K Number
K072404
Device Name
ERBE ERBEJET 2 SYSTEM
Manufacturer
Date Cleared
2007-10-31

(65 days)

Product Code
Regulation Number
880.5475
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The ERBEJET® 2 System is intended for the cutting and dissection of soft tissue in neurosurgery and soft tissue such as the liver, kidney, etc. within the abdomen, including Total Mesorectal Excision (TME), in open as well as endoscopic surgery.
Device Description
The ERBEJET® 2 System delivers pressurized normal saline solution (0.9% saline solution for irrigation) to cut and dissect soft tissue. The ERBEJET® 2 Unit together with its accessories is an active invasive surgical product. The sterile normal saline solution is the "cutting medium" which is projected under pressure through a nozzle. The pressure is generated by a sterile single-use double piston Pump Cartridge and is controlled by means of a Footswitch. The Footswitch has a "ReMode" button that allows the user to switch between two established or "set" programs during the surgical procedure. The ERBEJET® 2 Unit has a display screen that allows the user to adjust the desired pressure settings using effect levels (1 to 80). The user may use the BASIC program that comes preprogrammed or set up to nine additional personalized programs. The cutting medium is isolated from the pressure generation Unit (i.e. the ERBEJET® 2 Unit) except at the sterile Pump Cartridge. A range of Applicators with a nozzle diameter of 120 µm is available for a wide range of applications. An integrated suction function (i.e. the Suction Module, Model ESM 2 which is separate and optional) can be used with the Unit and is adjustable up to -12 psi. Settings for the suction are adjusted on the display screen of the ERBEJET® 2 Unit.
More Information

No
The device description focuses on mechanical and hydraulic principles (pressurized saline, pump cartridge, footswitch, pressure settings) and programmable user-defined settings. There is no mention of AI, ML, or any adaptive or learning algorithms. The "ReMode" and personalized programs are static, user-defined configurations, not AI/ML.

No
The device is used for cutting and dissecting tissue during surgery, which is an interventional procedure, not a therapeutic treatment.

No

The device is described as being for "cutting and dissection of soft tissue," which is a therapeutic function, not a diagnostic one. It delivers a pressurized saline solution to physically alter tissue.

No

The device description clearly outlines multiple hardware components including a unit, pump cartridge, footswitch, applicators, and an optional suction module. While it has a display screen and programmable settings, it is fundamentally a hardware-based system that utilizes software for control and display.

Based on the provided information, the ERBEJET® 2 System is not an IVD (In Vitro Diagnostic) device.

Here's why:

  • IVD devices are used to examine specimens derived from the human body. This includes things like blood, urine, tissue samples, etc., to provide information about a person's health status.
  • The ERBEJET® 2 System is a surgical device. Its intended use is for the cutting and dissection of soft tissue within the body during surgical procedures. It uses a saline solution to physically manipulate tissue, not to analyze biological samples.

The description clearly outlines a surgical tool used for direct intervention on the patient's body, which is the defining characteristic of a non-IVD medical device in this context.

N/A

Intended Use / Indications for Use

The ERBEJET® 2 System is intended for the cutting and dissection of soft tissue in neurosurgery and soft tissue such as the liver, kidney, etc. within the abdomen, including Total Mesorectal Excision (TME), in open as well as endoscopic surgery.

Product codes

FQH

Device Description

The ERBEJET® 2 System delivers pressurized normal saline solution (0.9% saline solution for irrigation) to cut and dissect soft tissue. The ERBEJET® 2 Unit together with its accessories is an active invasive surgical product. The sterile normal saline solution is the "cutting medium" which is projected under pressure through a nozzle. The pressure is generated by a sterile single-use double piston Pump Cartridge and is controlled by means of a Footswitch. The Footswitch has a "ReMode" button that allows the user to switch between two established or "set" programs during the surgical procedure. The ERBEJET® 2 Unit has a display screen that allows the user to adjust the desired pressure settings using effect levels (1 to 80). The user may use the BASIC program that comes preprogrammed or set up to nine additional personalized programs. The cutting medium is isolated from the pressure generation Unit (i.e. the ERBEJET® 2 Unit) except at the sterile Pump Cartridge. A range of Applicators with a nozzle diameter of 120 µm is available for a wide range of applications. An integrated suction function (i.e. the Suction Module, Model ESM 2 which is separate and optional) can be used with the Unit and is adjustable up to -12 psi. Settings for the suction are adjusted on the display screen of the ERBEJET® 2 Unit.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

soft tissue in neurosurgery and soft tissue such as the liver, kidney, etc. within the abdomen, including Total Mesorectal Excision (TME)

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)

The ERBEJET® 2 System shows improved linear distribution than the predicate device.

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

Not Found

Predicate Device(s)

K033590, K022613, K012464

Reference Device(s)

K061205, K043544

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 880.5475 Jet lavage.

(a)
Identification. A jet lavage is a device used to clean a wound by a pulsatile jet of sterile fluid. The device consists of the pulsing head, tubing to connect to a container of sterile fluid, and a means of propelling the fluid through the tubing, such as an electric roller pump.(b)
Classification. Class II (special controls). The device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to § 880.9.

0

K072404

CONFIDENTIAL

ERBE USA Incorporated Abbreviated 510(k) - ERBE ERBEJET® 2 System

510K SUMMARY

| Submitted By: | ERBE USA, Inc.
2225 Northwest Parkway
Marietta, GA 30067
Tel: 770-955-4400 Fax: 770-955-2577 | OCT 31 2007 |
|----------------------------------------|-------------------------------------------------------------------------------------------------------|-------------|
| Contact Person: | John Tartal
QA/RA Manager | |
| Date Prepared: | August 23, 2007 | |
| Common Name: | Water Jet Dissector | |
| Trade/Proprietary Name: | ERBE ERBEJET® 2 System | |
| Classification Name: | Jet Lavage (21 CFR Part 880.5475) | |
| Product Code: | FQH | |
| Legally Marketed
Predicate Devices: | ERBE Helix Hydro-Jet™ System, 510(k) Numbers: K033590;
K022613; K012464 | |

Device Description:

The ERBEJET® 2 System delivers pressurized normal saline solution (0.9% saline solution for irrigation) to cut and dissect soft tissue. The ERBEJET® 2 Unit together with its accessories is an active invasive surgical product. The sterile normal saline solution is the "cutting medium" which is projected under pressure through a nozzle. The pressure is generated by a sterile single-use double piston Pump Cartridge and is controlled by means of a Footswitch. The Footswitch has a "ReMode" button that allows the user to switch between two established or "set" programs during the surgical procedure. The ERBEJET® 2 Unit has a display screen that allows the user to adjust the desired pressure settings using effect levels (1 to 80). The user may use the BASIC program that comes preprogrammed or set up to nine additional personalized programs. The cutting medium is isolated from the pressure generation Unit (i.e. the ERBEJET® 2 Unit) except at the sterile Pump Cartridge. A range of Applicators with a nozzle diameter of 120 µm is available for a wide range of applications. An integrated suction function (i.e. the Suction Module, Model ESM 2 which is separate and optional) can be used with the Unit and is adjustable up to -12 psi. Settings for the suction are adjusted on the display screen of the ERBEJET® 2 Unit.

Intended Use:

The ERBEJET® 2 System is intended for the cutting and dissection of soft tissue in neurosurgery and soft tissue such as the liver, kidney, etc. within the abdomen, including Total Mesorectal Excision (TME), in open as well as endoscopic surgery.

1

ERBE USA Incorporated Abbreviated 510(k) - ERBE ERBEJET® 2 System

510K SUMMARY

Similarities and Differences of the Proposed Devices to the Predicate Devices Comparison/Substantial Equivalence):

Similarities

The ERBEJET® 2 System has the same indications for use as the predicate device. The mechanical and technical aspects of creating the pressurized "cutting medium" have changed; however, the performance (i.e. the pressure and volume flow) is substantially equivalent. See Section I, Chart on I-10 as well as Section III, Comparison of System Outputs and Performance Testing. The Applicators are similar to the predicate device with slight differences. See Section III, Comparison Table. However, the volume flow and pressures through the nozzle are equivalent. Under testing, the ERBEJET® 2 System shows improved linear distribution than the predicate device. See Section I, Chart on I-10. Although the suction pump (i.e. Suction Module, Model ESM 2) is separate from the ERBEJET® 2 Unit, the functions are integrated into the ERBEJET® 2 Unit via its display screen which is equivalent to the predicate device. While both systems have a display screen, the display of the ERBEJET® 2 Unit is easier for the user to understand and navigate through.

Differences

The ERBEJET® 2 System uses a two head piston Pump Cartridge to create the pressurized "cutting medium" while the predicate device uses a hydraulic piston. The predicate device has a high-pressure range up to 2,175 psi; however, it was determined by user feedback that this high-pressure range was not utilized. The modified device has a high-rovousure range up to 1,160 psi (80 bar). With the removal of the large hydraulic piston, the size and weight of the ERBEJET® 2 Unit has decreased substantially and the procent the one the proposed unit has improved because there is no hydraulic oil to change. The Applicators have differences in materials, which were tested under biocompatibility. See Spetion III, Biocompatibility. In addition, the Applicators have slight differences in their dimensions. See, Section III, Comparison Table. The changes were made as a result of user forely ack. There is a small amount of fluid, less than 0.2 ml, released at the end of activation with the ERBEJET® 2 System due to the way the flow shutoff valves close off. Conversely, the Helix Hydro-Jet has shown almost no water released at the end of activation. No safety or efficacy issues are expected from the release of the small amount of residual fluid a the end of activation with the ERBEJET® 2 System.

The ERBEJET® 2 System has been verified or validated in design control by ERBE Elektromedizin GmbH.

Conclusion:

The ERBEJET® 2 System has the same intended use, principles of operation, and technological characteristics as the predicate device. The ERBEJET® 2 System is smaller and easier to use. In conclusion, all the changes were verified or validated. As a mailer the changes did not raise safety or efficacy concerns nor adversely affect safety or effectiveness.

2

ERBE USA Incorporated Abbreviated 510(k) – ERBE ERBEJET® 2 System

CharacteristicsPredicate DeviceProposed Device
ManufacturerHumanMed AG
[Used to be Andreas Pein
Medizintechnik GmbH]ERBE Elektromedizin GmbH
510(k) ApplicantERBE USA, Inc. and Andreas
Pein Medizintechnik GmbHERBE USA, Inc.
510(k) NumberK033590; K022613; K012464Pending
Classification Regulation
Product Code, NameClass II, 21 CFR 880.5475
FQH, Jet LavageSame
Device NameHelix Hydro-Jet™ System
[Includes Fluid Cartridge,
Applicators, etc.]ERBEJET® 2 System
[Includes Pump Cartridge,
Applicators, Separate/Optional
Suction Module ESM 2, etc.]
Indications For UseThe Helix Hydro-Jet™ is intended
for the cutting and dissection of
soft tissue in neurosurgery and
soft tissue such as the liver,
kidney, etc. within the abdomen,
including Total Mesorectal
Excision (TME), in open as well
as endoscopic surgery.Same
Materials
• UnitMetal Sheet, Glass Display
Screen, Plastics, WiringSame
• Components
• Connecting CablesInsulation Plastic, Wiring, MetalsSame
• FootswitchAluminum, Plastics, Insulation
Plastics, RubberSame
• Fluid (Application)
Cartridge0.9% Normal Saline Solution,
Plastics (Polyethylene), SiliconeNot Applicable
• Pump CartridgeNot ApplicablePlastics (PA, TPE, PC, PVC),
Silicone
• ApplicatorsPlastics (PEEK, PA, PVC),
Stainless Steel, Silicone,
Synthetic Jewel (Corundum)Plastics (ABS, PA, PVC),
Stainless Steel, Silicone, Rubber,
Synthetic Jewel (Corundum)
• Suction Module
(ESM 2)The suction system of the Helix
Hydro-Jet™ is integrated inside
the Unit's case (see above).Metal Sheet, Plastics, Wiring
CharacteristicsPredicate DeviceProposed Device
• Suction AccessoriesContainer and Top:
Polycarbonate and
thermoplastic elastomerContainer:
Shock-resistant polycarbonate
Top:
Reinforced polyamide with
santoprene seal
Bag:
Two layers (Polyethylene inner
lining with polypropylene)Bag:
Three layers for durability and
odor protection (polyethylene/
polyamide / polyester)
Hose: Silicone, Rubber O-rings
Filter: Not Applicable
Switching Valve: Not Applicable
Rails & Brackets: Not ApplicableHose: Silicone, Rubber O-rings
Filter: Plastics
Switching Valve: Plastics
Rails & Brackets: Aluminum
Note: The suction accessories
are manufactured by Medela AG
in Switzerland (see additional
information at the end of the
Table).
Physical and Dimensional Attributes
• Unit
• Length13.8" (35 cm)14.6" (37 cm)
• Width13.8" (35 cm)16.1" (41 cm)
• Height4.0' (122 cm)5.1" (13 cm)
• MountingIncluded, 19.6" (50 cm) x 19.6"
(50 cm) [Base including wheels]Mountable to VIO Cart or Boom
• Weight163 lbs (74 kg)24.3 lbs (11kg)
• Components
• Connecting CablesMain Cable (Power Cord), UL-
Version, Length 4 m (13.2')Same
Not Applicable –
Suction is integrated inside the
UnitECB Connecting Cable,
Connects ERBEJET 2 with
Suction Module, ESM 2
• FootswitchOne Pedal Footswitch, AP and IP
X8 EquipmentOne Pedal Footswitch, AP and IP
X8 Equipment, with ReMode
• Fluid CartridgeSterile 0.9% Normal Saline
Solution in Plastic Bottle, 485 mlNot Applicable (see Pump
Cartridge)
CharacteristicsPredicate DeviceProposed Device
• Pump CartridgeNot Applicable (see Fluid
Cartridge)User connects Sterile 0.9%
Normal Saline Solution for
Irrigation to Pump Cartridge;
Saline is purchased separately
from other sources
• ApplicatorsApplicator, Blunt Dissector, Outer
Diameter (OD) 5mm x Length
180mm, Curved TipSame - except Length 183mm
Applicator, Blunt Dissector, Outer
Diameter (OD) 5mm x Length
336mm, Curved TipSame,
Applicator with Suction, Length 60
mm Flexible Sheath/Rigid TipSame - except Length 65 mm
Applicator with Suction, Outer
Diameter (OD) 6 mm x Length
300 mm Rigid Sheath/TipSame - except Length 306 mm
Applicator with Suction, Outer
Diameter (OD) 2.6 mm x Length
60 mm Bayonet Sheath/TipSame - except O.D. 2.8 mm and
Length 90 mm
• Suction SystemIntegrated within the Helix Hydro-
Jet UnitIntegrated for use with the
ERBEJET 2 Unit but separate/
optional module - ESM 2
Suction Container (2,000 ml)ESM Suction Container (2,000
ml)
Suction Bag (2,000 ml)ESM Suction Bag (2,000 ml)
Suction Container Top (included
with Suction Container above)
Suction HoseESM Suction Container Top (sold
separately from Container)
ESM Suction Hose, Length 30 cm
Not ApplicableESM Membrane Filter, 0.3 µm
Not ApplicableSwitching Valve w/ Suction
Hoses & Mounting Bracket
Not ApplicableMounting Bracket to Connect to
Side Rails
Not ApplicableBrackets/Side Rails, Length 260
mm and 390 mm
Energy DeliveredPressurized sterile saline for
cutting and dissectingSame
Supply Voltage and
Current100-120 V; 10 A120-240 V; 3 A
Frequency60 HzSame
CharacteristicsPredicate DeviceProposed Device
Pressure Range1 to 2,175 psi14.5 to 1,160.3 psi
Suction Range-1.45 to -11.6 psi (-12 psi on
display)Same
Nozzle Diameter120 μmSame
Volume Flow1 to 55 ml/min
(As measured within same
pressure range as the proposed
device)1 to 55 ml/min
Target PopulationPatients requiring open or
endoscopic surgery in
neurosurgery and in and around
the abdomenSame
Anatomical SitesSoft tissue in neurosurgery and
soft tissue such as the liver,
kidney, etc. within the abdomen,
including Total Mesorectal
Excision (TME), in open as well
as endoscopic surgerySame
• Unit, Connecting
Cables, FootswitchesNon-Sterile, ReusableSame
• Fluid CartridgeSterile, Single-Use, Radiation (R)Not Applicable
• Pump CartridgeNot ApplicableSterile, Single-Use, Radiation (R)
• ApplicatorsSterile, Single-Use, Ethylene
Oxide (EO)Same
• Suction System
Unit/ModuleWithin Helix Unit (see above)Non-Sterile, Reusable
BagsNon-Sterile, DisposableSame
Containers and HosesNon-Sterile, ReusableSame (includes Brackets/Rails)
Performance
Standards MetEN 60601-1; UL 2601-1; EN
60601-1-2; IEC 60529
(Footswitch Only)EN 60601-1; UL 60601-1;
EN 60601-1-1; EN 60601-1-2;
EN 60601-1-4; EN 60601-1-6;
EN ISO 10079-1;
IEC 60529 (Footswitch Only)
Other Standards
Used or Applied/MetISO 10993-1; ISO 10993-4; ISO-
10993-5; ISO 10993-10; ISO
10993-11; EN 556; EN 980; EN
868-1; EN 550; EN 552; EN 1441Same except for replaced or
newer standards:
ISO 11607; ISO 14971
CharacteristicsPredicate DeviceProposed Device
FDA Guidance
Documents UsedNot Known General Principles of Software
Validation, Version 1.1, dated
June 9, 1997 Guidance for FDA Reviewers
and Industry; Guidance for the
Content of Premarket
Submissions for Software
Contained in Medical Devices,
May 29, 1998Guidance Document for
Powered Suction Pump
510(k)s: Sep. 30, 1998 General Principles of
Software Validation; Final
Guidance for Industry and
FDA Staff; Jan. 11, 2002 Guidance for FDA Reviewers
and Industry; Guidance for
the Content of Premarket
Submissions for Software
Contained in Medical
Devices; May 11, 2005
Packaging and LabelingUnit Unit Label Instruction Sheet/Quick Guide User Manual Components Not Applicable Not Applicable Applicators Outer Package
Labels Applicators Notes on Use
Labeling Fluid Cartridge Outer Package
Labels Fluid Cartridge Notes on Use
Labeling Not Applicable Not Applicable Suction Accessories Outer
Package Labels Not ApplicableUnit Unit Label Not Available User Manual Components ESM 2 Module Label ESM 2 User Manual Applicators Outer Package
Labels Applicators Notes on Use
Labeling Not Applicable Not Applicable Pump Cartridge Outer
Package Labels Pump Cartridge Notes on Use
Labeling Suction Accessories Outer
Package Labels ESM 2 Filter Package Label

3

ERBE USA Incorporated Abbreviated 510(k) – ERBE ERBEJET® 2 System

CONFIDENTIAL

4

CONFIDENTIAL

ERBE USA Incorporated Abbreviated 510(k) – ERBE ERBEJET® 2 System


5

ERBE USA Incorporated Abbreviated 510(k) – ERBE ERBEJET® 2 System



CONFIDENTIAL

6

CONFIDENTIAL

ERBE USA Incorporated Abbreviated 510(k) – ERBE ERBEJET® 2 System

COMPARISON TABLE

Suction Accessories:

Medela AG 3002807523 in Switzerland has 510(k)s for their "powered suction pumps" under the product code "BTA" [510(k) # K061205 for the Vario 8/18ci Systems and 510(k) # K043544 for the Dominant 35c/i System] which includes their suction accessories. The ESM 2 suction modele is designed and manufactured by ERBE Elektromedizin GmbH and distributed by ERBE USA Incude 18 suction accessories that are being recommended and distributed for use with the ESM 2 suction module are the Medela AG suction accessories as designated under the Medela AG 510(k)s.

7

Image /page/7/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle or bird-like figure with three curved lines representing its body and wings. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular fashion around the bird figure.

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

OCT 3 1 2007

ERBE USA Inc. % Mr. John Tartal QA/RA Manager 2225 Northwest Parkway Marietta, Georgia 30067-9317

Re: K072404

Trade/Device Name: ERBE USA, Inc.'s ERBEJET® 2 System Regulation Number: 21 CFR 880.5475 Regulation Name: Jet lavage Regulatory Class: II Product Code: FQH Dated: August 23, 2007 Received: August 27, 2007

Dear Mr. Tartal:

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 (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 (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.

8

Page 2 - Mr. John Tartal

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 (240) 276-0115. 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 toll-free number (800) 638-2041 or (240) 276-3150 or the Internet address http://www.fda.gov/cdrb/industry/support/index.html.

Sincerely yours,
Mark A. Milburn

Mark N. Melkerson Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

9

Indications for Use

072404 510(k) Number (if known):

Device Name: ERBE USA, Inc.'s ERBEJET® 2 System

Indications For Use:

The ERBEJET® 2 System is intended for the cutting and dissection of soft tissue in neurosurgery and soft tissue such as the liver, kidney, etc. within the abdomen, including Total Mesorectal Excision (TME), in open as well as endoscopic surgery.

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

Mark A. Melkerson

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

510(k) Number K072404

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