(133 days)
The ViKY System is a motorized device whose intended use is to allow a surgeon to hold and position a rigid endoscope during endoscopic surgical procedures. Its light architecture allows the ViKY System to be maintained above the patient by a dedicated arm attached to the table. The ViKY System movements are controlled by the surgeon either by a foot controller or a voice controller.
The ViKY System is indicated for thoracic and laparoscopic minimally invasive procedures for the purpose of holding and controlling the movement of standard rigid endoscopes within surgical cavities during endoscopic surgery.
ViKY is a motorized endoscope holder for thoracic, abdominal, and pelvic minimally invasive procedures. ViKY is maintained by a dedicated arm attached to the table. It is moved according to surgeon orders by means of either a foot controller or a voice controller, in caudal, cranial and lateral directions, as well as zoom in and zoom out of the field.
This is a 510(k) premarket notification for a medical device called ViKY, a motorized endoscope holder. The document focuses on establishing substantial equivalence to predicate devices, rather than presenting a study with specific acceptance criteria and detailed device performance metrics in the format requested.
Therefore, many of the requested sections regarding acceptance criteria, sample sizes, ground truth, and expert involvement are not applicable or cannot be extracted from the provided text.
Here is an analysis based on the available information:
1. Table of Acceptance Criteria and Reported Device Performance:
The document does not detail specific acceptance criteria for performance metrics (e.g., accuracy of movement, speed, stability) for the ViKY device. Instead, it focuses on general safety and effectiveness through substantial equivalence and compliance with established electrical and EMC standards.
| Acceptance Criteria Category | Specific Criteria (from document) | Reported Device Performance (from document) |
|---|---|---|
| Electrical Safety | Compliance with EN 60601-1:1990 | Tested in accordance with EN 60601-1:1990 |
| Compliance with UL 60601-1:2003 | Tested in accordance with UL 60601-1:2003 | |
| Compliance with IEC 60601-1:1988 (with amendments) | Tested in accordance with IEC 60601-1:1988 (with amendments) | |
| Electromagnetic Compatibility (EMC) | Compliance with IEC 60601-1-2 (Second Edition, 2001) | Tested in accordance with IEC 60601-1-2 (Second Edition, 2001) |
| Functionality | Ability to hold and position a rigid endoscope | "ViKY is a motorized endoscope holder for thoracic, abdominal, and pelvic minimally invasive procedures." "It is moved according to surgeon orders by means of either a foot controller or a voice controller, in caudal, cranial and lateral directions, as well as zoom in and zoom out of the field." |
| Material/Sterilization | Sterilization capability | "The main technological difference is that the ViKY System is sterilized" |
2. Sample size used for the test set and the data provenance:
- Sample Size for Test Set: Not specified. The document mentions "summaries of testing on animals and clinical experience with the system were provided," but does not give specific sample sizes for these tests.
- Data Provenance: Not specified.
- Animal testing: Country of origin and whether retrospective or prospective are not mentioned.
- Clinical experience: Country of origin and whether retrospective or prospective are not mentioned.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
This information is not provided. The 510(k) submission focuses on regulatory compliance and substantial equivalence to existing devices, not on a detailed clinical study with ground truth established by experts in the context of AI or diagnostic performance.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
Not applicable. The document does not describe a study involving expert adjudication for a test set.
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 endoscope holder, not an AI diagnostic tool that assists human readers/interpreters. Therefore, an MRMC study and AI assistance effect size are not relevant to this submission.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
Not applicable. This device is a robotic assistant, always used with a human surgeon in the loop. It does not operate as a standalone algorithm for diagnosis or interpretation.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):
The concept of "ground truth" as typically applied to diagnostic AI studies (e.g., pathology as ground truth for cancer detection) is not applicable here. The "truth" for this device relates to its functional performance (e.g., does it hold the endoscope as intended, does it move accurately) and safety. The document refers to "testing on animals and clinical experience with the system," which likely serve as evidence of functional validation and safety, but specific "ground truth" definitions in this context are not provided.
8. The sample size for the training set:
Not applicable. This is a mechanical/robotic medical device, not an AI/machine learning algorithm that requires a "training set" in the conventional sense.
9. How the ground truth for the training set was established:
Not applicable, as there is no training set for an AI algorithm.
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510(k) Summary ViKY
DEC 1 8 2008
The summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of SMDA and 21 CFR 807.92.
510(k) Submitter:
EndoControl 5 avenue du Grand Sablon 38700 La Tronche France Phone : +33 476637583 Fax : +33 476637592
Contact Name:
Carine Huguel carine.huguel@endocontrol-medical.com
Date Prepared:
December 12th, 2008.
Proposed Device:
| Trade Name: | ViKY |
|---|---|
| Common Name: | Endoscope Holder |
| Classification Name: | General & Plastic Surgery, 21 CFR PART 876.1500 |
| Device Class: | II |
| Product Code: | GCJ |
Predicate Device:
The ViKY System is substantially equivalent to AESOP 3000 System and accessories that were cleared by FDA under K972699 on December 17, 1997, and to GMP|Surgical Solutions Inc. Laparocision™ Scope Controller System that was cleared by FDA under K050027 on January 27, 2005.
Device Description:
ViKY is a motorized endoscope holder for thoracic, abdominal, and pelvic minimally invasive procedures. ViKY is maintained by a dedicated arm attached to the table. It is moved according to surgeon orders by means of either a foot controller or a voice controller, in caudal, cranial and lateral directions, as well as zoom in and zoom out of the field.
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Intended Use:
The ViKY System is a motorized device whose intended use is to allow a surgeon to hold and position a rigid endoscope during endoscopic surgical procedures. Its light architecture allows the ViKY System to be maintained above the patient by a dedicated arm attached to the table. The ViKY System movements are controlled by the surgeon either by a foot controller or a voice controller.
Indications for Use:
The ViKY System is indicated for thoracic and laparoscopic minimally invasive procedures for the purpose of holding and controlling the movement of standard rigid endoscopes within surgical cavities during endoscopic surgery.
Comparison of Technological Characteristics:
The ViKY System and the predicate devices have electronic components to control the position of laparoscopes during laparoscopic surgical procedures. ViKY System has a light architecture that allows it to be attached to the table by a dedicated arm, which is similar to both LAPAROCISION (K050027), and AESOP (K972699). The main technological difference is that the ViKY System is sterilized, although the predicate devices are protected by a sterile covers. The differences in technology do not raise any significant questions or issues regarding the safety and effectiveness of the device.
Testing:
Electrical Safety is tested in accordance with the following standards:
- EN 60601-1:1990, Medical electrical equipment Part 1: General requirements for safety .
- UL 60601-1:2003, Medical Electrical Equipment -Part 1: General Requirements for Safety .
- IEC 60601-1, Medical Electrical Equipment Part 1: General Requirements for Safety, . 1988; Amendment 1, 1991-11, Amendment 2, 1995.
Electromagnetic Compatibility (EMC) is tested in accordance with the following standards:
- IEC 60601-1-2, (Second Edition, 2001), Medical Electrical Equipment Part 1-2: General . Requirements for Safety; Electromagnetic Compatibility -- Requirements and Tests.
In addition, summaries of testing on animals and clinical experience with the system were provided.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/2/Picture/1 description: The image shows the seal of the Department of Health & Human Services, USA. The seal features a stylized eagle with outstretched wings, symbolizing protection and service. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES · USA" are arranged in a circular pattern around the eagle.
Public Health Service
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
DEC 1 8 2008
EndoControl % Ms. Carine Huguel Quality Manager 5 Avenue Du Grand Sablon La Tronche 38700 France
Re: K082233 Trade/Device Name: ViKY Regulation Number: 21 CFR 876.1500 Regulation Name: Endoscope and accessories Regulatory Class: II Product Code: GCJ Dated: December 12, 2008 Received: December 15, 2008
Dear Ms. Huguel:
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
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Page 2 - Ms. Carine Huguel
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 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: K082233
Device Name: ViKY
Indications For Use:
The ViKY System is indicated for thoracic and laparoscopic minimally invasive procedures for the purpose of holding and controlling the movement of standard rigid endoscopes within surgical cavities during endoscopic surgery.
Prescription Use __ × (Part 21 CFR 801 Subpart D) 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)
Neil R. Oden forman
(Division Sign-Off) Division of General, Restorative, and Neurological Devices
510(k) Number K082233
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§ 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.