K Number
K163247
Device Name
3.3 mm Laurimed Microdebrider; 4.0 mm Laurimed Microdebrider
Manufacturer
Date Cleared
2017-03-09

(111 days)

Product Code
Regulation Number
874.4250
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The PolypVac Microdebrider is a shaver system intended for the resection of soft tissue and thin bone as part of the following endoscopic sinus procedures: ethmoidectomy, maxillary antrostomy, polypectomy, turbinectomy / turbinate reduction, sphenoidotomy, and frontal recess dissection.
Device Description
The PolypVac Microdebrider is a shaver system intended for the resection of soft tissue and thin bone as part of endoscopic sinus procedures. The system consists of a hand-held cutting device, tissue filter, and stylet. The PolypVac Microdebrider is supplied sterile and is single-use and disposable.
More Information

Not Found

No
The summary describes a mechanical shaver system and does not mention any AI or ML components or capabilities.

Yes
The device is a shaver system intended for the resection of soft tissue and thin bone as part of endoscopic sinus procedures, which are therapeutic interventions.

No

Explanation: The device is described as a "shaver system intended for the resection of soft tissue and thin bone," indicating a surgical or therapeutic function rather than diagnosis. There is no mention of it collecting data for analysis or providing diagnostic information.

No

The device description explicitly states the system consists of a hand-held cutting device, tissue filter, and stylet, which are hardware components.

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

Here's why:

  • IVD Definition: In vitro diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections. They are used to provide information for diagnosis, monitoring, or screening.
  • PolypVac Microdebrider Function: The description clearly states that the PolypVac Microdebrider is a "shaver system intended for the resection of soft tissue and thin bone" during surgical procedures. It is a surgical tool used within the body to remove tissue, not a test performed on a sample outside the body.

The information provided describes a surgical device, not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

The PolypVac Microdebrider is a shaver system intended for the resection of soft tissue and thin bone as part of the following endoscopic sinus procedures: ethmoidectomy, maxillary antrostomy, polypectomy, turbinectomy / turbinate reduction, sphenoidotomy, and frontal recess dissection.

Product codes

ERL

Device Description

The PolypVac Microdebrider is a shaver system intended for the resection of soft tissue and thin bone as part of endoscopic sinus procedures. The system consists of a hand-held cutting device, tissue filter, and stylet. The PolypVac Microdebrider is supplied sterile and is single-use and disposable.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Nasal passageways and sinuses.

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

Bench Testing:

  • Study type: Durability/Functionality Testing – Motor and Shaft, Dimensional Testing, Pull Force Testing - Bond Strength, Predicate Comparison - Resection Rate
  • Sample size: Not Specified
  • Key results: The subject PolypVac Microdebrider passed all functional testing and met all product specification requirements, thereby demonstrating equivalence to the predicate PolypVac device and suitability to the expanded indications for use.

Validation Testing:

  • Study type: Cadaver Simulated Use Testing
  • Sample size: Not Specified
  • Key results: Simulated use testing was completed successfully, no adverse events were observed. This testing demonstrates that the subject PolypVac Microdebrider is capable of safely performing the following procedures: turbinate reduction / turbinectomy, uncinectomy / maxillary antrostomy, ethmoidectomy, frontal recess dissection, and sphenoidotomy.

Key Metrics

Not Found

Predicate Device(s)

K161101, K041413

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 874.4250 Ear, nose, and throat electric or pneumatic surgical drill.

(a)
Identification. An ear, nose, and throat electric or pneumatic surgical drill is a rotating drilling device, including the handpiece, that is intended to drive various accessories, such as an ear, nose, and throat bur (§ 874.4140), for the controlled incision or removal of bone in the ear, nose, and throat area.(b)
Classification. Class II.

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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 graphic of three human profiles facing right, stacked on top of each other. The profiles are connected by flowing lines that resemble a ribbon or banner. The graphic is surrounded by the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged in a circular pattern.

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

March 9, 2017

Laurimed LLC Mr. Brian DuBois General Manger 500 Arguello St., Suite 100 Redwood City, CA 94063

Re: K163247

Trade/Device Name: PolypVac Microdebrider Regulation Number: 21 CFR 874.4250 Regulation Name: Ear, Nose, and Throat Electric or Pneumatic Surgical Drill Regulatory Class: Class II Product Code: ERL Dated: February 8, 2017 Received: February 9, 2017

Dear Mr. DuBois:

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.

1

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 devicerelated 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 yours.

Eric A. Mann -S

for Malvina B. Eydelman, M.D. Director Division of Ophthalmic and Ear, Nose and Throat Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known)

K163247

Device Name

PolypVac Microdebrider

Indications for Use (Describe)

The PolypVac Microdebrider is a shaver system intended for the resection of soft tissue and thin bone as part of the following endoscopic sinus procedures; ethmoidectorny, polypectorny, polypectorny, turbinate reduction, sphenoidotomy, and frontal recess dissection.

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

X Prescription Use (Part 21 CFR 801 Subpart D)

_ Over-The-Counter Use (21 CFR 801 Subpart C)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

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510(k) Summary – K163247

General Information [807.92(a)(1)] l.

Name, Address, Phone and FaxContact Person
Number of ApplicantAlex Gordon
Laurimed LLCDirector of Operations
500 Arguello Street, Suite 100Laurimed LLC
Redwood City, CA 94063500 Arguello Street, Suite 100
Phone: (650) 587-5296Redwood City, CA 94063
Fax:(650) 587-3823Phone: (650) 587-5230
Fax: (650) 587-3823

Date Prepared

February 8, 2017

II. Device Information [§807.92(a)(2)]

Trade Name: PolypVac Microdebrider Common Name: Microdebrider Classification Name: Ear, nose, and throat electric or pneumatic drill Classification: 21 CFR §874.4250 Product Code: ERL Device Class: Class II

lll. Predicate Device [§807.92(a)(3)]

The subject PolypVac Microdebrider is substantially equivalent to the primary predicate, the PolypVac Microdebrider (K161101), and the secondary predicate, the Medtronic Xomed XPS 3000 (K041413).

IV. Device Description [§807.92(a)(4)]

The PolypVac Microdebrider is a shaver system intended for the resection of soft tissue and thin bone as part of endoscopic sinus procedures. The system consists of a hand-held cutting device, tissue filter, and stylet. The PolypVac Microdebrider is supplied sterile and is single-use and disposable.

V. Indications for Use [§807.92(a)(5)]

The PolypVac Microdebrider is a shaver system intended for the resection of soft tissue and thin bone as part of the following endoscopic sinus procedures: ethmoidectomy, maxillary antrostomy, polypectomy, turbinectomy / turbinate reduction, sphenoidotomy, and frontal recess dissection.

VI. Comparison of Technological Characteristics with the Predicate Device [§807.92(a)((6)]

The technological characteristics and principles of operation of the subject PolypVac Microdebrider are substantially equivalent to the PolypVac Microdebrider primary predicate device (K161101) and the Medtronic Xomed XPS 3000 secondary predicate device (K041413).

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| Model Name | PolypVac Microdebrider
(Primary Predicate) | Xomed XPS 3000
(Secondary Predicate) | PolypVac Microdebrider | Rationale for Substantial |
|---------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Device Trade Name | PolypVac Microdebrider | XPS 3000 System | PolypVac Microdebrider | Equivalence |
| 510(k) Number | K161101 | K041413 | K163247 | |
| Product Code | ERL | ERL | ERL | Same. |
| Intended Use | Intended for the resection of
soft tissue during sinonasal
polypectomy. | Intended for the incision and removal of
soft and hard tissue or bone in general
otorhinolaryngology, head and neck, and
otoneurological surgery. | Intended for the resection of soft
tissue and thin bone in
endoscopic sinus procedures. | Both the subject PolypVac
Microdebrider and the Xomed XPS
3000 are intended for the resection
of soft tissue and thin bone during
otorhinolaryngology procedures. |
| Indications for
Use | Indicated for the excision of
polyps in the nasal
passageways and in sinuses
for which access has been
previously established. | The XPS 3000 is intended for the incision
and removal of soft and hard tissue or bone
in general otorhinolaryngology, head and
neck, and otoneurological surgery.
(non-applicable sections removed)
Sinus indications include: Septoplasty,
removal of septal spurs, POLYPECTOMY,
ANTROSTOMY, ETHMOIDECTOMY /
sphenoethmoidectomy, frontal sinus
trephination and irrigation, frontal sinus drill
out, endoscopic DCR, trans-spheniodal
procedures, maxillary sinus POLYPECTOMY,
circumferential MAXILLARY ANTROSTOMY,
choanal atresia, SPHENOIDOTOMY, and
medial, lateral, and posterior FRONTAL
SINUSOTOMY. (non-applicable sections removed) | The PolypVac Microdebrider is a
shaver system intended for the
resection of soft tissue and thin
bone as part of the following
endoscopic sinus procedures:
ethmoidectomy, maxillary
antrostomy, polypectomy,
turbinectomy / turbinate
reduction, sphenoidotomy, and
frontal recess dissection. | Both the subject PolypVac
Microdebrider and the Xomed XPS
3000 are indicted for:
$\Sigma$ Ethmoidectomy
$\Sigma$ Maxillary Antrostomy
$\Sigma$ Polypectomy
$\Sigma$ Turbinectomy / Turbinate
Reduction
$\Sigma$ Sphenoidotomy
$\Sigma$ Frontal recess dissection |
| Contraindications | None | None | None | Same. |
| Target
Population | Patients with accessible
sinonasal polyps | Patients in otorhinolaryngology, head and
neck, otoneurology, lipoplasty, and
orthopedic procedures. | Patients in otorhinolaryngology
procedures. | Both the subject PolypVac
Microdebrider and the Xomed XPS
3000 serve patients who would
benefit from otorhinolaryngology
procedures. |
| Anatomic Sites | Nose (including accessible
sinuses) | Nasal passageways, sinuses, nasopharynx,
larynx, ear, head and neck, and various
anatomic locations associated with
lipoplasty and/or orthopedic procedures. | Nasal passageways and sinuses. | Both the subject PolypVac
Microdebrider and the Xomed XPS
3000 are intended for use in the
nasal passageways and sinuses. |
| Model Name | PolypVac Microdebrider
(Primary Predicate) | Xomed XPS 3000
(Secondary Predicate) | PolypVac Microdebrider | Rationale for Substantial
Equivalence |
| Device Trade Name | PolypVac Microdebrider | XPS 3000 System | PolypVac Microdebrider | |
| 510(k) Number | K161101 | K041413 | K163247 | |
| Target Tissue | Sinonasal Polyps | Various soft and hard tissues encountered
during otology, otorhinolaryngology, head
and neck, lipoplasty, and orthopedic
procedures. | Various soft and hard tissues
encountered during
otorhinolaryngology procedures. | Both the subject PolypVac
Microdebrider and the Xomed XPS
3000 are intended for the resection
of various soft and hard tissues
encountered during
otorhinolaryngology procedures. |
| Method of
Introduction | Manual placement under
visual guidance. | Manual placement under visual guidance. | Manual placement under visual
guidance. | Same. |
| Mechanism of
Action | Suction from user-supplied
vacuum pump draws tissue
into side-facing cutting
window, tissue excised by
oscillating cutter. | Suction from user-supplied vacuum pump
draws tissue into side-facing cutting
window, tissue excised by oscillating cutter. | Suction from user-supplied
vacuum pump draws tissue into
side-facing cutting window, tissue
excised by oscillating cutter. | Same. |
| Compatibility | User-supplied endoscope,
vacuum pump, and sterile
irrigant syringe / bag. | User-supplied endoscope, vacuum pump,
and sterile irrigant bag. | User-supplied endoscope,
vacuum pump, and sterile irrigant
syringe / bag. | Same. |
| Design Features | Blade Diameter:
3.3 mm and 4.0 mm | Blade Diameter:
3.5 mm and 4.0 mm
(RAD 12 & 40 Blades) | Blade Diameter:
3.3 mm and 4.0 mm | Blades of similar diameter are
offered. |
| | Distal Tip:
Blunt distal tip with side-
facing cutting window. | Distal Tip:
Blunt distal tip with side-facing cutting
window. | Distal Tip:
Blunt distal tip with side-facing
cutting window. | Same. |
| | Internal Irrigation:
Irrigant routed within the
shaver blade to the cutting
window, where it is
suctioned through the
device, facilitating
evacuation of excised tissue. | Internal Irrigation:
Irrigant routed within the shaver blade to
the cutting window, where it is suctioned
through the device, facilitating evacuation of
excised tissue. | Internal Irrigation:
Irrigant routed within the shaver
blade to the cutting window,
where it is suctioned through the
device, facilitating evacuation of
excised tissue. | Same. |
| Model Name | PolypVac Microdebrider
(Primary Predicate) | Xomed XPS 3000
(Secondary Predicate) | PolypVac Microdebrider | Rationale for Substantial
Equivalence |
| Device Trade Name | PolypVac Microdebrider | XPS 3000 System | PolypVac Microdebrider | |
| 510(k) Number | K161101 | K041413 | K163247 | |
| Human Factors | Handle fits in the surgeon's
hand. Shaver blade extends
forward while vacuum and
irrigant connections extend
backwards.

Trigger location on side of
handle activates and halts
the motion of the tissue
cutter. | Handle fits in the surgeon's hand. Shaver
blade extends forward while vacuum and
irrigant connections extend backwards.

Foot pedal activates and halts the motion of
the tissue cutter. | Handle fits in the surgeon's hand.
Shaver blade extends forward
while vacuum and irrigant
connections extend backwards.

Trigger location on side of handle
activates and halts the motion of
the tissue cutter. | Same.

Both the subject PolypVac
Microdebrider and the Xomed XPS
3000 have controls that must be
pressed in order to activate
oscillation of the tissue cutter. |
| Materials /
Biocompatibility | Biocompatible for its
intended use. All contact
materials have been
evaluated per ISO 10993. | Biocompatible for its intended use.
Specific materials not known. | Biocompatible for its intended
use. All contact materials have
been evaluated per ISO 10993. | Both the subject PolypVac
Microdebrider and the Xomed XPS
3000 are biocompatible for their
intended use. |
| Sterility | E-beam radiation (SAL $10^{-6}$ ). | Ethylene Oxide (single-use shaver blades). | E-beam radiation (SAL $10^{-6}$ ). | Both the subject PolypVac
Microdebrider and the shaver blades
for the Xomed XPS 3000 are supplied
sterile. |

Table 1: Summary of Technological Characteristics

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VII. Performance Data [§807.92(b)]

Results of non-clinical testing demonstrate that the subject PolypVac Microdebrider is safe and effective for its intended use and substantially equivalent to the predicates.

Summary of Nonclinical Testing [§807.92(b)(1)]

Non-clinical testing was conducted to verify / validate the performance of the device and ensure the subject PolypVac Microdebrider functions as intended and meets design specifications. The results demonstrate that the subject PolypVac Microdebrider is substantially equivalent to the predicate device for its intended use and does not raise new issues of safety or effectiveness. Note that the changes presented in this submission have no effect on previously performed packaging validation and biocompatibility validation testing.

| Testing Type | Test Description | Results Supporting Substantial
Equivalence |
|--------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Bench Testing | Durability/Functionality Testing
– Motor and Shaft
Dimensional Testing
Pull Force Testing - Bond
Strength
Predicate Comparison -
Resection Rate | The subject PolypVac
Microdebrider passed all
functional testing and met all
product specification
requirements, thereby
demonstrating equivalence to
the predicate PolypVac device
and suitability to the expanded
indications for use. |
| Validation Testing | Cadaver Simulated Use Testing | Simulated use testing was
completed successfully, no
adverse events were observed.
This testing demonstrates that
the subject PolypVac
Microdebrider is capable of
safely performing the following
procedures: turbinate reduction
/ turbinectomy, uncinectomy /
maxillary antrostomy,
ethmoidectomy, frontal recess
dissection, and sphenoidotomy. |

Table 2. Performance Testing and Substantial Equivalence Support
----------------------------------------------------------------------------

Summary of Clinical Data [§807.92(b)(2)]

No clinical testing was performed nor necessary in support of this premarket notification.

VIII. Conclusion [§807.92(b)(3)]

The subject PolypVac Microdebrider has been carefully compared to a legally marketed device with respect to intended use and technological characteristics. In addition, non-clinical testing was conducted to verify / validate the performance of the device and ensure the subject PolypVac Microdebrider functions as intended and meets design specifications. The comparison and non-clinical results demonstrate that the subject PolypVac Microdebrider is substantially equivalent to the primary predicate, the PolypVac Microdebrider (K161101), and the secondary predicate, the Medtronic Xomed XPS 3000 (K041413), for the updated indication described in this submission.