K Number
K142682
Device Name
The Lipogems System
Date Cleared
2014-12-22

(94 days)

Product Code
Regulation Number
878.5040
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Lipogems System is a sterile medical device intended for the closed-loop processing of lipoaspirate tissue for the purpose of transferring autologous adipose tissue for aesthetic body contouring (lipofilling) in applications including plastic and reconstructive surgery, neurosurgery, gastrointestinal and affiliated organ surgery, urological surgery, general surgery, orthopedic surgery, qynecological surgery, thoracic surgery, and laparoscopic surgery. Only legally marketed accessory items. such as syringes, should be used with the system. If harvested fat is to be reimplanted. the harvested fat is only to be used without any additional manipulation.
Device Description
The Lipogems System is a pre-assembled device consisting of: - An ABS processing unit (Lipogems Processing Unit) containing 5 stainless steel spheres and . 2 stainless steel sieve filters; - . An input washing line connected to the 'blue' side the processing unit; - An access port for the loading of material to be processed with a Luer-lock connection and self-. occluding valve (blue side); - . A drain line connected to the gray side of the processing unit; - An access port for the discharge of processed material with a Luer-lock connection and selfoccluding valve (gray side); - . A bag for collecting waste material. The Lipogems System Processing Unit is manufactured in two size variants with the same functional characteristics: LGD 240: Lipogems Processing Unit with 240 cc capacity and standard exit sieve; LGD 60: Lipogems Processing Unit with 60 cc capacity and standard exit sieve; The intrinsic characteristics of the Lipogems fat treatment can be summarized as follows: - . Minimal handling of adipose tissue (only via mechanical action); - Maintenance of the vascular-stromal niches; ● - . Reduction of fat clusters to allow injection with fine needles, up to 27G; - . Removal of impurities, such as oil residues and blood. The result of processing with the Lipogens System is a homogeneous and micronized fraction of adjpose tissue, which allows a patient's subcutaneous fat to be processed for autologous reinjection within the operative procedure time. There is no direct interaction of the device with the patient, although the adipose tissue that is processed in the device comes from the patient and is returned to the same patient after processing. Interaction with other devices is necessary for operation of the Lipogems System, in particular, standard FDA cleared syringes are needed for the initial injection of adipose tissue into the processing unit, and for receiving the processed tissue upon completion of the processing steps. The steps of operation of the Lipogems System are: - The Lipogems processing unit receives a constant gravity feed of physiological saline through the 1. upper port. After first filling the processing unit with saline, adipose tissue is injected into the processing unit, where it undergoes a first reduction treatment and micronization of lipidic cluster as it passes through the input sieve. - 2. The processing unit is then shaken manually, causing the spheres contained within the processing unit to exert mechanical action on the tissue/saline emulsion and further reduce the lipidic clusters, preserving the vascular-stromal niches, while the continuous flow of saline eliminates oil and blood component residuals from the emulsion. The used saline is collected in the waste bag. Conducting the mechanical reduction while fully immersed in saline minimizes any traumatic action on the cells. - 3. After completion of the shaking/washing step, the solution appears clear (at the top of the processing unit) and the lipoaspirate is yellow (at the bottom). The saline flow is then stopped and the device is inverted. A second adipose cluster reduction takes place by pushing the floating adipose clusters through the second sieve, pushing fluid from below with a svringe. The reduced clusters pass out of the (now) top of the unit into a collecting syringe.
More Information

Not Found

No
The device description and operation are purely mechanical and manual, with no mention of any computational or data-driven processes.

No
The Lipogems System is described as a "sterile medical device intended for the closed-loop processing of lipoaspirate tissue for the purpose of transferring autologous adipose tissue for aesthetic body contouring (lipofilling)". It processes tissue, but does not itself provide a therapeutic effect. The therapeutic effect comes from the subsequent use of the processed tissue.

No

The device is described as a sterile medical device intended for the closed-loop processing of lipoaspirate tissue, not for diagnosis. Its function is to process tissue for transfer, not to identify or determine the nature of a condition.

No

The device description clearly outlines a physical system composed of hardware components (processing unit, spheres, filters, lines, ports, bag). The operation involves manual mechanical action and fluid flow, not software processing.

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

Here's why:

  • IVD Definition: An IVD device is used to examine specimens derived from the human body (like blood, urine, or tissue) in vitro (outside the body) to provide information for the diagnosis, monitoring, or treatment of a disease or condition.
  • Lipogems System Function: The Lipogems System processes adipose tissue mechanically for the purpose of transferring it back into the same patient for aesthetic or reconstructive purposes. It does not analyze the tissue to diagnose, monitor, or treat a disease or condition. It's a processing tool for a surgical procedure.
  • Intended Use: The intended use clearly states "for the closed-loop processing of lipoaspirate tissue for the purpose of transferring autologous adipose tissue for aesthetic body contouring (lipofilling)". This is a procedural application, not a diagnostic one.
  • Device Description: The description details a mechanical processing unit with sieves and spheres. There is no mention of reagents, assays, or analytical components typically found in IVD devices.
  • No Analysis: The process involves washing, shaking, and filtering the tissue. There is no analysis of the tissue's composition or characteristics for diagnostic purposes.

In summary, the Lipogems System is a medical device used for processing tissue for surgical transfer, not for performing diagnostic tests on specimens.

N/A

Intended Use / Indications for Use

The Lipogems System is a sterile medical device intended for the closed-loop processing of lipoaspirate tissue for the purpose of transferring autologous adipose tissue for aesthetic body contouring (lipofilling) in applications including plastic and reconstructive surgery, neurosurgery, gastrointestinal and affiliated organ surgery, urological surgery, general surgery, orthopedic surgery, qynecological surgery, thoracic surgery, and laparoscopic surgery. Only legally marketed accessory items. such as syringes, should be used with the system. If harvested fat is to be reimplanted. the harvested fat is only to be used without any additional manipulation.

Product codes

MUU

Device Description

The Lipogems System is a pre-assembled device consisting of:

  • An ABS processing unit (Lipogems Processing Unit) containing 5 stainless steel spheres and . 2 stainless steel sieve filters;
  • . An input washing line connected to the 'blue' side the processing unit;
  • An access port for the loading of material to be processed with a Luer-lock connection and self-. occluding valve (blue side);
  • . A drain line connected to the gray side of the processing unit;
  • An access port for the discharge of processed material with a Luer-lock connection and selfoccluding valve (gray side);
  • . A bag for collecting waste material.

The Lipogems System Processing Unit is manufactured in two size variants with the same functional characteristics:
LGD 240: Lipogems Processing Unit with 240 cc capacity and standard exit sieve; LGD 60: Lipogems Processing Unit with 60 cc capacity and standard exit sieve;

The intrinsic characteristics of the Lipogems fat treatment can be summarized as follows:

  • . Minimal handling of adipose tissue (only via mechanical action);
  • Maintenance of the vascular-stromal niches; ●
  • . Reduction of fat clusters to allow injection with fine needles, up to 27G;
  • . Removal of impurities, such as oil residues and blood.

The result of processing with the Lipogens System is a homogeneous and micronized fraction of adjpose tissue, which allows a patient's subcutaneous fat to be processed for autologous reinjection within the operative procedure time.

There is no direct interaction of the device with the patient, although the adipose tissue that is processed in the device comes from the patient and is returned to the same patient after processing.

Interaction with other devices is necessary for operation of the Lipogems System, in particular, standard FDA cleared syringes are needed for the initial injection of adipose tissue into the processing unit, and for receiving the processed tissue upon completion of the processing steps.

The steps of operation of the Lipogems System are:

  • The Lipogems processing unit receives a constant gravity feed of physiological saline through the 1. upper port. After first filling the processing unit with saline, adipose tissue is injected into the processing unit, where it undergoes a first reduction treatment and micronization of lipidic cluster as it passes through the input sieve.
    1. The processing unit is then shaken manually, causing the spheres contained within the processing unit to exert mechanical action on the tissue/saline emulsion and further reduce the lipidic clusters, preserving the vascular-stromal niches, while the continuous flow of saline eliminates oil and blood component residuals from the emulsion. The used saline is collected in the waste bag. Conducting the mechanical reduction while fully immersed in saline minimizes any traumatic action on the cells.
    1. After completion of the shaking/washing step, the solution appears clear (at the top of the processing unit) and the lipoaspirate is yellow (at the bottom). The saline flow is then stopped and the device is inverted. A second adipose cluster reduction takes place by pushing the floating adipose clusters through the second sieve, pushing fluid from below with a svringe. The reduced clusters pass out of the (now) top of the unit into a collecting syringe.
      The materials used in the manufacture of the device are in common usage for medical devices. Testing in accordance with the relevant standards in the ISO 10993 series has demonstrated device biocompatibility.

100 % testing of device patency and freedom from leakage is carried out after manufacture and before terminal sterilization by ethylene oxide gas, resulting in a sterility assurance level (SAL) of 10-9. The sterilization process has been validated in accordance with ISO 11135-1. The device is supplied for single use only.

A shelf life of five years has been established for the Lipogems System. This shelf life was established by exposing sterilized samples of the device to accelerated aging equivalent to five years real-time, in accordance with standard ASTM F1980.

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)

Performance data:
The performance of the device is entirely controlled by the user and is not predetermined by the device itself. The instructions for use advise the user to process the tissue by waving and shaking the unit vigorously for a few minutes to emulsify the content. The instructions continue by identifying that when the processing phase is complete, fat tissue will appear compact, light yellow in color, floating on the transparent liquid phase.

Nonclinical testing:
The following nonclinical tests have been performed on the relevant components of the Lipogems system:

  • Validation of the pre-assembly washing process carried out on the device spheres and sieves. ●
  • Biocompatibility testing of all materials in the fluid path, including: ●
    • Cytoxicity (ISO 10993-5); o
    • Sensitization (ISO 10993-10); O
    • Intracutaneous Reactivity (ISO 10993-10); O
    • Acute Systemic Toxicity (ISO 10993-11); O
    • LAL bacterial endotoxin test. O
  • . Validation of the sterilization process (ISO 11153-1)
    • Testing to validate a 5 year shelf life, including:
      • o Peel strength;
      • o
  • . In-process patency and leakage testing of every device.

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

Not Found

Predicate Device(s)

K120902

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

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.

0

Image /page/0/Picture/1 description: The image is a black and white logo for the U.S. Department of Health & Human Services. The logo consists of a circular border with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized image of three human profiles facing to the right, stacked on top of each other, creating a sense of depth and unity.

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

December 22, 2014

Lipogems International SpA % Mr. Roger Gray Donawa Lifescience Consulting Srl Piazza Albania 10 00153 Rome Italy

Re: K142682

Trade/Device Name: Lipogems System Regulation Number: 21 CFR 878.5040 Regulation Name: Suction lipoplasty system Regulatory Class: Class II Product Code: MUU Dated: September 24, 2014 Received: September 25, 2014

Dear Mr. Gray:

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

1

CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical 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.

Sincerely yours,

Binita S. Ashar -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

2

Indications for Use

510(k) Number (if known) K142682

Device Name Lipogems System

Indications for Use (Describe)

The Lipogems System is a sterile medical device intended for the closed-loop processing of lipoaspirate tissue for the purpose of transferring autologous adipose tissue for aesthetic body contouring (lipofilling) in applications including plastic and reconstructive surgery, neurosurgery, gastrointestinal and affiliated organ surgery, general surgery, orthopedic surgery, gynecological surgery, thoracic surgery, and laparoscopic surgery. Only legally marketed accessory items, such as syringes, should be used with the system. If harvested fat is to be reimplanted, the is only to be used without any additional manipulation.

Type of Use (Select one or both, as applicable)

2 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)

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

3

510(k) Summary in accordance with 21 CFR 807.92(c)

Device Name:The Lipogems System
Type of 510(k) submission:Traditional
Date of Submission:16 September 2014
Manufacturer:Lipogems International S.p.A.
Viale Bianca Maria 24
20129 Milano (MI)
Italy
510(k) Owner:Lipogems International S.p.A.
Viale Bianca Maria 24
20129 Milano (MI)
Italy
Phone:
Fax:+39 02 3707 2408/9
+39 02 3707 2410
510(k) Submitter and Contact:Mr Roger Gray
VP Quality and Regulatory
Donawa Lifescience Consulting
Piazza Albania 10
00153 Rome
Italy

Phone: +39 06 578 2665
Fax: +30 06 574 3786
Email: rgray@donawa.com |
| FDA Product Code: | MUU |
| FDA Regulation Number: | 878.5040 |
| FDA Classification Name: | System, Suction, Lipoplasty |
| Classification Panel: | General and Plastic Surgery |
| Common Name: | Lipoplasty System |
| FDA Classification: | Class II |
| FDA 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 of 1/3
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. |

4

Indications for Use/Intended Use:

The Lipogems System is a sterile medical device intended for the closed-loop processing of lipoaspirate tissue for the purpose of transferring autologous adipose tissue for aesthetic body contouring (lipofilling) in applications including plastic and reconstructive surgery, neurosurgery, gastrointestinal and affiliated organ surgery, urological surgery, general surgery, orthopedic surgery, qynecological surgery, thoracic surgery, and laparoscopic surgery. Only legally marketed accessory items. such as syringes, should be used with the system. If harvested fat is to be reimplanted. the harvested fat is only to be used without any additional manipulation.

Device Description:

The Lipogems System is a pre-assembled device consisting of:

  • An ABS processing unit (Lipogems Processing Unit) containing 5 stainless steel spheres and . 2 stainless steel sieve filters;
  • . An input washing line connected to the 'blue' side the processing unit;
  • An access port for the loading of material to be processed with a Luer-lock connection and self-. occluding valve (blue side);
  • . A drain line connected to the gray side of the processing unit;
  • An access port for the discharge of processed material with a Luer-lock connection and selfoccluding valve (gray side);
  • . A bag for collecting waste material.

The Lipogems System Processing Unit is manufactured in two size variants with the same functional characteristics:

LGD 240: Lipogems Processing Unit with 240 cc capacity and standard exit sieve; LGD 60: Lipogems Processing Unit with 60 cc capacity and standard exit sieve;

The intrinsic characteristics of the Lipogems fat treatment can be summarized as follows:

  • . Minimal handling of adipose tissue (only via mechanical action);
  • Maintenance of the vascular-stromal niches; ●
  • . Reduction of fat clusters to allow injection with fine needles, up to 27G;
  • . Removal of impurities, such as oil residues and blood.

The result of processing with the Lipogens System is a homogeneous and micronized fraction of adjpose tissue, which allows a patient's subcutaneous fat to be processed for autologous reinjection within the operative procedure time.

There is no direct interaction of the device with the patient, although the adipose tissue that is processed in the device comes from the patient and is returned to the same patient after processing.

Interaction with other devices is necessary for operation of the Lipogems System, in particular, standard FDA cleared syringes are needed for the initial injection of adipose tissue into the processing unit, and for receiving the processed tissue upon completion of the processing steps.

The steps of operation of the Lipogems System are:

  • The Lipogems processing unit receives a constant gravity feed of physiological saline through the 1. upper port. After first filling the processing unit with saline, adipose tissue is injected into the processing unit, where it undergoes a first reduction treatment and micronization of lipidic cluster as it passes through the input sieve.
    1. The processing unit is then shaken manually, causing the spheres contained within the processing unit to exert mechanical action on the tissue/saline emulsion and further reduce the lipidic clusters, preserving the vascular-stromal niches, while the continuous flow of saline

5

eliminates oil and blood component residuals from the emulsion. The used saline is collected in the waste bag. Conducting the mechanical reduction while fully immersed in saline minimizes any traumatic action on the cells.

    1. After completion of the shaking/washing step, the solution appears clear (at the top of the processing unit) and the lipoaspirate is yellow (at the bottom). The saline flow is then stopped and the device is inverted. A second adipose cluster reduction takes place by pushing the floating adipose clusters through the second sieve, pushing fluid from below with a svringe. The reduced clusters pass out of the (now) top of the unit into a collecting syringe.
      The materials used in the manufacture of the device are in common usage for medical devices. Testing in accordance with the relevant standards in the ISO 10993 series has demonstrated device biocompatibility.

100 % testing of device patency and freedom from leakage is carried out after manufacture and before terminal sterilization by ethylene oxide gas, resulting in a sterility assurance level (SAL) of 10-9. The sterilization process has been validated in accordance with ISO 11135-1. The device is supplied for single use only.

A shelf life of five years has been established for the Lipogems System. This shelf life was established by exposing sterilized samples of the device to accelerated aging equivalent to five years real-time, in accordance with standard ASTM F1980.

ltemPredicate deviceSubject deviceSimilarity
Device nameGID 700 Tissue CanisterThe Lipogems SystemN/A
Device ManufacturerGID Group IncLipogems International SpAN/A
510(k) ReferenceK120902Not yet assignedN/A
FDA Product CodeMUUMUUSame
FDA Classification NameSystem, Suction, LipoplastySystem, Suction, LipoplastySame
FDA Regulation Number878.5040878.5040Same
Indications for Use /
Intended UseThe GID 700 is used for aspiration,
harvesting, filtering, and transferring
of autologous adipose tissue for
aesthetic body contouring. The
system should be used with a
legally marketed vacuum or
aspirator apparatus as a source of
suction. If harvested fat is to be
reimplanted, the harvested fat is
only to be used without any
additional manipulation.
The GID 700 is intended for use in
the following surgical specialties
when aspiration of soft tissue is
desired: plastic and reconstructive
surgery, neurosurgery,
gastrointestinal and affiliated organ
surgery, urological surgery, general
surgery, orthopedic surgery,
gynecological surgery, thoracic
surgery, and laparoscopic surgery.The Lipogems System is a sterile
medical device intended for the
closed-loop processing of
lipoaspirate tissue for the purpose of
transferring autologous adipose
tissue for aesthetic body contouring
(lipofilling) in applications including
plastic and reconstructive surgery,
neurosurgery, gastrointestinal and
affiliated organ surgery, urological
surgery, general surgery, orthopedic
surgery, gynecological surgery,
thoracic surgery, and laparoscopic
surgery. Only legally marketed
accessory items, such as syringes,
should be used with the system. If
harvested fat is to be reimplanted,
the harvested fat is only to be used
without any additional manipulation.Similar
VariationsOne only: GID 700Two: LGD 240, LGD 60Different
System conceptClosed loopClosed loopSame
ConstructionPreassembledPreassembledSame
SterilitySupplied sterile for single useSupplied sterile for single useSame

Substantial equivalence:

6

ItemPredicate deviceSubject deviceSimilarity
Sterilization methodElectron beam radiationEthylene oxideDifferent
Sterility Assurance LevelSAL = 10-6SAL = 10-6Same
BiocompatibilityBiocompatibleBiocompatibleSame
Source of EnergyUser supplied vacuumNone requiredDifferent
Mechanical operationManual stirring mechanism
comprising a propeller and a combManual shaking of s/steel spheresDifferent
Canister size700 ml240 or 60 mlDifferent
Canister portsSuction, vent, input, extractionSaline feed, input, drainage,
extractionSimilar
Tissue washing mediaLactated Ringers SolutionPhysiological salineDifferent
Mesh sizes200 micron mesh to allow
separation of waste products from
adipose tissue - tissue does not
pass through meshLGD 240 and LGD 60: 2000 micron
mesh at inlet and 1000 micron mesh
at outlet - collected adipose tissue
passes though both meshesDifferent
Unit testingImplosion testLeakage testDifferent

The subject device and the predicate device share many identical or similar features and parameters. Differences exist in the following areas:

  • Size variations
  • Sterilization method
  • Source of energy ●
  • Mechanical operation ●
  • . Tissue washing media
  • Filtering .
  • Unit testing ●

The most significant difference relates to the user manual shaking of the processing unit of the subject device in order to achieve adipose tissue reduction, whereas the predicate devices utilizes a rotary stirring action of a propeller and comb.

Substantial Equivalence Conclusion:

Based on the information contained in this submission, it is concluded that the Lipogems System is substantially equivalent to the identified predicate device which is already in interstate commerce within the USA.

Performance data:

The performance of the device is entirely controlled by the user and is not predetermined by the device itself. The instructions for use advise the user to process the tissue by waving and shaking the unit vigorously for a few minutes to emulsify the content. The instructions continue by identifying that when the processing phase is complete, fat tissue will appear compact, light yellow in color, floating on the transparent liquid phase.

Nonclinical testing:

The following nonclinical tests have been performed on the relevant components of the Lipogems system:

  • Validation of the pre-assembly washing process carried out on the device spheres and sieves. ●
  • Biocompatibility testing of all materials in the fluid path, including: ●
    • Cytoxicity (ISO 10993-5); o
    • Sensitization (ISO 10993-10); O
    • Intracutaneous Reactivity (ISO 10993-10); O
    • Acute Systemic Toxicity (ISO 10993-11); O
    • LAL bacterial endotoxin test. O

7

  • . Validation of the sterilization process (ISO 11153-1)
    • Testing to validate a 5 year shelf life, including:
      • o Peel strength;
      • o
  • . In-process patency and leakage testing of every device.