(62 days)
PAJUNK®'s Kit for balloon aided laparoscopy is intended for making incisions into the patients body to allow insertion of endoscopes and endoscopic accessories during general and minimal invasive surgical procedures.
The kit provides a common port with trocar and valve closure (for gaining acces for minimal invasive surgery) packed in a separate bag within the sterilized unit and a rigid balloon guidance with obturator and filling syringe (for insertion of the endoscopic visualisation device) packed in another separate bag. Both units are available seperately and as a procedure unit.
It is especially intended for diagnostics and aftercare in minimal invasive procedures.
Due to the length of the balloon quidance and the clinical practice there is no need to create a pneumoperitoneum via insufflation
The port may be left in place for up to 10 days with the seal closure trocar in place.
The kit is sterile and intended for single use.
The provided text describes a 510(k) premarket notification submission for PAJUNK®'s Kit for balloon aided laparoscopy. This submission is for a medical device, not an AI/ML powered device, and therefore does not contain information typically associated with AI/ML device studies and acceptance criteria.
The submission focuses on demonstrating substantial equivalence to predicate devices already cleared for market, rather than proving performance against specific acceptance criteria through clinical studies in the way an AI/ML device would.
Therefore, many of the requested sections about acceptance criteria, device performance, sample sizes, ground truth, expert involvement, and MRMC studies are not applicable to this document. The document describes a traditional medical device submission process for demonstrating safety and effectiveness based on equivalence to existing devices.
However, I can extract information related to the device's intended use, components, and the comparison to predicate devices, which forms the basis of its acceptance for market clearance.
Here's a breakdown of the relevant information from the document and why other sections are not applicable:
1. Table of Acceptance Criteria and Reported Device Performance:
- Acceptance Criteria: For this type of device (a Class II Endoscope and accessories), the "acceptance criteria" for 510(k) clearance are primarily centered around demonstrating substantial equivalence to legally marketed predicate devices in terms of:
- Intended Use: The new device must have the same intended use as the predicate or a modified intended use that does not raise new questions of safety and effectiveness.
- Technological Characteristics: The new device must have the same technological characteristics as the predicate, or different technological characteristics that do not raise new questions of safety and effectiveness and are supported by appropriate scientific testing.
- Safety and Effectiveness: The device must be as safe and effective as the predicate device(s).
- Reported Device Performance: The submission asserts that the device is "substantially equivalent to the predicate devices and safe and effective" based on:
- Comparison of technological characteristics.
- Validated sterilization process.
- Biocompatibility data (not detailed in this excerpt but mentioned).
- The "optional use of optical devices (image giving endoscopes) in order to monitor the procedure and to conduct manually operated interventions under sight/ view are at least as safe and effective as common techniques are, actually this is intended to enhance safety and effectiveness."
Table format (interpreted for this traditional device):
| Acceptance Criteria Category (for 510(k) Substantial Equivalence) | Reported Device Performance / Basis for Acceptance |
|---|---|
| Intended Use Equivalence | Device Statement: "PAJUNK®'s Kit for balloon aided laparoscopy is intended for making incisions into the patients body to allow insertion of endoscopes and endoscopic accessories during general and minimal invasive surgical procedures... It is especially intended for diagnostics and aftercare."Comparison: Predicate devices are indicated for "minimal invasive procedures." The subject device is indicated for "inserting and guiding optical endoscopes for aftercare and diagnostics." The submission states this is discussed for substantial equivalence. |
| Technological Characteristics Equivalence | Device Components: Kit consists of a Port (with Trocar, Seal closure trocar) and a Balloon guidance (with Obturator, Filling syringe).Comparison: Features combine "technical features of PAJUNK®'s devices already approved for market" (K012771 Trocar Sleeve and accessories - balloon systems; K063528 TrokaSys). Detailed comparison is in Section 12. |
| Sterilization Efficacy | Device Statement: "The kit is sterile and intended for single use."Validation: "The sterilization process is the same as that used for all PAJUNK® Products already cleared for market. It has been validated for double-bag packages with the balloon systems (K012771) and the disposable trocars TrokaSys (K063528), predicate devices of this submission." |
| Biocompatibility | Device Statement: Not explicitly detailed in the excerpt.Validation: Mentioned as "biocompatibility data demonstrates that the proposed Kit is substantially equivalent." |
| Safety and Effectiveness | Device Statement: The conclusion states "safe and effective."Basis: Comparison to predicate devices, validated sterilization, biocompatibility data, and the optional use of optical devices is stated to "enhance safety and effectiveness." |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):
- Not Applicable. This submission does not describe a clinical performance study with a "test set" in the context of an AI/ML device validating a diagnostic or predictive capability. The "study" here is primarily a comparative analysis against predicate devices and validation of established manufacturing processes (like sterilization), not a data-driven performance test set.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not Applicable. As above, there is no "ground truth" establishment in the context of a diagnostic or predictive algorithm. The device's safety and effectiveness are established through engineering principles, material science, equivalence to existing devices, and validated manufacturing processes, not through expert-labeled data for an algorithm.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not Applicable. There is no test set or adjudication process described for performance evaluation in the context of an AI/ML device.
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. This device is an instrument for surgical procedures (kit for balloon aided laparoscopy), not an imaging analysis tool, diagnostic aid, or AI/ML product. Therefore, MRMC studies and "human readers improve with AI" metrics are irrelevant.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not Applicable. This is a hardware medical device, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- Not Applicable. There is no ground truth data type as the device's function is mechanical/procedural, not data analysis or diagnosis. Safety and effectiveness are based on design, materials, manufacturing controls, and comparison to existing safe and effective devices.
8. The sample size for the training set:
- Not Applicable. There is no "training set" as this is not an AI/ML device.
9. How the ground truth for the training set was established:
- Not Applicable. There is no training set or ground truth in this context.
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510(k) Premarket Notification Submission:
ﻢ . . . . . . . . .
MAY - 8 2008
Summary of Safety and Effectiveness for PAJUNK®'s Kit for balloon aided laparoscopy
Date of Preparation: April 12th 2008
Submitter Information/ production site:
Pajunk GmbH Karl-Hall-Strasse 01 78187 Geisingen Germany Fon: +49(0)7704-9291-586 Fax: +49(0)7704-9291-605 Establishment Registration Number: 9611612 Contact:
Christian Quass, Director Regulatory Affairs Fon: +49(0)7704-9291-586 Fax: +49(0)7704-9291-605 E-Mail: christian.quass@pajunk.com
USA Contact:
Pajunk Medical Systems German American Trade Center 5126 South Royal Atlanta Drive 30084 Tucker, Georgia USA
Contact
Stefan Dayagi Fon: +01(0)770-493-9305
E-Mail: stefan.dayagi@pajunk-usa.com Contract Sterilizer:
STERIGENICS GERMANY GMBH Rheingaustrasse 190-196 65203 Wiesbaden, GERMANY Registration Number: 3002807090 Operations: Contract Sterilizer Status: Active
Device Information:
| Device Name: | PAJUNK®'s Kit for balloon aided laparoscopy |
|---|---|
| Trade Names: | Balloon Laparoscopes |
| Common Name: | Kit, balloon, trocar, port |
| Classification Name: | Endoscope and accessories |
| Classification Reference: | 21 CFR §876.1500, April 1, 2007 |
| Establishment Registration Number: | 9611612 |
| Regulatory Class: | II |
| Product Code: | GCJ |
| Panel: | Gastroenterology/Urology |
| Predicate Devices: | 1. K012771 Trocar Sleeve and accessories – PAJUNK®2. K063528 TrokaSys – PAJUNK® |
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Device Description:
The kit provides a common port with trocar and valve closure (for gaining acces for minimal invasive surgery) packed in a separate bag within the sterilized unit and a rigid balloon guidance with obturator and filling syringe (for insertion of the endoscopic visualisation device) packed in another separate bag. Both units are available seperately and as a procedure unit.
It is especially intended for diagnostics and aftercare in minimal invasive procedures.
Due to the length of the balloon quidance and the clinical practice there is no need to create a pneumoperitoneum via insufflation
The port may be left in place for up to 10 days with the seal closure trocar in place.
The kit is sterile and intended for single use.
Indications for use:
PAJUNK®'s Kit for balloon aided laparoscopy is intended for making incisions into the patients body to allow insertion of endoscopes and endoscopic accessories during general and minimal invasive surgical procedures.
Additional Claims
It is especially intended for diagnostics and aftercare.
Due to the length of the balloon guidance and the clinical practice there is no need to create a pneumoperitoneum via insufflation.
The port may be left in place for up to 30 days.
Predicate Devices:
PAJUNK®'s Kit for balloon aided laparoscopy, the subject device of this submission, combines technical features of PAJUNK®'s devices already approved for market. Predicate devices with identical or at least similar indications of use are:
While the predicate devices are indicated for minimal invasive procedures the subject device is indicated for inserting and guiding optical endoscopes for aftercare and diagnostics. The detailed discussion of substantial eqivalence can be found in Section 12 of this submission.
Sterilization
The sterilization process is the same as that used for all PAJUNK® Products already cleared for market. It has been validated for double-bag packages with the balloon systems and the disposable trocars TrokaSys, predicate devices of this submission.
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Technology Characteristics:
The Kit consists of the following components arranged in two bags for two steps in procedure:
| Bag 01 | Port |
|---|---|
| Trocar | |
| Seal closure trocar | |
| Bag 02 | Balloon guidance |
| Obturator | |
| Filling syringe (30ml) |
Conclusion:
The comparison between the predicate devices and the proposed devices in section 12 of this submission as well as the validated sterilization process and biocompatibility data demonstrates that the proposed Kit is substantially equivalent to the predicate devices and safe and effective. The optional use of optical devices (image giving endoscopes) in order to monitor the procedure and to conduct manually operated interventions under sight/ view are at least as safe and effective as common techniques are, actually this is intended to enhance safety and effectiveness ..
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Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo consists of a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" arranged around the perimeter. Inside the circle is a stylized emblem featuring a symbol of intertwined ribbons or streams.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
MAY - 8 2008
Pajunk GmbH Medizintechnologie % Christian Quass Director, Regulatory Affairs Karl-Hall-Strasse 01 78187 Geisingen, Germany
Re: K080654
Trade/Device Name: PAJUNK®'s Kit for balloon aided laparoscopy Regulation Number: 21 CFR 876.1500 Regulation Name: Endoscope and accessories Regulatory Class: II Product Code: GCJ Dated: April 21, 2008 Received: April 23, 2008
Dear Christian Quass:
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.
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Page 2 - Christian Quass
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 Center for Devices and Radiological Health's (CDRH's) Office of Compliance at (240) 276-0115. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding postmarket surveillance, please contact CDRH's Office of Surveillance and Biometric's (OSB's) Division of Postmarket Surveillance at (240) 276-3474. For questions regarding the reporting of device adverse events (Medical Device Reporting (MDR)), please contact the Division of Surveillance Systems at (240) 276-3464. 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,
Mark M. Millman
Mark N. Melkerson Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Indications for use
510(k) Number:
Device Name:
PAJUNK®'s Kit for balloon aided laparoscopy
Indications for Use:
PAJUNK®'s Kit for balloon aided laparoscopy is intended for making incisions into the patients body to allow insertion of endoscopes and endoscopic accessories during general and minimal invasive surgical procedures.
Prescription Use (Per 21 CFR 801.109) AND/OR
Over-The-Counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Nil R.P. Oyal for xxx
(Division Sign-Off) Division of General, Restorative, and Neurological Devices
510(k) Number K080654
§ 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.