K Number
K151222
Device Name
Cautery Tip Cleaner
Manufacturer
Date Cleared
2015-05-22

(15 days)

Product Code
Regulation Number
878.4400
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The disposable cautery tip cleaner is a single use sterile device intended to be used as an electrosurgical accessory to remove eschar buildup from the tips of electrosurgical cauterization blades during surgical procedures.
Device Description
The disposable cautery tip cleaner is a 50mm by 50mm small foam pad with an abrasive surface, and adhesive back layer, which are used to aid in the removal of eschar on electrosurgical blades during surgical procedures. The abrasive surface is made from aluminum oxide 'gravel', with a polyurethane foam pad and polyurethane adhesive layer containing a barium monofilament for x-ray detection. The adhesive back allows for universal placement and keeps the device in place while the tip of the electrosurgical cauterization device is scratched on the abrasive surface to remove eschar buildup. The product does not come in contact with the patient, is provided sterile and is single-use.
More Information

Not Found

No
The device description and performance studies indicate a simple mechanical device for cleaning cautery tips, with no mention of AI or ML.

No
The device is described as an electrosurgical accessory used to clean electrosurgical cauterization blades, not to treat a medical condition or disease.

No

Explanation: The device is described as an electrosurgical accessory used to clean cautery tips during surgery, and its function is to remove eschar buildup, not to provide diagnostic information about a patient's condition.

No

The device description clearly outlines physical components (foam pad, abrasive surface, adhesive back layer, barium monofilament) and does not mention any software functionality.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In Vitro Diagnostic devices are used to examine specimens taken from the human body (like blood, urine, tissue) to provide information about a person's health. They are used outside of the body (in vitro).
  • Device Function: This device is used to clean the tip of a surgical instrument during a surgical procedure. It does not interact with patient specimens or provide diagnostic information.
  • Intended Use: The intended use clearly states it's an "electrosurgical accessory to remove eschar buildup from the tips of electrosurgical cauterization blades during surgical procedures." This is a functional, non-diagnostic purpose.
  • Device Description: The description details its physical characteristics and how it's used to clean the cautery tip. There is no mention of analyzing biological samples.
  • Lack of Diagnostic Information: The provided information does not include any metrics or studies related to diagnostic performance (like sensitivity, specificity, etc.). The performance studies focus on sterility, functional requirements, and packaging integrity.

This device is a surgical accessory used to maintain the functionality of another surgical instrument. It does not fit the definition or purpose of an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

The disposable cautery tip cleaner is a single use sterile device intended to be used as an electrosurgical accessory to remove eschar buildup from the tips of electrosurgical cauterization blades during surgical procedures.

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

GEI

Device Description

The disposable cautery tip cleaner is a 50mm by 50mm small foam pad with an abrasive surface, and adhesive back layer, which are used to aid in the removal of eschar on electrosurgical blades during surgical procedures. The abrasive surface is made from aluminum oxide 'gravel', with a polyurethane foam pad and polyurethane adhesive layer containing a barium monofilament for x-ray detection. The adhesive back allows for universal placement and keeps the device in place while the tip of the electrosurgical cauterization device is scratched on the abrasive surface to remove eschar buildup. The product does not come in contact with the patient, is provided sterile and is single-use.

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

The product is usually placed somewhere on the sterile field, typically on the mayo stand. This product does not come in contact with the patient.

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 Summary:

Requirement: Sterility
Specification: SAL 10-6
Method: ISO 11137-2
Result: Pass

Requirement: Functional Requirements
Specification: Product adhesive backing must be easily removed
Method: Removed adhesive backing from tip cleaner
Result: Pass

Requirement: Packaging
Specification: Vacuum leak test
Method: ISO 11607, ASTMF 1980
Result: Pass

Requirement: Packaging
Specification: Dye penetration test
Method: ASTMF 1929, ASTMF 1980
Result: Pass

Requirement: Packaging
Specification: Agar contact-attack test
Method: ISO 11607, ASTMF 1980
Result: Pass

Requirement: Packaging
Specification: Tensile seal strength test
Method: ASTMF 88, ASTMF 1980
Result: Pass

Requirement: Packaging
Specification: Accelerated aging test
Method: ASTMF 1980, ISO 11737
Result: Pass

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.

K053433

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

§ 878.4400 Electrosurgical cutting and coagulation device and accessories.

(a)
Identification. An electrosurgical cutting and coagulation device and accessories is a device intended to remove tissue and control bleeding by use of high-frequency electrical current.(b)
Classification. Class II.

0

Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized caduceus symbol, which is a staff with two snakes coiled around it, representing medicine and healing. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular pattern around the caduceus symbol.

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

May 22, 2015

Key Surgical Incorporated Ms. Amy Yanta Regulatory Affairs 8101 Wallace Road Eden Prairie, Minnesota 55344

Re: K151222

Trade/Device Name: Key Surgical® Cautery Tip Cleaner Regulation Number: 21 CFR 878.4400 Regulation Name: Electrosurgical cutting and coagulation device and accessories Regulatory Class: Class II Product Code: GEI Dated: May 6, 2015 Received: May 13, 2015

Dear Ms. Yanta:

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 device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set

1

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/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 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.

Jennifer R. Stevenson -S

For 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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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

510(k) Number (if known) K151222

Device Name

Key Surgical® Cautery Tip Cleaner

Indications for Use (Describe)

The disposable cautery tip cleaner is a single use sterile device intended to be used as an electrosurgical accessory to remove eschar buildup from the tips of electrosurgical cauterization blades during surgical procedures.

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)

Form Approved: OMB No. 0910-0120

Expiration Date: January 31, 2017

See PRA Statement below.

CONTINUE ON A SEPARATE PAGE IF NEEDED.

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."

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Image /page/3/Picture/0 description: The image shows the logo for Key Surgical. The logo consists of a blue circle with a white "K" inside, followed by the word "KEY" in gray and "SURGICAL" in blue. There is a registered trademark symbol to the right of the word "SURGICAL".

SECTION 5: 510(k) Summary

Key Surgical® Cautery Tip Cleaners

The summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements as required by 21 CFR 807.92.

Date:May 06, 2015
---------------------

Administrative Information

Submitter:Key Surgical, Inc.
Establishment Registration Number:2183785
Contact Person:Amy Yanta
8101 Wallace Road
Eden Prairie, MN 55344
Regulatory Affairs
952.288.2269

Device Identification

Device Name:Cautery Tip Cleaners
Common Name:Cautery Tip Cleaners
Device Classification Name:Electrosurgical cutting and coagulation device and accessories
Device Classification:Class II
Panel:General & Plastic Surgery
Classification Regulation:878.4400
Product Code:GEI
Performance Standards:No Recognized Consensus Standards
Predicate Device:Cautery Tip Cleaner, cleared on 01/19/2006 via K053433
Trade Name:None

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Image /page/4/Picture/0 description: The image shows the logo for Key Surgical. The logo consists of a blue circle with a white "K" inside, followed by the word "KEY" in gray and "SURGICAL" in blue. There is a registered trademark symbol to the right of the word "SURGICAL".

SECTION 5: 510(k) Summary

Device Description

The disposable cautery tip cleaner is a 50mm by 50mm small foam pad with an abrasive surface, and adhesive back layer, which are used to aid in the removal of eschar on electrosurgical blades during surgical procedures. The abrasive surface is made from aluminum oxide 'gravel', with a polyurethane foam pad and polyurethane adhesive layer containing a barium monofilament for x-ray detection. The adhesive back allows for universal placement and keeps the device in place while the tip of the electrosurgical cauterization device is scratched on the abrasive surface to remove eschar buildup. The product does not come in contact with the patient, is provided sterile and is single-use.

Statement of Intended Use

The disposable cautery tip cleaner is a single use sterile device intended to be used as an electrosurgical accessory to remove eschar buildup from the tips of electrosurgical cauterization blades during surgical procedures.

Substantial Equivalence Discussion

The Key Surgical Cautery Tip Cleaner predicate device is the Xodus Medical, Inc., K053433, cleared on January 19, 2006. The following illustrates the similarities in the product design.

| | Proposed Device: | Predicate Device:
Cautery Tip Cleaner | |
|----------------------------------|--------------------------------------|------------------------------------------|--|
| Property or Characteristic | Key Surgical® Cautery Tip Cleaner | | |
| Intended Use/Indications for Use | A device intended to be used to aid | The disposable Cautery Tip Cleaner | |
| | in the removal of eschar buildup on | is a single use sterile product. Its | |
| | electrosurgical blades during | intended use is as an electrosurgical | |
| | surgical procedures. The cautery tip | accessory to clean uncoated cautery | |
| | cleaner is sterile and a single use | blades that are part of an | |
| | device. | electrosurgical pencil. The cautery | |
| | | blade is "scratched" on the cautery | |
| | | tip cleaner to remove eschar build- | |
| | | up during surgical procedures to | |
| | | allow the cautery blade to function | |
| | | effectively throughout the | |
| | | procedure. The product is usually | |
| | | placed somewhere on the sterile | |
| | | field, typically on the mayo stand. | |
| | | This product does not come in | |
| | | contact with the patient. | |
| Conditions of Use | Single Use, disposable | Single Use, disposable | |
| Materials | Aluminum oxide 'gravel', with a | Square polyurethane foam pad | |
| | polyurethane foam pad and | featuring a textile abrasive layer | |
| | polyurethane adhesive layer | with an adhesive backing containing | |
| | containing a barium monofilament | an x-ray detectable radiopaque | |
| | for x-ray detection | strip. | |
| Adhesive back | Yes, for universal placement and aid | Yes, for universal placement and aid | |
| | in keeping the device in place | in keeping the device in place | |

Table 2: Substantial Equivalence

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Image /page/5/Picture/0 description: The image shows the logo for Key Surgical. The logo consists of a blue circle with a white "K" inside, followed by the text "KEY" in gray and "SURGICAL" in blue. A registered trademark symbol is located to the right of the word "SURGICAL".

SECTION 5: 510(k) Summary

SterilityProvided SterileProvided Sterile
Principle of OperationThe cautery tip cleaner is used to
aid in the removal of eschar on
electrosurgical blades during
surgical proceduresElectrosurgical accessory to clean
uncoated blades that are part of a
electrosurgical pencil
Interface with Electrosurgical
Cauterization BladeThe Cautery Tip Cleaner does not
impact the function of the
electrosurgical cauterization blades.
It is not required for use with the
blades, but an accessory that aids in
the removal of eschar buildup.Used for the cleaning of
electrosurgical cautery tips during
surgical procedures.

Performance Data Summary

Table 3: Performance Data Summary of Cautery Tip Cleaners

RequirementSpecificationMethodResult
SterilitySAL 10-6ISO 11137-2Pass
Functional
RequirementsProduct adhesive backing must
be easily removedRemoved adhesive backing
from tip cleanerPass
PackagingVacuum leak testISO 11607, ASTMF 1980Pass
Dye penetration testASTMF 1929, ASTMF 1980Pass
Agar contact-attack testISO 11607, ASTMF 1980Pass
Tensile seal strength testASTMF 88, ASTMF 1980Pass
Accelerated aging testASTMF 1980, ISO 11737Pass

Substantial Equivalence Conclusion

The differences between the Cautery Tip Cleaners and the predicate device do not constitute a new intended use, and do not raise different questions of safety and effectiveness. They are both designed to aid in the cleaning of electrosurgical blades during surgical procedures.

The Cautery Tip Cleaners are substantially equivalent to the predicate device cleared under K053433.

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