K Number
K162947
Device Name
Disposable End-to-end Anastomosis Circular Stapler; Universal Endoscopic Linear Cutting Stapler and Single Use Loading Unit; Linear Cutting Stapler and Single Use Loading Unit; Disposal Hemorrhoidal Circular Stapler
Date Cleared
2017-03-03

(133 days)

Product Code
Regulation Number
878.4750
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The Disposable End-to-end Anastomosis Circular Stapler has applications throughout the alimentary tract for the creation of end-to end, side-to-side and end-to-side anastomoses in both open and laparoscopic surgeries, including bariatric surgery. The Universal Endoscopic Linear Cutting Stapler and Single Use Loading Unit has applications in abdominal, gynecologic, pediatric and thoracic surgery for resection of anastomosis. They may be used for transection and resection of liver substance, hepatic vasculature and for transection and resection and resection of pancreas. The Linear Cutting Stapler and Single Use Loading Unit has applications in abdominal, gynecological, pediatric and thoracic surgical procedures for resection and creation of anastomosis. The stapler may be used for occlusion of the left atrial appendage in open procedures. They may be used for transection of pancreas. The Disposable Hemorrhoidal Circular Stapler has application throughout the anal to perform surgical treatment of hemorrhoidal disease.
Device Description
Disposable End-to-end Anastomosis Circular Stapler places a double staggered, circular row of titanium staples upon activation, which was achieved by squeezing the handles firmly as far as they could go. Immediately after formation of the staples, the excess tissue will be resect by the circular knife, and then a circular anastomosis is created. The stapler are available in 25mm and 31mm three specifications. The staple size is 4.8 mm. Universal Endoscopic Linear Cutting Stapler and Single Use Loading Unit places two, triple-staggered rows of progressive or equal titanium staples and simultaneously divides the tissue from central line. The devices are available in 30mm, 45mm and 60mm three lengths. Reloads are available in staple sizes 2mm-3mm, 3mm-4mm, 2.5mm, 4.0mm. 4.8mm to accommodate various tissue thicknesses. The device may be reloaded and fired up to 25 times in a single procedure. Linear Cutting Stapler and Single Use Loading Unit places two double staggered rows of titanium staples and simultaneously cut and divides tissue between the two double rows. The devices are available in 60mm, 80mm and 100mm lengths. Reloads are available in two staple sizes to accommodate various tissue thicknesses: 3.8mm and 4.8mm. It may be reloaded and fired up to 7 times for a total 8 firings in a single procedure. Disposable Hemorrhoidal Circular Stapler is a set of instrument that place a double staggered, circular row of titanium staples. Immediately after the formation of staples, the circular knife blade resects the excess of compressed mucosa. The stapler is available in 33mm one specification. The staple size is 4.5mm. It cannot be reloaded.
More Information

Not Found

No
The device description and performance studies focus on mechanical function and material properties, with no mention of AI/ML, image processing, or data-driven decision making.

No
The devices described are surgical staplers used for mechanical wound closure and tissue resection, which are procedural tools rather than devices that provide therapy for a condition.

No
The provided text describes various types of surgical staplers used for transection, resection, and creation of anastomoses in different surgical procedures. These devices are used for treatment and repair, not for diagnosing conditions.

No

The device description clearly outlines physical, mechanical staplers and their components (staples, knives, handles), indicating it is a hardware medical device. There is no mention of software as the primary or sole component.

Based on the provided text, no, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use clearly describes surgical procedures performed on the patient's body (in vivo), such as creating anastomoses, resecting tissue, and occluding structures. IVDs are used to examine specimens from the body (in vitro) to provide information for diagnosis, monitoring, or treatment.
  • Device Description: The device descriptions detail mechanical staplers and cutting instruments used during surgery. This aligns with surgical devices, not diagnostic tests performed on samples.
  • Performance Studies: The performance studies focus on mechanical properties and tissue interaction (bench tests on swine tissue), which are relevant to surgical devices. IVD performance studies would typically involve evaluating the accuracy and reliability of measurements or analyses performed on biological samples.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples, detecting analytes, or providing diagnostic information.

The devices described are surgical instruments used for mechanical manipulation of tissue during procedures.

N/A

Intended Use / Indications for Use

The Disposable End-to-end Anastomosis Circular Stapler has applications throughout the alimentary tract for the creation of end-to end, side-to-side and end-to-side anastomoses in both open and laparoscopic surgeries, including bariatric surgery.

The Universal Endoscopic Linear Cutting Stapler and Single Use Loading Unit has applications in abdominal, gynecologic, pediatric and thoracic surgery for resection of anastomosis. They may be used for transection and resection of liver substance, hepatic vasculature and for transection and resection and resection of pancreas.

The Linear Cutting Stapler and Single Use Loading Unit has applications in abdominal, gynecological, pediatric and thoracic surgical procedures for resection and creation of anastomosis. The stapler may be used for occlusion of the left atrial appendage in open procedures. They may be used for transection of pancreas.

The Disposable Hemorrhoidal Circular Stapler has application throughout the anal to perform surgical treatment of hemorrhoidal disease.

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

GDW

Device Description

Disposable End-to-end Anastomosis Circular Stapler places a double staggered, circular row of titanium staples upon activation, which was achieved by squeezing the handles firmly as far as they could go. Immediately after formation of the staples, the excess tissue will be resect by the circular knife, and then a circular anastomosis is created. The stapler are available in 25mm and 31mm three specifications. The staple size is 4.8 mm.

Universal Endoscopic Linear Cutting Stapler and Single Use Loading Unit places two, triple-staggered rows of progressive or equal titanium staples and simultaneously divides the tissue from central line. The devices are available in 30mm, 45mm and 60mm three lengths. Reloads are available in staple sizes 2mm-3mm, 3mm-4mm, 2.5mm, 4.0mm. 4.8mm to accommodate various tissue thicknesses. The device may be reloaded and fired up to 25 times in a single procedure.

Linear Cutting Stapler and Single Use Loading Unit places two double staggered rows of titanium staples and simultaneously cut and divides tissue between the two double rows. The devices are available in 60mm, 80mm and 100mm lengths. Reloads are available in two staple sizes to accommodate various tissue thicknesses: 3.8mm and 4.8mm. It may be reloaded and fired up to 7 times for a total 8 firings in a single procedure.

Disposable Hemorrhoidal Circular Stapler is a set of instrument that place a double staggered, circular row of titanium staples. Immediately after the formation of staples, the circular knife blade resects the excess of compressed mucosa. The stapler is available in 33mm one specification. The staple size is 4.5mm. It cannot be reloaded.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

alimentary tract, abdominal, gynecologic, pediatric, thoracic, liver, hepatic vasculature, biliary structures, pancreas, left atrial appendage, anal canal

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Open and laparoscopic surgeries.

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

Bench test was conducted on swine stomach and intestine tissue for both proposed device and predicate device to determine substantially equivalence. The bench tests include following tests

  • Pressure Resistance Test
  • Closed Staple Height Test
  • Staple Formation Test
  • Force Required to Fire Stapler Test

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Non clinical tests were conducted to verify that the proposed device met all design specifications as was Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the proposed device complies with the following standards:

  • ISO 10993-1:2009 Biological evaluation of medical devices- Part 1: Evaluation and testing within a risk management process.
  • ISO 10993-5:2009 Biological evaluation of medical devices-Part 5: Tests for in vitro cytotoxicity.
  • ISO 10993-10:2010 Biological evaluation of medical devices- Part 10: Test for irritation and delayed-type hypersensitivity
  • USP 38-NF 33 Bacterial Endotoxins Tests
  • ASTM F 88/F88M-09 Standard test method for seal strength of flexible barrier materials; A
  • ISO 11137-2: 2013 Sterilization of health care products -Radiation- Part 2: Establishing the sterilization dose
  • ISO 11135: 2014 Sterilization of health-care products - Ethylene oxide - Requirements for the development, validation and routine control of a sterilization process for medical devices
  • ASTM F88/F88-09 Standard test method for seal strength of flexible barrier materials.
  • ASTM F1929-12 Standard Test Method for Detecting Seal Leaks in Porous Medical Packaging by Dye Penetration

Bench test was conducted on swine stomach and intestine tissue for both proposed device and predicate device to determine substantially equivalence. The bench tests include following tests:

  • Pressure Resistance Test
  • Closed Staple Height Test
  • Staple Formation Test
  • Force Required to Fire Stapler Test

No clinical study is included in this submission.

Key Results: Based on the comparison and analysis, the proposed devices are determined to be Substantially Equivalent (SE) to the predicate devices.

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.

K062850, K111825, K051301, K061156

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

§ 878.4750 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.

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 depiction of a human figure with three faces in profile, overlaid on top of each other. The figure is positioned to the right of the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA", which is arranged in a circular fashion around the figure.

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

March 3, 2017

Chongqing Qmi Surgical Co., Ltd % Ms. Diana Hong Mid-Link Consulting Co., Ltd P.O. Box 120-119 Shanghai, 200120 CN

Re: K162947

Trade/Device Name: Disposable End-to-end Anastomosis Circular Stapler; Universal Endoscopic Linear Cutting Stapler And Single Use Loading Unit; Linear Cutting Stapler And Single Use Loading Unit: Disposal Hemorrhoidal Circular Stapler

Regulation Number: 21 CFR 878.4750 Regulation Name: Implantable staple Regulatory Class: Class II Product Code: GDW Dated: January 24, 2017 Received: January 30, 2017

Dear Ms. Hong:

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 mav 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 of medical device

1

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/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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,

David Krause -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

2

Indications for Use

510(k) Number (if known) K162947

Device Name

Disposable End-to-end Anastomosis Circular Stapler, Universal Endoscopic Linear Cutting Stapler and Single Use Loading Unit, Linear Cutting Stapler and Single Use Loading Unit, Disposable Hemorrhoidal Circular Stapler

Indications for Use (Describe)

The Disposable End-to-end Anastomosis Circular Stapler has applications throughout the alimentary tract for the creation of end-to end, side-to-side and end-to-side anastomoses in both open and laparoscopic surgeries, including bariatric surgery.

The Universal Endoscopic Linear Cutting Stapler and Single Use Loading Unit has applications in abdominal, gynecologic, pediatric and thoracic surgery for resection of anastomosis. They may be used for transection and resection of liver substance, hepatic vasculature and for transection and resection and resection of pancreas.

The Linear Cutting Stapler and Single Use Loading Unit has applications in abdominal, gynecological, pediatric and thoracic surgical procedures for resection and creation of anastomosis. The stapler may be used for occlusion of the left atrial appendage in open procedures. They may be used for transection of pancreas.

The Disposable Hemorrhoidal Circular Stapler has application throughout the anal to perform surgical treatment of hemorrhoidal disease.

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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3

510(k) Summary

This 510(k) Summary is being submitted in accordance with requirements of Title 21, CFR Section 807.92.

The assigned 510(k) Number: K162947

    1. Date of Preparation: 03/03/2017
    1. Sponsor Identification

CHONGQING QMI SURGICAL CO., LTD.

A Zone 1st floor, Yangliu Road No.2 North New Zone, Chongqing China

Establishment Registration Number: Not yet registered

Contact Person: Kang Li Position: General Manager Tel: +86-23-67300630 Fax: +86-23-63053502 Email: kang.li@qmimed.com

    1. Designated Submission Correspondent
      Ms. Diana Hong (Primary Contact Person) Ms. Ying Xu (Alternative Contact Person)

Mid-Link Consulting Co., Ltd P.O. Box 120-119, Shanghai, 200120, China

Tel: +86-21-22815850, Fax: 240-238-7587 Email: info@mid-link.net

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4. Identification of Proposed Device

Trade Name: Disposable End-to-end Anastomosis Circular Stapler

Universal Endoscopic Linear Cutting Stapler and Single Use Loading Unit Linear Cutting Stapler and Single Use Loading Unit Disposable Hemorrhoidal Circular Stapler Common Name: Stapler and Reload

Regulatory Information

Classification Name: Staple, Implantable Classification: II; Product Code: GDW Subsequent product code: GAG Regulation Number: 21CFR 878.4750 Review Panel: General & Plastic Surgery

Intended Use Statement:

The Disposable End-to-end Anastomosis Circular Stapler has applications throughout the alimentary tract for the creation of end-to end, side-to-side and end-to-side anastomoses in both open and laparoscopic surgeries, including bariatric surgery.

The Universal Endoscopic Linear Cutting Stapler and Single Use Loading Unit has applications in abdominal, gynecologic, pediatic and thoracic surgery for resection and creation of anastomosis. They may be used for transection of liver substance, hepatic vasculature and biliary structures and for transection and resection of pancreas.

The Linear Cutting Stapler and Single Use Loading Unit has applications in abdominal, gynecological, pediatric and thoracic surgical procedures for resection and creation of anastomosis. The stapler may be used for occlusion of the left atrial appendage in open procedures. They may be used for transection and resection of pancreas.

The Disposable Hemorrhoidal Circular Stapler has application throughout the anal canal to perform surgical treatment of hemorrhoidal disease.

Device Description

Disposable End-to-end Anastomosis Circular Stapler places a double staggered, circular row of titanium staples upon activation, which was achieved by squeezing the handles firmly as far as they could go.

5

Immediately after formation of the staples, the excess tissue will be resect by the circular knife, and then a circular anastomosis is created. The stapler are available in 25mm and 31mm three specifications. The staple size is 4.8 mm.

Universal Endoscopic Linear Cutting Stapler and Single Use Loading Unit places two, triple-staggered rows of progressive or equal titanium staples and simultaneously divides the tissue from central line. The devices are available in 30mm, 45mm and 60mm three lengths. Reloads are available in staple sizes 2mm-3mm, 3mm-4mm, 2.5mm, 4.0mm. 4.8mm to accommodate various tissue thicknesses. The device may be reloaded and fired up to 25 times in a single procedure.

Linear Cutting Stapler and Single Use Loading Unit places two double staggered rows of titanium staples and simultaneously cut and divides tissue between the two double rows. The devices are available in 60mm, 80mm and 100mm lengths. Reloads are available in two staple sizes to accommodate various tissue thicknesses: 3.8mm and 4.8mm. It may be reloaded and fired up to 7 times for a total 8 firings in a single procedure.

Disposable Hemorrhoidal Circular Stapler is a set of instrument that place a double staggered, circular row of titanium staples. Immediately after the formation of staples, the circular knife blade resects the excess of compressed mucosa. The stapler is available in 33mm one specification. The staple size is 4.5mm. It cannot be reloaded.

5. Identification of Predicate Devices

Predicate Device 1 510(k) Number: K062850 Product Name: autosuture™ Circular EEATM surgical staplers

Predicate Device 2 510(k) Number: K111825 Product Name: Endo GIATM Staplers

Predicate Device 3 510(k) Number: K051301 Product Name: PROXIMATE® PPH Hemorrhoidal Circular Stapler and Accessories

Predicate Device 4 510(k) Number: K061156 Product Name: ENDOPATH Linear Cutters and Staplers

Non-Clinical Test Conclusion 6.

6

Non clinical tests were conducted to verify that the proposed device met all design specifications as was Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the proposed device complies with the following standards:

  • A ISO 10993-1:2009 Biological evaluation of medical devices- Part 1: Evaluation and testing within a risk management process.
  • ISO 10993-5:2009 Biological evaluation of medical devices-Part 5: Tests for in vitro cytotoxicity.

  • ISO 10993-10:2010 Biological evaluation of medical devices- Part 10: Test for irritation and delayed-type hypersensitivity

  • A USP 38-NF 33 Bacterial Endotoxins Tests
  • ASTM F 88/F88M-09 Standard test method for seal strength of flexible barrier materials; A
  • ISO 11137-2: 2013 Sterilization of health care products -Radiation- Part 2: Establishing the sterilization dose

  • ISO 11135: 2014 Sterilization of health-care products - Ethylene oxide - Requirements for the development, validation and routine control of a sterilization process for medical devices

  • A ASTM F88/F88-09 Standard test method for seal strength of flexible barrier materials.
  • ASTM F1929-12 Standard Test Method for Detecting Seal Leaks in Porous Medical Packaging by Dye Penetration

Bench test was conducted on swine stomach and intestine tissue for both proposed device and predicate device to determine substantially equivalence. The bench tests include following tests

  • Pressure Resistance Test

  • Closed Staple Height Test

  • Staple Formation Test

  • Force Required to Fire Stapler Test

    1. Clinical Test Conclusion

No clinical study is included in this submission.

7

8. Substantially Equivalent (SE) Comparison

ItemProposed DevicePredicate Device 1ItemProposed DevicePredicate Device 2Predicate Device 4
Product CodeGDWK062850Product CodeGDWK111825K061156
Regulation Number21 CFR 878.4750SameRegulation Number21 CFR 878.4750SameSame
Intended UseThe Disposable End-to-end
Anastomosis Circular Stapler has
applications throughout the
alimentary tract for the creation of
end-to end, side-to-side and
end-to-side anastomoses in both open
and laparoscopic surgeries, including
bariatric surgery.SameIntended UseThe Universal Endoscopic Linear Cutting Stapler
and Single Use Loading Unit has applications in
abdominal, gynecologic, pediatric and thoracic
surgery for resection, transection and creation of
anastomosis. They may be used for transection and
resection of liver substance, hepatic vasculature and
biliary structures and for transection and resection
of pancreas.SameThe ENDOPATH Endocutter 60 Endoscopic
Linear Cutter is intended for transection,
resection, and/or creation of anastomoses.
The instrument has application in multiple
open or minimally invasive general,
gynecologic, urologic, thoracic, and
pediatric surgical procedures. It can be used
with staple line or tissue buttressing
materials.
Cutting MechanismCircular KnifeSameCutting MechanismLinear KnifeSameSame
Operation PrincipleManualSameOperation PrincipleManualSameSame
Safety MechanismInsurance is used for preventing from
mis-firingSameSafety MechanismGreen button is used for preventing from mis-firingSameSame
Closed staple height2.0mmSameClosed staple height1.0, 1.5, 1.75, 2.0mm
0.751.25, 1.251.75mm1.0, 1.5, 2.0mm
0.751.25, 1.251.75mm1.0, 1.5, 1.8mm
Closed staple formImage: staple formSameClosed staple formImage: staple formSameSame
SterilizationIrradiation SterilizationEO SterilizationSterilizationIrradiation SterilizationEO SterilizationEO Sterilization
Endotoxin Limit20 EUSameEndotoxin Limit20 EUSameSame
LabelingConforms with 21 CFR 801SameLabelingConforms with 21 CFR 801SameSame

Table 1 Comparison of Technology Characteristics for Disposable End-to-end Anastomosis Circular Stapler

8

Table 2 Comparison of Technology Characteristics for Universal Endoscopic Linear Cutting Stapler and Single Use Loading Unit

9

ItemProposed DevicePredicate Device 2
Product CodeGDWK111825
Regulation Number21 CFR 878.4750Same
Intended UseThe Linear Cutting Stapler and
Single Use Loading Unit has
applications in abdominal,
gynecological, pediatric and thoracic
surgical procedures for resection,
transection and creation of
anastomosis. The stapler may be used
for occlusion of the left atrial
appendage in open procedures. They
may be used for transection and
resection of pancreas.Same
Cutting MechanismLinear KnifeSame
Operation PrincipleManualSame
Closed staple height1.5mm, 2.0mm1.0mm, 1.5mm, 2.0mm
Closed staple formImage: staple formSame
SterilizationIrradiation SterilizationEO Sterilization
Endotoxin Limit20 EUSame
LabelingConforms with 21 CFR 801Same

Table 3 Comparison of Technology Characteristics for Linear Cutting Stapler and Single Use Loading Unit

10

ItemProposed DevicePredicate Device 3
Product CodeGDWK051301
Regulation Number21 CFR 878.4750Same
Intended UseThe Disposable Hemorrhoidal Circular Stapler has application throughout the anal canal to perform surgical treatment of hemorrhoidal disease.Same
Cutting MechanismCircular KnifeSame
Operation PrincipleManualSame
Safety MechanismInsurance is used for preventing from mis-firingSame
Closed staple height2.0mmSame
Closed staple formImage: staple formSame
SterilizationEO SterilizationSame
Endotoxin Limit20 EUSame
LabelingConforms with 21 CFR 801Same

Table 4 Comparison of Technology Characteristics for Disposable Hemorrhoidal Circular Stapler

  • Substantially Equivalent (SE) Conclusion 9.
    Based on the comparison and analysis above, the proposed devices are determined to be Substantially Equivalent (SE) to the predicate devices.