopic Hollow Electrodes
Indications for Use (Describe)
These electrodes are intended for use in minimally invasive surgical procedures where monopolar electrosurgical cutting and coagulation are desired. Irrigation and suction capabilities via the same handset are available as well.
| Type of Use (Select one or both, as applicable) | |
|---|---|
| \u2611 Prescription Use (Part 21 CFR 801 Subpart D) | \u2610 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}------------------------------------------------
510(k) Summary
A. Device Information:
| Category | Comments |
|---|---|
| Sponsor: | New Deantronics Taiwan Ltd.12F., No.51, Sec. 4, Chong Yang Rd.,Tu Cheng District,New Taipei City 23675, Taiwan R.O.C.Tel: (886) 2-2268-1726Fax: (886) 2-2268-3800 |
| Correspondent ContactInformation: | Craig CoombsCoombs Medical Device Consulting1193 Sherman StreetAlameda, CA 94501Tel: 510-337-0140 |
| Device Common Name: | Electrosurgical accessory |
| Device Classification Number: | 21 CFR 878.4400 |
| Device Classification &Product Code: | Class 2,GEI |
| Device Proprietary Name: | Laparoscopic Hollow Electrodes |
Predicate Device Information:
| Predicate Device: | Disposable Laparoscopic Electrodes,Coated and Non-coated |
|---|---|
| Predicate Device Manufacturer: | New Deantronics |
| Predicate Device Common Name: | Electrosurgical accessory |
| Predicate Device Premarket Notification # | K153265 |
| Predicate Device Classification: | 21 CFR 878.4400Electrosurgical, Cutting & CoagulationDevice and Accessories |
| Predicate Device Class & Product Code: | Class 2, GEI |
Reference Device Information:
| Reference Device: | Valleylab Laparoscopic Electrodes |
|---|---|
| Reference Device Manufacturer: | Valleylab, Inc. |
| Reference Device Common Name: | Electrosurgical accessory |
| Reference Device Premarket Notification # | K964175 |
| Reference Device Classification: | 21 CFR 878.4400Electrosurgical, Cutting & CoagulationDevice and Accessories |
| Reference Device Class & Product Code: | Class 2, GEI |
{4}------------------------------------------------
B. Date Summary Prepared
15 Feb 2019
C. Description of Device
The New Deantronics Laparoscopic Hollow Electrodes, sold as sterile packaged, and ready for use devices, are intended for use in minimally invasive surgical procedures where monopolar electrosurgical cutting and coagulation are desired. The laparoscopic electrodes are used in conjunction with a Valleylab™ E2750 Laparoscopic Handset and 5 mm (internal diameter) or larger trocar, electrosurgical generator, and patient return electrode. During the operation, the electrode tip and the insulated shaft are to be inserted through a trocar, then conductive shaft end is inserted into the nose of an electrosurgical pencil from which it receives the high frequency current and delivers the current onto a target tissue for cutting and coagulation in a laparoscopic procedure. These devices can be used in hospitals and are used by trained professionally only.
D. Indications for Use
These electrodes are intended for use in minimally invasive surgical procedures where monopolar electrosurgical cutting and coagulation are desired. Irrigation and suction capabilities via the same handset are available as well.
{5}------------------------------------------------
E. Comparison to Predicate Device
As described below, the application New Deantronic Hollow Electrodes is substantially equivalent in intended use, technology, design and physician use to the predicate New Deantronics Disposable Laparoscopic Electrodes, coated and non-coated (K153265).
| Feature | Application Device:New DeantronicsLaparoscopic HollowElectrodes | Predicate Device:New DeantronicsDisposable LaparoscopicElectrodes, coated andnon-coated(K153265) | Reference Device:Valleylab LaparoscopicHandsets and LaparoscopicElectrodes(K964175) | Pertinence of Feature toConsideration of SubstantialEquivalence. |
|---|---|---|---|---|
| Indications for Use | These electrodes areintended for use inminimally invasivesurgical procedureswhere monopolarelectrosurgical cuttingand coagulation aredesired. Irrigation andsuction capabilities viathe same handset areavailable as well. | The disposablelaparoscopic electrodesare intended for use inminimally invasivesurgical procedureswhere monopolarelectrosurgical cuttingand coagulation aredesired. | The Valleylab LaparoscopicHandsets (models E2750,E2751, E2750T and E2751T)and the Electrodes (modelE2770 series, E2780 series,E2780R series and E2780R-ASP) are intended for use inthose laparoscopic orthoracoscopic surgicalprocedures where thedelivery of electrosurgicalcurrent, irrigation andsuction via a single handsetis desirable.The device is not intendedto be used in endoscopicsurgical procedures. | The Indications for Use of theapplication and predicate devicesare nearly the identical; all ofthese devices are for RF cuttingor coagulation in minimallyinvasive surgical procedures.The application device hasirrigation and suction capabilities,but as evidenced by thereference device, thesecapabilities have long beenapplied to such devices and raiseno new questions of safety orefficacy for these types ofdevices. |
| Product Code | GEI | GEI | GEI | Identical to both predicate andreference devices |
| Feature | Application Device:Laparoscopic HollowElectrodes | Predicate Device:New DeantronicsDisposable LaparoscopicElectrodes(K153265) | Reference Device:Valleylab LaparoscopicHandsets and LaparoscopicElectrodes (K964175) | Pertinence of Feature toConsideration of SubstantialEquivalence. |
| Technology | ||||
| Mechanism ofOperation | The New DeantronicsLaparoscopic HollowElectrodes combine RFtechnology with suctionand irrigation of fluidsduring electrosurgicalprocedures. | Same RF cutting andcoagulation capability | Same RF cutting andcoagulation capability andsame suction & irrigationcapabilities as applicationdevice | Identical to predicate for RFcutting and coagulation andidentical to reference for RFcapabilities and suction andirrigation of fluids. |
| Compatible w/ RFMonopolar or Bipolaradministration? | Monopolar only | Same | Same | Identical to both predicateand reference devices |
| Compatible Device | Valleylab™ E2750Laparoscopic handset | Monopolarelectrosurgical pencils w0.093" (2.36mm) nozzle &w 5mm cannula or larger | Valleylab™ E2750Laparoscopic handset | Identical to reference device;clinically equivalent topredicate device for insertioninto 3rd party hand pieces |
| Design | ||||
| Electrode length | Retractable: 28cmand 36 cmNon-Retractable:28cm | 36cm and 45 cm | Same as application | Identical to reference device;Clinically equivalent topredicate. All sizes of alldevices intended forlaparoscopic applications |
| Electrode OuterDiameter | Retractable: 5.00mmNon-Retractable:4.75mm | 2.36mm shaft OD | Same as application | Identical to reference device;Clinically equivalent topredicate. All sizes of alldevices intended forlaparoscopic applications |
| Feature | Application Device:Laparoscopic HollowElectrodes | Predicate Device:New DeantronicsDisposable LaparoscopicElectrodes(K153265) | Reference Device:Valleylab LaparoscopicHandsets and LaparoscopicElectrodes (K964175) | Pertinence of Feature toConsideration of SubstantialEquivalence. |
| Electrode InnerDiameter | Retractable: 4.10mmNon-Retractable:3.18mm | Not Applicable | Same as application | ldentical to reference device;Clinically equivalent topredicate. |
| Materials forElectrode Tip | SUS 304 Stainlesswithout coating | SUS 304 Stainless withPTFE coating orwithout coating | SUS 304 Stainless withoutcoating | Functional tip identical topredicate and referencedevices |
| Materials forElectrode Sheath | Retractable: PTFE, PCand POF (black)Non-Retractable: POF(black) | POF (blue) | Retractable: PTFE, PC andPOF (black)Non-Retractable: POF(black) | Nearly identical to predicateand reference devices |
| Materials forElectrode Hub(Retractable Only) | PC (Polycarbonate) | Not Applicable;No hub | PC (Polycarbonate) | ldentical to reference device |
| Materials for TipProtector | Distal: LDPEProximal: LDPE | Distal: LDPEProximal: LDPE | RetractableDistal: PVC,Proximal: LDPENon-RetractableDistal: LDPE, Proximal:LDPE | Nearly identical to predicateand reference devices |
| Feature | Application Device:Laparoscopic HollowElectrodes | Predicate Device:New DeantronicsDisposable LaparoscopicElectrodes(K153265) | Reference Device:Valleylab LaparoscopicHandsets and LaparoscopicElectrodes (K964175) | Pertinence of Feature toConsideration of SubstantialEquivalence. |
| Electrode Tip | Retractable:Curved Spatula,Wire J-Hook,Wire L-Hook,Flat L-HookNon-Retractable:Straight Spatula,Curved Spatula,Wire J-Hook,Wire L-Hook,Cylindrical Tip | Straight Spatula,Curved Spatula,Wire J-Hook,Wire L-Hook,Flat L-Hook | Retractable:Curved Spatula,Wire J-Hook,Wire L-Hook,Flat L-HookNon-Retractable:Straight Spatula,Curved Spatula,Wire J-Hook,Wire L-Hook,Cylindrical Tip,Flat L-Hook | Almost Identical, except forNon-Retractable Flat L-Hookexisting in reference but not inapplication. All styles inapplication device are found inpredicate device, except forcylindrical tip. Differencesraise no new questions ofsafety or efficacy |
| Maximum PeakVoltage | High Frequency:13.5 $kV_{p-p}$Main Frequency: 5400Vfor 60 seconds | 6300V (60Hz) for 60seconds | 5200V (60Hz) for 60 seconds | High withstand voltage is assafe as the predicate andreference devices. |
| Other Attributes | ||||
| Single Use orReusable? | Single Use | Single Use | Single Use | Identical to predicate andreference devices |
| Provided Sterilized? | Yes | Yes | Yes | Identical to predicate andreference devices |
| Sterilization | Retractable: EtO | EtO | Retractable: EtO | Identical to predicate and |
| Method | Non-Retractable: Gamma | Non-Retractable: Gamma | reference devices | |
| Performance/Safety Testing in | IEC 60601-1 | IEC 60601-1 | AAMI HF18-1986 | Fundamentally Identical to |
| accordance with | IEC 60601-1-2 | IEC 60601-1-2 | IEC 601-2-2 | predicate and reference devices, |
| IEC 60601-2-2IEC 60601-2-18 | IEC 60601-2-2IEC 60601-2-18 | application device inconformance with latest versionof the listed standards |
{6}------------------------------------------------
{7}------------------------------------------------
{8}------------------------------------------------
{9}------------------------------------------------
F. Summary of Supporting Data.
New Deantronics has conducted extensive testing to ensure that the subject devices met design specification, function as intended and conform to the internationally recognized standards.
Bench Testing
All the test results demonstrate the performance of New Deantronics Laparoscopic Hollow Electrodes meet the requirements of its pre-defined acceptance criteria and intended uses. The results of the non-clinical testing demonstrate that the Laparoscopic Hollow Electrodes are as safe and effective as the predicate devices.
Performance bench testing was conducted in accordance with FDA's guidance Premarket Notification (510(k)) Submissions for Electrosurgical Devices for General Surgery issued August 15, 2016 and internal requirements. Suction & Aspiration testing and Thermal Effects on Tissue testing were conducted to demonstrate adequate performance within a system.
Electrical Safety and Electromagnetic Compatibility Testing
Electrical safety testing was conducted in accordance with: IEC 60601-1:2005+AM1:2012 Medical electrical equipment - Part 1: General requirements for basic safety and essential performance
IEC 60601-2-2:2017 Medical electrical equipment - Part 2-2: Particular requirements for the basic safety and essential performance of high frequency surgical equipment and high frequency surgical accessories.
Electromagnetic Compatibility Testing (EMC) was conducted in accordance with: IEC 60601-1-2:2014 Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances - Requirements and tests.
The New Deantronics Laparoscopic Hollow Electrodes passed all electrical safety and EMC testing.
Shelf-Life Testing
Shelf-life testing was conducted in accordance with FDA's guidance document Premarket Notification (510(k)) Submissions for Electrosurqical Devices for General Surgery issued August 15, 2016 and internal requirements. The New Deantronics Laparoscopic Hollow Electrodes were subjected to accelerated aging. The aging studies established that the device and packaging remain functional and maintain sterility for 2 years.
Biocompatibility Testing
Biocompatibility testing was conducted in accordance with ISO 10993-1:2009/AC:2010, Biological evaluation of medical devices – Part 1: Evaluation and testing within a risk management process, and FDA's guidance documents, Use of International Standard ISO
{10}------------------------------------------------
10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process" issued June 16, 2016 and Premarket Notification (510(k)) Submissions for Electrosurgical Devices for General Surgery issued August 15, 2016. This testing demonstrates that the materials in the device will not cause a biocompatibility reaction when used as intended.
Animal Studies
No animal studies were performed as appropriate verification of the device was achieved from the results of the bench performance testing, biocompatibility evaluation, and electrical/safety testing.
Clinical Studies
No clinical studies were performed as appropriate verification of the device was achieved from the results of the bench performance testing, biocompatibility evaluation, and electrical/safety testing.
Conclusion
It is concluded that the New Deantronics Laparoscopic Hollow Electrodes are substantially equivalent to the predicate New Deantronics Disposable Laparoscopic Electrodes, coated and non-coated (K153265).
§ 878.4400 Electrosurgical cutting and coagulation device and accessories.
(a)
Identification. An electrosurgical cutting and coagulation device and accessories is a device intended to remove tissue and control bleeding by use of high-frequency electrical current.(b)
Classification. Class II.