(40 days)
The MicroCutter XCHANGE™30 is intended for use in multiple open or minimally invasive surgical procedures for the transection, resection, and/or creation of anastomoses in small and large intestine as well as the transection of the appendix.
The MicroCutter XCHANGE™ 30 Stapler is a single patient use stapler that delivers two. double staggered rows of 316L stainless steel staples while simultaneously transecting tissue between staple rows. The MicroCutter XCHANGE™ 30 Blue Staple Cartridge is available for deployment with the MicroCutter XCHANGE ™ 30 Stapler which delivers a blue staple (3.5mm) compatible with tissue that can be compressed to 1.5mm. The staple line is approximately 30mm long with a transection length of approximately 27mm.
The provided document is a 510(k) Summary for a medical device (MicroCutter XCHANGE™ 30 Blue Staple Cartridge) and describes its non-clinical performance data for demonstrating substantial equivalence to a predicate device. It is not a study proving the device meets clinical acceptance criteria or describing a comparative effectiveness study involving human readers and AI.
Here's an analysis of the provided information based on your request, highlighting what is present and what is missing because this document focuses on non-clinical data for a 510(k) submission:
1. Table of acceptance criteria and the reported device performance
The document provides a comparative table of technological characteristics between the predicate and subject devices and mentions various tests were conducted. However, it does not explicitly define acceptance criteria as a specific numeric or qualitative threshold for each test directly alongside reported performance data in a clear table format. It states that tests "met design specifications" or "passed."
| Feature/Test | Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|---|
| Reliability Testing | Meets design specification | Demonstrated device performance and strength meets design specification, post gamma sterilization, transit conditioning, environmental conditioning, and accelerated aging. |
| Bioburden Testing | Passed per ANSI/AAMI/ISO 11737-1 | Passed in accordance with ANSI/AAMI/ISO 11737-1. |
| Shelf Life Testing | Passed per ASTM F 1980 | Completed and passed in accordance with ASTM F 1980. |
| Biocompatibility Testing | Passed per ISO 10993-1 | Completed and passed in accordance with ISO 10993-1 requirements. |
| Tissue Leak Pressure (Bench) | No statistical difference vs. predicate (p>0.05) | No statistical difference as compared to Covidien ENDO GIA Universal blue staple cartridge: p>0.05. |
| Other technological characteristics (e.g., staple material, size, deployment) | "No Change" compared to predicate | Subject device characteristics were "No Change" from predicate, implying they meet the predicate's established performance. |
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 explicitly state the sample sizes for the "test sets" for the listed non-clinical tests. It refers to "design verification testing."
- Sample Size: Not specified for individual tests.
- Data Provenance: Not specified, but implied to be internal testing by Cardica, Inc. (Redwood City, California, USA). The tests are non-clinical bench tests.
- Nature: The testing described is prospective, as it was conducted to verify a design modification.
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 to this document. The tests described are non-clinical (mechanical, biological, physical) and do not involve human experts establishing ground truth for a diagnostic algorithm.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This information is not applicable. No adjudication method is described as the tests are non-clinical engineering and biological assessments.
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
No, a multi-reader multi-case (MRMC) comparative effectiveness study was not done. This document describes non-clinical testing for a surgical stapler, not an AI diagnostic device.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
This information is not applicable. This document describes the performance of a physical medical device (surgical stapler component), not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
For the non-clinical tests, the "ground truth" implicitly refers to engineering specifications, regulatory standards (e.g., ISO, ASTM, ANSI/AAMI), and established performance of the predicate device. For instance, 'Bioburden testing passed in accordance with ANSI/AAMI/ISO 11737-1' means the standard itself defines the acceptable reference. 'No statistical difference as compared to Covidien ENDO GIA Universal blue staple cartridge' means the predicate device's performance sets the benchmark.
8. The sample size for the training set
This information is not applicable. This document describes the testing of a physical medical device, not an AI algorithm that requires a training set.
9. How the ground truth for the training set was established
This information is not applicable. As no AI algorithm or training set is involved, there is no "ground truth for the training set" to establish.
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K140118 Special 510(k) MicroCutter XCHANGETM 30
Attachment 1 510(k) Summary
510(k) Summary - MicroCutter XCHANGE™ 30 Blue Staple Cartridge
FEB 2 5 2014
Date Prepared A.
January 15, 2014
B. . Applicant Information
Cardica, Inc. 900 Saginaw Drive Redwood City, California 94063 Main: 650-364-9975 Fax: 650-364-3134
C. Contact Person
ﺮ
Vee Arya Senior QA/RA Manager
(650) 331-7152 direct (650) 644-7339 mobile (650) 331-7195 fax arya@cardica.com
Alternate Contact: Frederick Bauer Vice President of Operations
(650) 331-7163 direct (650) 331-7195 fax bauer@cardica.com
D. Establishment Registration Number
3004114958
E. Device Information
Device Class: Class II Common, Usual or Classification Name: Staple, Implantable Regulation Number: 21 CFR §878.4750 Product Code: GDW
r. Trade Name
MicroCutter XCHANGETM 30 Blue Cartridge
- G. Legally Marketed Predicate Device(s) MicroCutter XCHANGETM 30 (K132581)
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K140118 Special 510(k) MicroCutter XCHANGETM 30
H. Device Description
The MicroCutter XCHANGE™ 30 Stapler is a single patient use stapler that delivers two. double staggered rows of 316L stainless steel staples while simultaneously transecting tissue between staple rows. The MicroCutter XCHANGE™ 30 Blue Staple Cartridge is available for deployment with the MicroCutter XCHANGE ™ 30 Stapler which delivers a blue staple (3.5mm) compatible with tissue that can be compressed to 1.5mm. The staple line is approximately 30mm long with a transection length of approximately 27mm.
l. Indications for Use
The MicroCutter XCHANGE™30 is intended for use in multiple open or minimally invasive surgical procedures for the transection, and/or creation of anastomoses in small and large intestine as well as the transection of the appendix.
J. Comparison to Predicate Device
The subject MicroCutter XCHANGE™ 30 Blue Staple Cartridge (polyarylamide) is equivalent in its Indications for Use to the predicate MicroCutter XCHANGE™ 30 Blue staple cartridge (LCP) (K132581). The only modification is a change to the material used for the distal tip of the cartridge insert component from liquid crystal polymer (LCP) to polyarylamide supplied by a vendor. The implantable staple remains unchanged, and there are no other changes to design, operation or materials of the stapler or cartridge except the distal material and colorant of the cartridge insert component within the MicroCutter XCHANGETM 30 Blue Cartridge.
K. Technological Characteristics
The technological characteristics of the subject MicroCutter XCHANGE™ 30 Blue Staple Cartridge (polyarylamide) are substantially equivalent to the predicate device as demonstrated through verification testing as indicated in Section L "Non-clinical Performance Data" and table below.
The subject MicroCutter XCHANGE™ 30 Blue Staple Cartridge has similar features as compared to the predicate device as shown in table below:
| Feature | PREDICATE DEVICEMicroCutter XCHANGE 30Blue Staple Cartridge (LCP)(K132581) | SUBJECT DEVICEMicroCutter XCHANGE 30Blue Staple Cartridge (IXEF) |
|---|---|---|
| Deployment Device | ||
| Deployment | Cartridge based deployment(up to 6 deployments per tool)for single patient use | No Change |
| Shaft Length | 340mm | No Change |
| Transection Line Length | 27mm | No Change |
| End-Effector Opening | 2.4mm at tissue stop(proximal);11.7mm at distal opening | No Change |
| Shaft Rotation | 360° | No Change |
| Articulation | 160° (80° each direction) | No Change |
| Staple | ||
| Staple Material | Stainless steel (316L) | No Change |
| Unformed Staple height | 3.22mm | No Change |
| Formed Staple Height | 1.4mm (compatible with tissue thickness that can becompressed easily to 1.50mm) | No Change |
| Formed StapleConfiguration | D shaped | No Change |
| Feature | PREDICATE DEVICEMicroCutter XCHANGE 30Blue Staple Cartridge (LCP)(K132581) | SUBJECT DEVICEMicroCutter XCHANGE 30Blue Staple Cartridge (IXEF) |
| Staple Line Configuration | Two (2), double-staggeredrows | No Change |
| Staple Line Length | 30mm | No Change |
| Number of Staples PerDeployment | 50 (One row of 13 and onerow of 12 on either side oftransaction line) | No Change |
| MRI Compatibility | MR-Conditional | No Change |
| Biocompatibility | ||
| Material Biocompatibility(Delivery Device andStaple) | All components of theCardica MicroCutterXCHANGE 30 are comprisedof materials that were deemedacceptable in accordance withISO Standard 10993-1. | No Change |
| Staple CartridgeCartridge Insert | Liquid Crystal Polymer (LCP)and Stainless Steel | Polyarylamide replacing LCP isthe only change. Detailedinformation on the polyarylamidematerial was provided viareferencing to a Device MasterFile owned by the manufacturerof this material. |
| Staple Cartridge Packaging, Sterilization and Shelf Life | ||
| Packaging | Tyvek andNylon/LDPE/HDPEcoextrusion film Pouch | No Change |
| Sterilization | Gamma radiation | No Change |
| Sterility Assurance Level | 10-6 | No Change |
| Shelf Life | 12 months | No Change |
| Performance | ||
| Tissue Leak Pressure(Bench) | No statistical difference ascompared to Covidien ENDOGIA Universal blue staplecartridge : p>0.05 | No Change |
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K140118 Special 510(k) Special 510(k)
MicroCutter XCHANGE™ 30
L. Non-Clinical Performance Data
This modification was verified through design verification testing. Bench testing was
ﺗ
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conducted and the results demonstrated substantial equivalence to the predicate devices, and that the MicroCutter XCHANGE TM 30 Blue Staple Cartridge (polyarylamide) met design specifications. A summary of the design requirements evaluated were as follows:
- Reliability testing was completed and demonstrated that device performance and . strength with the material change meets design specification, post gamma sterilization. transit conditioning, environmental conditioning, and accelerated aging.
- . Bioburden testing was conducted and passed in accordance with ANSI/AAMI/ISO 11737-1 Sterilization of Medical Devices- Microbiological Methods Part I: Estimation of Population of Microorganisms on Products.
- . Shelf life testing was completed and passed in accordance with ASTM F 1980.
- Biocompatibility testing was completed and passed in accordance with ISO � 10993-1 requirements.
M. Clinical Performance
The modification was fully verified through design testing described in Section L above, and does not require a clinical study.
N. Conclusions
The subject MicroCutter XCHANGE™ 30 Blue Staple Cartridge ( polyarylamide has been carefully compared to a legally marketed device, MicroCutter XCHANGE™ 30 Blue Staple Cartridge (LCP), with respect to intended use and technological characteristics. In addition, non-clinical testing was conducted to verify the performance of the device and ensure the MicroCutter XCHANGE™ 30 Blue Staple Cartridge (polyarylamide) functions as intended and meets design specifications. The comparison and non-clinical results demonstrate that the device is substantially equivalent to the predicate device for its intended use.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
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Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
February 25, 2014
Cardica Incorporated Ms. Vee Arya Senior Quality Assurance/Regulatory Affairs Manager 900 Saginaw Drive Redwood City, California 94063
Re: K140118
Trade/Device Name: MicroCutter XCHANGE" 30 Blue Cartridge Regulation Number: 21 878.4750 Regulation Name: Implantable staple Regulatory Class: Class II Product Code: GDW Dated: January 28, 2014 Received: January 29, 2014
Dear Ms. Arya:
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 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 (reporting of medical
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Page 2 - Vee Arya
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 tollfree 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 vours.
David Krause -S
for
Binita S. Ashar, M.D., M.B.A., F.A.C.S. Acting Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
Indications for Use
510(k) Number (if known) . K140118
Device Name
MicroCutter XCHANGE™ 30 Blue Cartridge
Indications for Use (Describe)
The MicroCutter XCHANGE™30 is intended for use in multiple open or minimally invasive surgical procedures for the transection, resection, and/or creation of anastomoses in small and large intestine as well as the transection of the appendix.
Type of Use (Select one or both, as applicable)
∑ Prescription Use (Part 21 CFR 801 Subpart D)
[ ] Over-The-Counter Use (21 CFR 801 Subpart C)
PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.
FOR FDA USE ONLY
Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)
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FORM FDA 3881 (1/14)
PSC Publishing Services (301) 443-6746 EF
Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement on last page.
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§ 878.4750 Implantable staple.
(a)
Identification. An implantable staple is a staple-like device intended to connect internal tissues to aid healing. It is not absorbable.(b)
Classification. Class II.