(88 days)
The EndoGastric Solutions (EGS) EsophyX™ System with SerosaFuse™ Fastener is indicated for use in endoluminal, transoral tissue approximation, full thickness plication and ligation in the GI tract and is indicated for the treatment of symptomatic chronic gastroesophageal reflux disease in patients who require and respond to pharmacological therapy. It is also indicated to narrow the gastroesophageal junction and reduce hiatal hernia ≤ 2cm in size in patients with symptomatic chronic gastroesophageal reflux disease.
The EndoGastric Solutions SerosaFuse™ implantable fasteners, and associated EsophyX delivery device and accessories consist of sterile polypropylene fastener implants and an ergonomic, flexible fastener delivery device. The fasteners and delivery devices are provided sterile and are for single use. The polypropylene fasteners are proprietary and function only with the EGS delivery devices. The delivery devices use either a stainless steel helix or suction to grasp tissue and fasten it using the SerosaFuse polypropylene fasteners. The fastener delivery subsystem comprises 3 elements: stylet, pusher, and a lumen. They run the length of the device, the pusher being a hollow tube that rides over the length of the stylet, both riding in the lumen. The stylet is sharp at the distal tip to pierce tissue. The fastener is loaded by snapping it onto the stylet in the loading port of the handle. When pushed by the operator, the stylet carries the fastener down the lumen which runs from the proximal handle assembly to the distal tissue port where it will eventually be deployed into the tissue.
The provided text describes a 510(k) summary for the EndoGastric Solutions (EGS) EsophyX™ System with SerosaFuse™ Fastener and accessories. A 510(k) submission primarily demonstrates substantial equivalence to a predicate device, rather than proving device performance against specific acceptance criteria through a clinical study with detailed statistical outcomes.
Therefore, the requested information regarding acceptance criteria, reported device performance, sample size, data provenance, expert adjudication, MRMC study, standalone performance, ground truth establishment, and training set details are not explicitly available in the provided document. The document focuses on device description, intended use, and comparison to predicate devices for regulatory approval based on substantial equivalence.
Here's what can be extracted based on the limitations of the provided document:
1. A table of acceptance criteria and the reported device performance:
- Not explicitly provided. The document focuses on demonstrating substantial equivalence to predicate devices, not on meeting specific, quantifiable acceptance criteria with reported performance metrics from a study.
2. Sample size used for the test set and the data provenance:
- Not provided. The document does not describe a performance study with a test set. It mentions a 510(k) submission which relies on comparison to predicate devices, not typically a new clinical study for performance metrics in the way implied by these questions.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable/Provided. No specific test set or ground truth establishment by experts is described in the context of this 510(k) summary.
4. Adjudication method for the test set:
- Not applicable/Provided. No test set requiring adjudication is described.
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:
- Not applicable/Provided. This device is an endoscopic tissue approximation/plication system, not an AI-assisted diagnostic device that would typically involve human readers and an MRMC study.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable/Provided. This is a medical device for tissue approximation, not an algorithm.
7. The type of ground truth used:
- Not applicable/Provided. As there is no described performance study for the device against specific criteria, the concept of a "ground truth" for performance evaluation is not detailed.
8. The sample size for the training set:
- Not applicable/Provided. This device is not an AI/algorithm-based system that requires a "training set."
9. How the ground truth for the training set was established:
- Not applicable/Provided. As there is no training set mentioned, this information is not relevant or provided.
In summary, the provided 510(k) summary primarily demonstrates substantial equivalence to existing predicate devices based on intended use and method of operation. It does not detail specific performance studies with acceptance criteria, test sets, or ground truth establishment in the manner typically associated with the evaluation of AI or diagnostic devices.
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510(k) SUMMARY 3
This summary of 510(k) safety and effectiveness information is submitted in accordance with the requirements of SMDA 1990 and 21 CFR 807.92.
SEP 1 4 2007 510(k) Number: K071651
Applicant Information:
| Date Prepared: | June 14, 2007 |
|---|---|
| Date Revised | September 12, 2007 |
| Name: | EndoGastric Solutions, Inc. |
| Address: | 8210 154th Avenue N.E.Redmond, WA 98052Phone: 425 307 9200Fax: 425 307 9201 |
| Contact Person: | Michael A. Daniel |
| Phone Number: | Office: 925-254-5228 / Cell 415-407-0223 |
| Facsimile Number: | (925) 254-5187 |
Device Information:
| Classification: | Class II |
|---|---|
| Trade Name: | EndoGastric Solutions (EGS) EsophyX™ System with SerosaFuse™Fastener and accessories |
| Common Name: | Endoscopic tissue approximation/plication system |
| Classification Name: | Nonabsorbable Polypropylene Surgical Suture GAW / 21 CFR 878.5010Endoscopic Suture/Plication System, (GERD) ODE / 21 CFR 876.1500Endoscopic Tissue Approximation Device OCW / 21 CFR 876.1500 |
Predicate Devices:
The EndoGastric Solutions (EGS) EsophyX™ System with SerosaFuse™ Fastener and accessories is substantially equivalent in intended use and method of operation to a combination of the following predicate devices:
| NDO Surgical Endoscopic Plication System | K023234 |
|---|---|
| Bard Endoscope Suturing System / Bard EndoCinch | K994290 / K003956 |
| EGS StomaphyX TM endoluminal fastener and delivery system | K062875 |
EndoGastric Solutions, Inc. 510(k) Submission.
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Device Description:
The EndoGastric Solutions SerosaFuse™ implantable fasteners, and associated EsophyX delivery device and accessories consist of sterile polypropylene fastener implants and an ergonomic, flexible fastener delivery device. The fasteners and delivery devices are provided sterile and are for single use. The polypropylene fasteners are proprietary and function only with the EGS delivery devices. The delivery devices use either a stainless steel helix or suction to grasp tissue and fasten it using the SerosaFuse polypropylene fasteners. The fastener delivery subsystem comprises 3 elements: stylet, pusher, and a lumen. They run the length of the device, the pusher being a hollow tube that rides over the length of the stylet, both riding in the lumen. The stylet is sharp at the distal tip to pierce tissue. The fastener is loaded by snapping it onto the stylet in the loading port of the handle. When pushed by the operator, the stylet carries the fastener down the lumen which runs from the proximal handle assembly to the distal tissue port where it will eventually be deployed into the tissue.
Intended Use:
The EndoGastric Solutions (EGS) EsophyX™ System with SerosaFuse™ Fastener is indicated for use in endoluminal, transoral tissue approximation, full thickness plication and ligation in the GI tract and is indicated for the treatment of symptomatic chronic gastroesophageal reflux disease in patients who require and respond to pharmacological therapy. It is also indicated to narrow the gastroesophageal junction and reduce hiatal hernia ≤ 2cm in size in patients with symptomatic chronic gastroesophageal reflux disease.
Comparison to Predicate Device(s):
The design of the EndoGastric Solutions SerosaFuse™ implantable fasteners, associated delivery devices and accessories is similar to the predicates listed in that they are all devices designed to reach the desired suture location under endoscopic visualization, grasp tissue and place sutures/clips in a desired location. All products are re-loadable for repeat fastener/suture/clip placement. The products all share common features such as a sterile, stainless steel needle (called a stylet in the EGS delivery devices) housed in a suture loading unit (the delivery device), They all deliver fastener/suture/clips through soft tissue by manually actuating the needle with a handle mechanism. All devices are packaged sterile and are for single patient use. Further, the EndoGastric Solutions SerosaFuse™ implantable fasteners, associated delivery devices and accessories and the predicate devices have the same or similar intended use.
Summary:
Based upon the intended use, descriptive information, and performance evaluation provided in this pre-market notification, the EndoGastric Solutions SerosaFuse™ implantable fasteners, associated delivery devices and accessories have been shown to be substantially equivalent to currently marketed predicate devices.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo is a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is an abstract image of an eagle.
Food and Drug Administration 9200 Corporate Blvd. Rockville MD 20850
SEP 1 4 2007
Mr. Michael A. Daniel Vice President, Regulatory and Clinical Affairs EndoGastric Solutions™, Inc. 8210 154th Avenue, N.E. REDMOND WA 98052
Re: K071651
Trade/Device Name: EsophyX™System with EGS SerosaFuse™ Fasteners and accessories Regulation Number: 21 CFR §876.1500 Regulation Name: Endoscope and accessories Regulatory Class: II Product Code: ODE Dated: June 15, 2007 Received: June 18, 2007
Dear Mr. Daniel:
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.
If your device is classified (see above) into either class II (Special Controls) or class III (Premarket Approval), 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.
Image /page/2/Picture/10 description: The image is a black and white seal for the FDA Centennial 1906-2006. The seal is circular with text around the perimeter. The center of the seal has the letters FDA in a stylized font with the word Centennial underneath. There are three stars below the word Centennial.
Protecting and Promoting Public Health
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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 (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.
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), please contact the Office of Compliance at one of the following numbers, based on the regulation number at the top of this letter:
| 21 CFR 876.xxx | (Gastroenterology/Renal/Urology) | 240-276-0115 |
|---|---|---|
| 21 CFR 884.xxx | (Obstetrics/Gynecology) | 240-276-0115 |
| 21 CFR 894.xxx | (Radiology) | 240-276-0120 |
| Other | 240-276-0100 |
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). 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 (240) 276-3150
or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely yours,
Nancy Cbrogdon
Nancy C. Brogdon Director, Division of Reproductive, Abdominal, and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known): K07/65/
EndoGastric Solutions (EGS) EsophyX™ System with SerosaFuse™ Device Name: Fastener and accessories
Indications For Use:
The EndoGastric Solutions (EGS) EsophyX™ System with SerosaFuse™ Fastener is indicated for use in endoluminal, transoral tissue approximation, full thickness plication and ligation in the GI tract and is indicated for the treatment of symptomatic chronic gastroesophageal reflux disease in patients who require and respond to pharmacological therapy. It is also indicated to narrow the gastroesophageal junction and reduce hiatal hernia ≤ 2cm in size in patients with symptomatic chronic gastroesophageal reflux disease.
Prescription Use X (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Herbert Lehman
(Division Sign-Off Division of Reproductive, Abdominal a Radiological Devices 510(k) Number
Page 1 of 1
EndoGastric Solutions, Inc. 510(k) Submission. June 15, 2007.
§ 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.