K Number
K014216
Device Name
SECCA SYSTEM
Date Cleared
2002-03-21

(90 days)

Product Code
Regulation Number
878.4400
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Secca™ System is intended for general use in the electrosurgical coagulation of tissue and intended for use specifically in the treatment of fecal incontinence in those patients with incontinence to solid or liquid stool at least once per week and who have failed more conservative therapy.
Device Description
Radiofrequency electrosurgical generator and electrosurgical accessories
More Information

Not Found

No
The summary describes a radiofrequency electrosurgical system for tissue coagulation and treatment of fecal incontinence. There is no mention of AI, ML, image processing, or any data-driven algorithms typically associated with AI/ML in medical devices. The description focuses on the physical components and intended use of the device.

Yes
The "Intended Use / Indications for Use" states that the device is "intended for use specifically in the treatment of fecal incontinence." Treatment implies a therapeutic purpose.

No.
Explanation: The device is described as an electrosurgical system intended for the treatment (coagulation of tissue) of fecal incontinence. It performs a therapeutic action rather than diagnosing a condition.

No

The device description explicitly states it is a "Radiofrequency electrosurgical generator and electrosurgical accessories," which are hardware components.

Based on the provided information, the Secca™ System is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use clearly states it's for "electrosurgical coagulation of tissue" and "treatment of fecal incontinence." This is a therapeutic procedure performed directly on the patient's body.
  • Device Description: It's described as a "Radiofrequency electrosurgical generator and electrosurgical accessories." This aligns with devices used for surgical interventions, not for testing samples outside the body.
  • Anatomical Site: The anatomical site is the "Lower GI tract, anal sphincter," which is a part of the patient's body where the device is used directly.

IVD devices are designed to perform tests on samples taken from the human body (like blood, urine, tissue) to provide information about a person's health. The Secca™ System does not fit this description. It's a surgical device used for treatment.

N/A

Intended Use / Indications for Use

The Secca™ System is intended for general use in the electrosurgical coagulation of tissue and intended for use specifically in the treatment of fecal incontinence in those patients with incontinence to solid or liquid stool at least once per week and who have failed more conservative therapy.

Product codes (comma separated list FDA assigned to the subject device)

GEI

Device Description

The Secca™ System is mentioned in the "Name of Device" section. It is further described as a "Radiofrequency electrosurgical generator and electrosurgical accessories" and falls under the "Classification Name: Electrosurgical cutting and coagulation device and accessories".

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

anal sphincter, lower GI tract

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Not Found

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K010210, K000245, K991291, K000170, K992542, K904646, K913736, K981361, K992382, K970083

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 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.

0

Attachment 14

MAR 2 1 2002

510(k) SUMMARY

Curon Medical, Inc.'s Secca™ System

Submitter's Name, Address, Telephone Number, Contact Person and Date Prepared

Submitter:

Curon Medical, Inc. 735 Palomar Avenue Sunnyvale, CA 94085 408-733-9910 main 408-522-8699 fax

Contact Person:

Jonathan S. Kahan, Esq. Regulatory Counsel Hogan & Hartson, LLP 555 13th Street, N.W. Washington, DC 20004 Phone: (202) 637-5794 Fax: (202) 637-5910

Date Prepared: December 20, 2001

Name of Device

Secca™ System

Common or Usual Name

Radiofrequency electrosurgical generator and electrosurgical accessories

Classification Name

Electrosurgical cutting and coagulation device and accessories

Predicate Devices

    1. Stretta System (K010210
    1. Stretta System (K000245)
  • Stretta Inflatable Basket Electrode (K991291) ತೆ.
  • Secca Tubular Electrode (K000170) ধ:

1

2/3 K014216

    1. A4000 Tubular Electrode (K992542)
    1. BioCare International's BCI-100 Fecal Incontinence System (K904646)
    1. Biosearch, Inc.'s Anorectal Biofeedback System 5 (K913736)
    1. Ethicon's PowerStar Bipolar Scissors (K981361)
    1. Ellman's Surgitron Radiolase System and Accessories (K992382)
  1. Portlyn Corporation's Dynabite Hot Gastroenterology Biopsy Forceps (K970083)

Intended Use

The Secca™ System is intended for general use in the electrosurgical coagulation of tissue and intended for use specifically in the treatment of fecal incontinence in those patients with incontinence to solid or liquid stool at least once per week and who have failed more conservative therapy.

Substantial Equivalence

The Secca System is substantially equivalent to other marketed devices that have received premarket clearance. The general intended use of the Secca System to coagulate tissue electrosurgically is the same as the general intended use of Curon Medical's previously cleared Stretta System (K010210 and K000245) ("Stretta"), Secca Tubular Electrode (K000170), A4000 Tubular Electrode (K992542), and Stretta Inflatable Basket Electrode (K991291). The Secca System's specific indication for use for treatment of fecal incontinence is also substantially the same as for a number of predicate biofeedback devices. Specifically, BioCare International's BCI-100 Fecal Incontinence System (K904646) ("BCI-100 System") and Biosearch, Inc.'s Anorectal Biofeedback System 5 (K913736) ("Anorectal System 5") are cleared for biofeedback training of the anal sphincter in the treatment of fecal incontinence and/or constipation. Finally, FDA also has cleared a number of other devices for use in anorectal procedures to perform tissue ablation or coagulation, including Ethicon's PowerStar Bipolar Scissors (K981361) device, Ellman's Surgitron Radiolase System and Accessories (K992382), and Portlyn Corporation's Dynabite Hot Gastroenterology Biopsy Forceps (K970083) device. Although these devices are not specifically indicated for use in the treatment of fecal incontinence, like the Secca System they are all generally used to apply electrical energy within the lower GI tract for treatment of gastroenterological pathologies.

Comparing the principles of operation and the technological characteristics of the Secca System to its predicates, the device and generator design also is substantially similar to the Company's previously cleared Stretta System (K010210 and K000245), except for a few minor modifications. Likewise, its design is substantially similar to Curon's cleared Tubular Electrodes (K000170 and K992542) and Stretta Inflatable Basket Electrode (K991291). All of these devices have been designed, tested, and produced by the same manufacturer in much the same manner.

2

Any minor differences in indications between the Secca System and the predicates do not alter its therapeutic effect, considering the impact on safety and prodicates as not and med by preclinical and clinical testing. Furthermore, although minor modifications have been made to the technological features of the Secca System since the Company's clearance of the predicate Stretta System, these changes are minimal and do not affect the safety or effectiveness of the Secca System. Thus, the Secca System presents no new significant technological features compared to the previously cleared predicates. Therefore, because the intended use and indications for use of the device are substantially the same as the cleared predicates and there are no significant new technological features, the device may be found substantially equivalent to those other devices.

3

DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo is circular and contains the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is a stylized image of an eagle or bird with its wings spread.

Public Health Service

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

MAR 2 1 2002

Curon Medical, Inc. c/o Mr. Jonathan S. Kahan, Esq. Hogan & Hartson, L.L.P. 555 Thirteenth Street, N.W. Washington, D.C. 20004-1109

Re: K014216

Trade Name: Secca System Regulation Number: 878.4400 Regulation Name: Electrosurgical cutting and coagulation device and accessories Regulatory Class: II Product Code: GEI Dated: December 20, 2001 Received: December 21, 2001

Dear Mr. Kahan:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and we have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to 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 such 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); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

4

Page 2 - Mr. Jonathan Kahan

This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 21 CFR Part 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4659. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html

Sincerely yours,

Miriam C. Provost

Celia M. Witten, Ph.D., M.D. Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

5

K014216

SECCA™ SYSTEM INDICATIONS FOR USE:

The Secca™ System is intended for general use in the electrosurgical coagulation of tissue and intended for use specifically in the treatment of fecal incontinence in those patients with incontinence to solid or liquid stool at least once per week and who have failed more conservative therapy.

Muriann C. Provost

(Division Sign-Off) Division of General, Restorative and Neurological Devices

510(k) Number K014216