K Number
K020614
Manufacturer
Date Cleared
2002-05-24

(88 days)

Product Code
Regulation Number
876.1500
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The CA-Guard Irrigating Cannula is intended to provide an access port to body cavities for endoscopes and endoscopic accessories when intraoperative irrigation or infusion of trocar wound surfaces is desired. The cannula has been tested for compatibility with lidocaine and marcane. Saline and water may also be used as irrigants. The CA-Guard Irrigating Cannula is inherently a needleless system and therefore, minimizes the possibility of "needle sticks" for healthcare workers, in accordance with the Needlestick Safety and Prevention Act of 2000.

Device Description

The Irrigating Cannula is a non-toxic, sterile, single use, disposable surgical access port. The device is intended to be inserted percutaneously into the peritoneal cavity to provide access for endoscopic instruments. The cannula is intended to replace the cannula that is supplied with the United States Surgical Versaport® 11mm Trocar System.

The proximal end of the cannula is equipped with a female luer connector. The luer communicates with 6 longitudinal grooves on the surface of the inner member of the cannula. The inner member is covered with polyolefin shrink tubing. An array of twenty-four (24) holes deliver infusate to the compromised tissue surfaces of the trocar wound.

AI/ML Overview

This document is a 510(k) premarket notification for an "Irrigating Cannula." This type of submission generally establishes substantial equivalence to a predicate device rather than strictly proving effectiveness against predefined acceptance criteria for a new clinical claim. Therefore, the information provided focuses on demonstrating equivalence through comparison and performance testing, rather than a clinical study with typical acceptance criteria for a diagnostic or AI-driven device.

Based on the provided text, here is an analysis of the acceptance criteria and study information:

1. Table of Acceptance Criteria and Reported Device Performance

Acceptance Criteria (Implied)Reported Device Performance
Material Biocompatibility: Materials are safe for human contact and show no adverse reactions."The materials of construction have been carefully selected for their long history of biocompatibility." (Implied acceptance by using well-established, safe materials).
Mechanical Compatibility: Device is physically compatible with the intended existing system (predicate Versaport® Trocar System)."The CA Guard Irrigating Cannula is designed to be mechanically compatible with all components of the United States Surgical Versaport® 11mm Trocar System using the 5 mm PLUS SEAL." (Implied acceptance by successful physical integration and function with the predicate system).
Infusate Compatibility: Device maintains integrity and function when exposed to specified infusates (lidocaine, marcaine, saline, water)."The cannula has been tested for compatibility with lidocaine and marcane. Saline and water may also be used as irrigants." (Implied acceptance by successful testing with no adverse effects on the device from the infusates).
Performance Equivalence: Device performs "as well as or better than" the predicate device in its intended function (providing access, irrigation/infusion via its luer connector and grooves/holes)."Performance of the device was characterized and compared to that of the predicate utilizing 5 tests." "The tests demonstrated the Irrigating Cannula is substantially equivalent to the cannula manufactured and marketed by the United States Surgical Corporation as part of the Versaport® Trocar System pursuant to 510(k) K954108." "Since the Irrigating Cannula embodies technological characteristics essentially identical to those of the predicate device, we believe the device is safe and effective and that it performs as well as or better than the predicate device." (Implied acceptance by demonstrating equivalent performance in unspecified tests compared to the predicate.)
Needlestick Minimization: The design inherently reduces the risk of needlestick injuries for healthcare workers."The CA-Guard Irrigating Cannula is inherently a needleless system and therefore, minimizes the possibility of 'needle sticks' for healthcare workers, in accordance with the Needlestick Safety and Prevention Act of 2000." (Design feature that inherently meets this safety objective).
Manufacturing Quality: Device is manufactured according to quality system regulations (QSR) and good manufacturing practices (GMP)."The device has been designed and developed utilizing design control methods in compliance with the QSR. The Irrigating Cannula will be manufactured per specifications and good manufacturing practices that ensure the device is safe and effective for its intended use." (Commitment to QSR/GMP ensures quality and regulatory compliance, implying acceptance of manufacturing process).
Technological Equivalence: Device's technological characteristics are comparable to the predicate."The Irrigating Cannula was compared to the predicate device using 14 points of comparison and found to be equivalent." (Implied acceptance by a formal comparison finding equivalence on key characteristics).

2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

The document does not specify a "test set" in the context of human data or a clinical trial. The performance evaluation appears to be based on laboratory or bench testing of the device itself and comparison to the predicate. No information is provided regarding the number of devices tested, the country of origin of data, or whether it was retrospective or prospective, as these are typically not applicable to this type of performance testing for a 510(k) submission of a cannula.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

This information is not applicable as there was no "test set" involving human data or expert review to establish ground truth in the clinical sense for this device. The evaluation was primarily engineering and materials-based.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

This information is not applicable as there was no "test set" involving human data or expert review requiring adjudication.

5. 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

This information is not applicable. The device is an "Irrigating Cannula," a physical surgical instrument, not an AI or diagnostic imaging device that would involve human readers or AI assistance.

6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done

This information is not applicable. The device is a physical surgical instrument, not an algorithm.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

The "ground truth" for this device's evaluation is not a clinical "ground truth" derived from patient outcomes or expert consensus. Instead, it relies on:

  • Predicate device performance: The performance of the legally marketed United States Surgical Versaport® Trocar System (K954108) serves as the benchmark or "ground truth" for equivalence.
  • Material properties and established biocompatibility: Existing scientific knowledge and history of use for chosen materials.
  • Engineering specifications and functional testing: Device performance against its own design specifications and functional requirements (e.g., fluid flow, mechanical fit).

8. The sample size for the training set

This information is not applicable. The device is a physical surgical instrument, not an AI model requiring a training set.

9. How the ground truth for the training set was established

This information is not applicable. The device is a physical surgical instrument, not an AI model that utilizes a training set with established ground truth.


Summary of the Study (as described in the document):

The "study" for the Irrigating Cannula was a performance characterization and comparison to a legally marketed predicate device (United States Surgical Versaport® Trocar System K954108) for the purpose of demonstrating substantial equivalence under a 510(k) submission.

  • Comparison Basis: The new device was compared across "14 points of comparison" for technological characteristics, finding them "essentially identical" or equivalent.
  • Performance Testing: "5 tests" were utilized to characterize and compare the performance of the Irrigating Cannula to the predicate device. The specific nature of these tests is not detailed, but they demonstrated substantial equivalence. These likely included tests related to mechanical integrity, fluid flow, and compatibility.
  • Infusate Compatibility Testing: The cannula was specifically tested for compatibility with lidocaine and marcaine, finding it suitable for use with these and other common irrigants (saline, water).
  • Biocompatibility: Relied on the "long history of biocompatibility" of the selected materials.
  • Design & Manufacturing: The device was designed and developed using design control methods compliant with Quality System Regulations (QSR), and will be manufactured per specifications and Good Manufacturing Practices (GMP).

In essence, the "study" was a robust technical and engineering assessment, coupled with a formal comparison to a predicate device, focusing on functional equivalence, material safety, and compatibility rather than clinical efficacy or diagnostic accuracy, which are not relevant for this class of device in a 510(k) context.

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Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo consists of a stylized depiction of an eagle or bird-like figure with three curved lines forming its body and wings. The logo is encircled by the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" in a circular arrangement.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

CA-GUARD, LTD. Mr. Al Weisenborn Official Correspondent 19526 East Lake Drive Miami. FL 33015

.JUL 2 7 2015

Re: K020614 Trade/Device Name: Irrigating Cannula Regulation Number: 21 CFR 876.1500 Regulation Name: Endoscope and accessories Regulatory Class: II Product Code: OCX, GCJ Dated (Date on orig SE Itr): February 21, 2002 Received (Date on orig SE ltr): February 25, 2002

Dear Mr. Weisenborn,

This letter corrects our substantially equivalent letter of May 24, 2002.

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

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Page 2 -

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); 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.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Small Manufacturers, International and Consumer Assistance 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" (21CFR 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 Small Manufacturers, International and Consumer Assistance 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.

Benjamin R. Fisher -S

Benjamin R. Fisher, Ph.D. Director Division of Reproductive, Gastro-Renal, and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Inclications for Use

Page_1 of 1

510(k) Number (if known): K020614

Device Name: Irrigating Cannula

Indications for Use:

Irrigating Cannula is in-CA-Guard The tended to provide an access port to body cavities for endoscopes and endoscopic accessories when intraoperative irrigation or infusion of trocar wound surfaces is desired.

Daniel A. Skadsen

(Division Sign-Off) Division of Reproductive, At and Radiological Devices 510(k) Number

PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED

Concurrence of CDRH, Office of Device Evaluation (ODE)

Prescription Use _/
(Per 21 CFR 801.109)

OR

Over-The-Counter Use

(Optional Format 1-2-96)

CA-Guard, LTD.

610 E. Olympia Ave · Punta Gorda, FL 33950

Revised: May 23, 2002

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MAY 2 4 2002

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Page 17 of 17

Summary of Safety and Effectiveness for the Irrigating Cannula

Submitted by CA-Guard, LTD. 610 E. Olympia Ave Punta Gorda, FL 33950 Phone: (941) 833-1102

Contact Person:Al Weisenborn
Device Trade Name:Irrigating Cannula
Common Name:Cannula
Classification Name:Endoscopes and Accessories, per 21 CFR §876.1500

Identification of a Legally Marketed Predicate Device

The Irrigating Cannula is substantially equivalent to the cannula manufactured and marketed by the United States Surgical Corporation as part of the Versaport® Trocar System pursuant to 510(k) K954108.

General Description

The Irrigating Cannula is a non-toxic, sterile, single use, disposable surgical access port. The device is intended to be inserted percutaneously into the peritoneal cavity to provide access for endoscopic instruments. The cannula is intended to replace the cannula that is supplied with the United States Surgical Versaport® 11mm Trocar System.

The proximal end of the cannula is equipped with a female luer connector. The luer communicates with 6 longitudinal grooves on the surface of the inner member of the cannula. The inner member is covered with polyolefin shrink tubing. An array of twenty-four (24) holes deliver infusate to the compromised tissue surfaces of the trocar wound.

Intended Use

The CA-Guard Irrigating Cannula is intended to provide an access port to body cavities for endoscopes and endoscopic accessories when intraoperative irrigation or infusion of trocar wound surfaces is desired. The cannula has been tested for compatibility with lidocaine and marcane. Saline and water may also be used as irrigants. The CA-Guard Irrigating Cannula is inherently a needleless system and therefore, minimizes the possibility of "needle sticks" for healthcare workers, in accordance with the Needlestick Safety and Prevention Act of 2000.

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The CA Guard Irrigating Cannula is designed to be mechanically compatible with all components of the United States Surgical Versaport® 11mm Trocar System using the 5 mm PLUS SEAL.

Summary of Technological Characteristics

The Irrigating Cannula was compared to the predicate device using 14 points of comparison and found to be equivalent.

Summary of Performance Data

Performance of the device was characcterized and compared to that of the predicate utilizing 5 tests. Additionally, the cannula was tested for compatibility with the indicated infusates. The tests demonstrated the Irrigating Cannula is substantially equivalent to the masula manufactured and marketed by the United States Surgical Corporation as part of the Versaport® Trocar System pursuant to 510(k) K954108. The materials of construction have been carefully selected for their long history of biocompatibility.

Since the Irrigating Cannula embodies technological characteristics essentially identical to those of the predicate device, we believe the device is safe and effective and that it performs as well as or better than the predicate device. The device has been designed and developed utilizing design control methods in compliance with the QSR. The Irrigating Cannula will be manufactured per specifications and good manufacturing practices that ensure the device is safe and effective for its intended use.

§ 876.1500 Endoscope and accessories.

(a)
Identification. An endoscope and accessories is a device used to provide access, illumination, and allow observation or manipulation of body cavities, hollow organs, and canals. The device consists of various rigid or flexible instruments that are inserted into body spaces and may include an optical system for conveying an image to the user's eye and their accessories may assist in gaining access or increase the versatility and augment the capabilities of the devices. Examples of devices that are within this generic type of device include cleaning accessories for endoscopes, photographic accessories for endoscopes, nonpowered anoscopes, binolcular attachments for endoscopes, pocket battery boxes, flexible or rigid choledochoscopes, colonoscopes, diagnostic cystoscopes, cystourethroscopes, enteroscopes, esophagogastroduodenoscopes, rigid esophagoscopes, fiberoptic illuminators for endoscopes, incandescent endoscope lamps, biliary pancreatoscopes, proctoscopes, resectoscopes, nephroscopes, sigmoidoscopes, ureteroscopes, urethroscopes, endomagnetic retrievers, cytology brushes for endoscopes, and lubricating jelly for transurethral surgical instruments. This section does not apply to endoscopes that have specialized uses in other medical specialty areas and that are covered by classification regulations in other parts of the device classification regulations.(b)
Classification —(1)Class II (special controls). The device, when it is an endoscope disinfectant basin, which consists solely of a container that holds disinfectant and endoscopes and accessories; an endoscopic magnetic retriever intended for single use; sterile scissors for cystoscope intended for single use; a disposable, non-powered endoscopic grasping/cutting instrument intended for single use; a diagnostic incandescent light source; a fiberoptic photographic light source; a routine fiberoptic light source; an endoscopic sponge carrier; a xenon arc endoscope light source; an endoscope transformer; an LED light source; or a gastroenterology-urology endoscopic guidewire, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.(2) Class I for the photographic accessories for endoscope, miscellaneous bulb adapter for endoscope, binocular attachment for endoscope, eyepiece attachment for prescription lens, teaching attachment, inflation bulb, measuring device for panendoscope, photographic equipment for physiologic function monitor, special lens instrument for endoscope, smoke removal tube, rechargeable battery box, pocket battery box, bite block for endoscope, and cleaning brush for endoscope. The devices subject to this paragraph (b)(2) are exempt from the premarket notification procedures in subpart E of part 807of this chapter, subject to the limitations in § 876.9.