K Number
K141713
Device Name
SMARTGRAFT 200 SYSTEM
Manufacturer
Date Cleared
2014-10-28

(125 days)

Product Code
Regulation Number
878.5040
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The SmartGraft™ 200 system is intended to be used in medical procedures involving the harvesting, centrifugation and transferring of autologous adipose tissue. The SmartGraft™ 200 system is used for concentrating adipose tissue for aesthetic body contouring, and for tissue that has been harvested with a legally marketed lipoplasty system. The SmartGraft™ 200 system is intended for use in the following surgical specialties when the concentration of harvested adipose tissue is desired. - · Neurosurgery, - · Gastrointestinal Surgery, - · Urological Surgery, - · Plastic and Reconstructive Surgery, - · General Surgery, - · Orthopedic Surgery, - · Gynecological Surgery, - · Thoracic Surgery, - · Laparoscopic Surgery, and - · Arthroscopic Surgery
Device Description
The SmartGraft™ 200 System is a disposable process pack to be used with the InGeneron Tissue Processing Unit (centrifuge). The process pack is a collection of sterile single-use off-the-shelf and proprietary components used during the process of harvesting, centrifugation, and transferring of autologous adipose tissue. It is intended for the concentration of aspirated adipose tissue for subsequent transfer during the same procedure.
More Information

Not Found

No
The summary describes a system for processing adipose tissue using centrifugation and does not mention any AI or ML components or functions.

Yes.
The device is used in medical procedures involving the harvesting, centrifugation, and transferring of autologous adipose tissue for various surgical specialties, indicating a direct therapeutic application by aiding in the preparation of tissue for treatment.

No

The device is described as a system for harvesting, centrifuging, and transferring autologous adipose tissue, primarily for concentrating it for aesthetic body contouring or subsequent transfer. Its intended use focuses on processing tissue for therapeutic or reconstructive purposes, not on diagnosing medical conditions.

No

The device description explicitly states it is a "disposable process pack" and a "collection of sterile single-use off-the-shelf and proprietary components," indicating it is a hardware system, not software only.

Based on the provided information, the SmartGraft™ 200 system is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • Intended Use: The intended use clearly states that the system is for "harvesting, centrifugation and transferring of autologous adipose tissue" for "aesthetic body contouring" and subsequent transfer during the same procedure. This is a surgical procedure involving tissue manipulation within the body or for re-implantation, not for testing samples in vitro (outside the body) to diagnose a condition.
  • Device Description: The description focuses on processing adipose tissue for transfer, not for analyzing it for diagnostic purposes.
  • Lack of Diagnostic Claims: There are no mentions of analyzing the tissue to detect diseases, conditions, or markers. The performance studies focus on the viability of the processed tissue, which is relevant to its use in grafting, not diagnosis.
  • Surgical Specialties: The intended users are surgeons in various specialties, indicating a surgical application rather than a laboratory diagnostic one.

IVD devices are typically used to examine specimens (like blood, urine, tissue samples) in vitro to provide information for diagnosis, monitoring, or screening. The SmartGraft™ 200 system's function is to prepare tissue for surgical use, not to perform diagnostic tests on it.

N/A

Intended Use / Indications for Use

The SmartGraff™ 200 system is intended to be used in medical procedures involving the harvesting, centrifygation and transferring of autologous adipose tissue. The SmartGraft™ 200 system is used for concentrating adipose tissue for aesthetic body contouring, and for tissue that has been harvested with a legally marketed lipoplasty system.

The SmartGraft™ 200 system is intended for use in the following surgical specialties when the concentration of harvested adipose tissue is desired.

  • Neurosurgery,
  • Gastrointestinal Surgery,
  • Urological Surgery,
  • Plastic and Reconstructive Surgery,
  • General Surgery,
  • Orthopedic Surgery,
  • Gynecological Surgery,
  • Thoracic Surgery,
  • Laparoscopic Surgery, and
  • Arthroscopic Surgery

Product codes (comma separated list FDA assigned to the subject device)

MUU

Device Description

The SmartGraft™ 200 System is a disposable process pack to be used with the InGeneron Tissue Processing Unit (centrifuge). The process pack is a collection of sterile single-use off-the-shelf and proprietary components used during the process of harvesting, centrifugation, and transferring of autologous adipose tissue. It is intended for the concentration of aspirated adipose tissue for subsequent transfer during the same procedure.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

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)

Determination of substantial equivalence was substantiated by a tabular specification comparison between the SmartGraft™ 200 and the two legally marketed predicate devices, and through two non-clinical studies involving only the SmartGraft™ 200 system. Both usability of the system according to Instructions for Use, and operation of the system to produce concentrated adipose tissue from lipoaspirate were tested. Concentrated adipose tissue produced using the SmartGraft™ 200 system was investigated further evaluating the nucleated cell viability of the concentrated adipose tissue compared to unprocessed adipose tissue. The results of the viability evaluation indicate that the SmartGraft™ 200 system does not adversely impact viability of the adipose tissue. Impact of the SmartGraft™ 200 system on cell viability is then substantially equivalent to that of predicate devices. A specification comparison between the SmartGraft™ 200 System and predicate devices was used to make a determination of substantial equivalence. The specification comparison shows that all three use low g-force centrifugation for a short period of time as an operating principle to obtain concentrated lipoaspirate. The Usability and Clinical Evaluation protocols and corresponding reports indicate that that the SmartGraft™ 200 System performs to specification, and can be operated successfully with the Instructions for Use provided.

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

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K100114, K121005

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 878.5040 Suction lipoplasty system.

(a)
Identification. A suction lipoplasty system is a device intended for aesthetic body contouring. The device consists of a powered suction pump (containing a microbial filter on the exhaust and a microbial in-line filter in the connecting tubing between the collection bottle and the safety trap), collection bottle, cannula, and connecting tube. The microbial filters, tubing, collection bottle, and cannula must be capable of being changed between patients. The powered suction pump has a motor with a minimum of1/3 horsepower, a variable vacuum range from 0 to 29.9 inches of mercury, vacuum control valves to regulate the vacuum with accompanying vacuum gauges, a single or double rotary vane (with or without oil), a single or double diaphragm, a single or double piston, and a safety trap.(b)
Classification. Class II (special controls). Consensus standards and labeling restrictions.

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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

October 28, 2014

InGeneron Incorporated Ms. Anita Kadala Chief Executive Officer/General Counsel 8205 El Rio Houston, Texas 77054

Re: K141713

Trade/Device Name: SmartGraft™ 200 System Regulation Number: 21 CFR 878.5040 Regulation Name: Suction lipoplasty system Regulatory Class: Class II Product Code: MUU Dated: October 7, 2014 Received: October 10, 2014

Dear Ms. Kadala:

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

1

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 Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/Resourcesfor You/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 Industry and Consumer Education 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.

for

Sincerely yours,

David Krause -S

Binita S. Ashar, M.D., M.B.A., F.A.C.S. Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K141713

Device Name SmartGraft™ 200

Indications for Use (Describe)

The SmartGraff™ 200 system is intended to be used in medical procedures involving the harvesting, centrifygation and transferring of autologous adipose tissue. The SmartGraft™ 200 system is used for concentrating adipose tissue for aesthetic body contouring, and for tissue that has been harvested with a legally marketed lipoplasty system.

The SmartGraft™ 200 system is intended for use in the following surgical specialties when the concentration of harvested adipose tissue is desired.

  • · Neurosurgery,
  • · Gastrointestinal Surgery,
  • · Urological Surgery,
  • · Plastic and Reconstructive Surgery,
  • · General Surgery,
  • · Orthopedic Surgery,
  • · Gynecological Surgery,
  • · Thoracic Surgery,
  • · Laparoscopic Surgery, and
  • · Arthroscopic Surgery

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)

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510(k) Summary

Date Summary Prepared: 07 October 2014
Applicant/Sponsor:InGeneron, Inc.
8205 El Rio
Houston, TX 77054
Contact Person:Anita Kadala - CEO/General Counsel
713-440-9900
Tel:
FAX: 713-715-5454
Email: AKadala@ingeneron.com
Device Trade Name:SmartGraft™ 200 System
Common Name:Suction Lipoplasty System
Classification Name:Suction Lipoplasty System, Class II
Regulation:21 CFR 878.5040, Suction Lipoplasty System
Product Code:MUU
Legally Marketed Devices
To Which Substantial
Equivalence is Claimed:K100114 Vortech™ Adipose Transfer System, Biomet
Biologics, Inc. and,
K121005 AdiPrep™ Adipose Transfer System from
Harvest Technologies Corp.
Device Description:The SmartGraft™ 200 System is a disposable process pack
to be used with the InGeneron Tissue Processing Unit
(centrifuge). The process pack is a collection of sterile
single-use off-the-shelf and proprietary components used
during the process of harvesting, centrifugation, and
transferring of autologous adipose tissue. It is intended for
the concentration of aspirated adipose tissue for subsequent
transfer during the same procedure.
Indication For Use:The SmartGraft™ 200 System is intended to be used in
medical procedures involving the harvesting, centrifugation
and transferring of autologous adipose tissue. The

4

SmartGraft™ 200 System is used for concentrating adipose tissue for aesthetic body contouring, and for tissue that has been harvested with a legally marketed lipoplasty system.

The SmartGraft™ 200 System is intended for use in the following surgical specialties when the concentration of harvested adipose tissue is desired.

  • Neurosurgery
  • . Gastrointestinal Surgery
  • . Urological Surgery
  • . Plastic and Reconstructive Surgery
  • . General Surgery
  • Orthopedic Surgery
  • . Gynecological Surgery
  • Thoracic Surgery
  • . Laparoscopic Surgery
  • . Arthroscopic Surgery

The SmartGraft™ 200 System is believed to be Substantial Equivalence: substantially equivalent to the two referenced legally marketed predicate devices in that it has the same intended use, same operating principles and same function within the medical procedure, uses equivalent polymeric materials of construction, are all provided as sterile single-use disposables. The SmartGraft™ 200 device is sterilized using the same sterilization method as one referenced legally marketed predicate device. Substantial equivalence to a legally marketed predicate device in reference to biocompatibility for the intended use was determined using a recognized standard. The SmartGraft™ 200 System and both referenced legally marketed predicate devices are intended to be used for the same application across the same range of surgical specialties.

Technological Characteristics:

The SmartGraft™ 200 System is substantially equivalent to the two legally marketed predicate devices cited based on technological characteristics. The SmartGraft™ 200 and the two legally marketed predicates cited all are used in the concentration of adipose tissue harvested with legally marketed lipoplasty systems. All three are single-use devices made of medical-grade polymer materials. The

0018

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SmartGraft™ 200 device and at least one other predicate are tested for biocompatibility to ISO 10993. All three are sterilized using standard sterilization methods for sterile single-use devices. The SmartGraft™ 200 device and one predicate device utilize EO gas sterilization, whereas the other predicate device uses gamma irradiation for sterilization. All three devices utilize a centrifuge-like device using relatively low g-force for short periods of time for concentration of adipose tissue for transfer. The volume of adipose tissue processed by the SmartGraft™ 200 System is essentially identical to one of the predicate devices. Both of these volumes are larger than the volume processed by the other predicate device.

Bench Testing: Determination of substantial equivalence was substantiated by a tabular specification comparison between the SmartGraft™ 200 and the two legally marketed predicate devices, and through two non-clinical studies involving only the SmartGraft™ 200 system. Both usability of the system according to Instructions for Use, and operation of the system to produce concentrated adipose tissue from lipoaspirate were tested. Concentrated adipose tissue produced using the SmartGraft™ 200 system was investigated further evaluating the nucleated cell viability of the concentrated adipose tissue compared to unprocessed adipose tissue. The results of the viability evaluation indicate that the SmartGraft™ 200 system does not adversely impact viability of the adipose tissue. Impact of the SmartGraft™ 200 system on cell viability is then substantially equivalent to that of predicate devices. A specification comparison between the SmartGraft™ 200 System and predicate devices was used to make a determination of substantial equivalence. The specification comparison shows that all three use low g-force centrifugation for a short period of time as an operating principle to obtain concentrated lipoaspirate. The Usability and Clinical Evaluation protocols and corresponding reports indicate that that the SmartGraft™ 200 System performs to specification, and can be operated successfully with the Instructions for Use provided.