(199 days)
The Girgis Scope Video 200 Double Bladed Laryngoscope (GSV200.DBL) is indicated to improve direct visualization of larynx and assist in both non-complicated and difficult intubation of unpredictable airway condition.
GSV200.DBL is designed to assist in tracheal intubation procedure by direct visualization of laryngeal anatomy in closed position and use movable blade with camera as accessory from different angle in open position. The physical shape of GSV200.DBL is a modification of traditional Macintosh blade similar to Propper flip tip laryngoscope with added movable blade with camera as accessory to provide visualization to insert endotracheal tube.
Girgis Scope Video DBL is designed to use two power sources, one in the stationary handle for fiber optic illumination of the airway and the second in the DVR monitor to illuminate the Larynx for the video camera. Battery chargers, cables to computer and cable to connect to TV screen are accessories included in the kit. The GSV200.DBL is provided non-sterile and is reusable and can be disassembled to provide cleaning and disinfection.
The provided document is a 510(k) summary for the Girgis Scope Video 200 Double Bladed Laryngoscope (GSV200.DBL). It outlines the device's characteristics and compares it to a predicate device, concluding that it is substantially equivalent. However, it explicitly states, "No clinical studies were conducted." Therefore, it does not contain the information requested regarding acceptance criteria and a study proving the device meets those criteria with a specified performance, sample sizes, ground truth establishment, or expert evaluations.
The document primarily focuses on non-clinical performance data, which consists of adherence to various electrical safety and biocompatibility standards, and a simulated use/usability study.
Here's a breakdown of the available information and a direct statement about what is not present:
1. Table of acceptance criteria and reported device performance:
The document does not provide a table of acceptance criteria with corresponding device performance metrics from a clinical study. The conclusion section mentions that "the usability study demonstrated ease-of-use of the system," but no specific performance metrics or acceptance criteria for this usability are detailed.
2. Sample size used for the test set and the data provenance:
- Test set sample size: Not applicable, as no clinical efficacy study was performed. For the "Simulated Use/Usability study," the sample size is not specified, only the roles of the participants: Anesthesiologists, Emergency Room Physicians, and Emergency Medical Service (EMS).
- Data provenance: Not applicable for a clinical study. For the usability study, it's a simulated use, likely conducted in a controlled environment, not a retrospective or prospective study from a specific country.
3. Number of experts used to establish the ground truth for the test set and their qualifications:
Not applicable, as no clinical efficacy study was performed requiring ground truth established by experts.
4. Adjudication method for the test set:
Not applicable, as no clinical efficacy study was performed.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, and its effect size:
No MRMC comparative effectiveness study was done.
6. If a standalone performance study was done:
No standalone (algorithm only without human-in-the-loop performance) study was done, as this refers to a medical device, not an AI algorithm.
7. The type of ground truth used:
Not applicable, as no clinical efficacy study was performed.
8. The sample size for the training set:
Not applicable, as no AI algorithm was developed or trained.
9. How the ground truth for the training set was established:
Not applicable, as no AI algorithm was developed or trained.
Summary of Non-Clinical Performance Data (as mentioned in the document):
The device's performance is demonstrated through adherence to various industry and safety standards, rather than clinical efficacy studies. These include:
- Electrical Safety Standards: IEC 60335-1, IEC 60335-2-29, IEC 60950-1, IEC 60601-1, IEC 60601-1-2.
- Biocompatibility Standards: USP 24, NF 19 Biological Test for Plastics (Class VI 70 degrees C), ISO 10933-5 (in vitro Cytotoxicity), ISO 10993-10 (Irritation and Skin Sensitization - Kligman Maximization Test and Intracutaneous Injection Test), ISO 10993-11 (Systemic Toxicity), ASTM F 756-08 (Hemolytic Properties), ASTN F 619-03 (Extraction of Medical Plastics).
- Sterilization Standard: AAMI/ANSI ST79 (Comprehensive Guide to Steam Sterilization and Sterility Assurance in Health Care Facilities).
- Software Validation: "Software Validation per Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices."
- Usability Study: "A Simulated Use/Usability study was conducted using Anesthesiologists, Emergency Room Physicians, and Emergency Medical Service (EMS)." The conclusion states this study "demonstrated ease-of-use of the system," but no specific performance metrics or acceptance criteria for usability are provided in the document.
The core argument for substantial equivalence relies on the device's design and indications for use being "identical" or "similar" to the predicate device (Propper Flip-Tip™ Laryngoscope, K915804), coupled with adherence to the aforementioned non-clinical standards and the usability study.
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Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
June 22, 2017
Girgis Scope LLC % E. Smith Consultant Smith Associates 1468 Harwell Avenue Crofton. Marvland 21114
Re: K163412
Trade/Device Name: Girgis Scope Video 200 Double Bladed Laryngoscope (GSV200.DBL) Regulation Number: 21 CFR 868.5540 Regulation Name: Rigid Laryngoscope Regulatory Class: Class I Product Code: CCW Dated: May 23, 2017 Received: Mav 26, 2017
Dear E. Smith:
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 devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in
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the quality systems (OS) 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,
Mark S. Fellman -S
for
Lori A. Wiggins, MPT, CLT Acting Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control, and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known) K163412
Device Name
Girgis Scope Video 200 Double Bladed Laryngoscope (GSV200.DBL)
Indications for Use (Describe)
The Girgis Scope Video 200 Double Bladed Laryngoscope (GSV200.DBL) is indicated to improve direct visualization of larynx and assist in both non-complicated and difficult intubation of unpredictable airway condition.
| 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)
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510(K) Summary
| Sponsor | |
|---|---|
| Company Name: | Girgis Scope LLC |
| Company Address: | 2 Stonegate DriveMonroe Township, NJ 08831 |
| Telephone: | 1-732-710-9724 |
| Fax: | 1-732-605-1631 |
| Contact Person: | Madgy Girgis, M.D. |
| Summary Preparation Date: | June 22, 2017 |
| Trade Name: | Girgis Scope Video 200 Doubled Bladed Laryngoscope (GSV200.DBL) |
| Common/Usual Name: | Video Laryngoscope |
| Classification Name: | Laryngoscope Rigid Accessory |
| Regulation Code: | 21 CFR 868.5540 |
| Product Code: | CCW |
| Device Class: | Class I |
| Panel: | Division of Anesthesiology |
Predicate Device
| Manufacturer | Brand Name | Classification |
|---|---|---|
| Propper ManufacturingCompany, Inc. | Propper Flip-Tip™™Laryngoscope | K915804 |
Device Description
GSV200.DBL is designed to assist in tracheal intubation procedure by direct visualization of laryngeal anatomy in closed position and use movable blade with camera as accessory from different angle in open position. The physical shape of GSV200.DBL is a modification of traditional Macintosh blade similar to Propper flip tip laryngoscope with added movable blade with camera as accessory to provide visualization to insert endotracheal tube.
Girgis Scope Video DBL is designed to use two power sources, one in the stationary handle
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for fiber optic illumination of the airway and the second in the DVR monitor to illuminate the Larynx for the video camera. Battery chargers, cables to computer and cable to connect to TV screen are accessories included in the kit. The GSV200.DBL is provided non-sterile and is reusable and can be disassembled to provide cleaning and disinfection.
Indications for Use Statement
The Girgis Scope Video 200 Double Bladed Laryngoscope (GSV200.DBL) is indicated to improve direct visualization of larynx and assist in both non-complicated and difficult intubation in situation of unpredictable airway condition.
| Parameters | Girgis Scope LLC(K163412) | Propper ManufacturingCompany, Inc.(K915804) | Comments |
|---|---|---|---|
| Indications for Use | The Girgis Scope Video200 Double BladedLaryngoscope(GSV200.DBL) isindicated to improvedirect visualization oflarynx and assist inboth non-complicatedand difficult intubationin situation ofunpredictable airwaycondition. | Propper Flip Tip™laryngoscope isindicated to improvedirect visualization oflarynx and assist inboth non-complicatedand difficult intubationin situation ofunpredictable airwaycondition. | Identical |
| Type of Device | GVS200.DBL is amodification of thetraditional MacIntoshlaryngoscope.In addition to properdesign movable bladeand ratchet springholder are attached. | Propper Flip-Tip™Laryngoscope is amodification of thetraditional MacIntoshlaryngoscope. | Similar - Propper offersa flip tip at the distalend of thelaryngoscope blade andthe GSV200.DBL offersa second blade. |
| Design | Anatomically designedto improve visibility ofthe vocal cords andreduce teeth damage | Anatomically designedto improve visibility ofthe vocal cords andreduce teeth damage | Identical |
| Laryngoscope Flexi-Tipand Lever Control | Flexi-tip is adjustable to70 degrees usinglevering movablehandle to provide aprecise control toexpose the epiglottis. | Flexi-tip is adjustable to70 degrees usinglevering movablehandle to provide aprecise control toexpose the epiglottis. | Identical |
Predicate Product Comparison Table
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| Fiber Optic IntubatingLaryngoscope | Stationary handle forfiber optic illuminationof the mouth | Stationary handle forfiber optic illuminationof the mouth | Identical |
|---|---|---|---|
| Power Supply and LightSource | Stationarylaryngoscope handlecontaining a LithiumIon rechargeablebattery (3.7V).GSV200.DBL utilizes arechargeable battery topower light bulb andthrough their 5mmfibro-optic bundle toprovide bright whiteillumination. | Stationarylaryngoscope handlecontaining battery.Propper utilizes AA andC Batteries to powerlight bulb and throughtheir 5mm fibro-opticbundle to providebright whileillumination. | Predicate uses Cbatteries and theGSV200.DBL utilizes arechargeable battery |
| Sterilization | Pre-vacuum sterilizer132 degrees for 4minutes | Pre-vacuum sterilizer132 degrees for 4minutes | Identical |
| Laryngoscope Blades | Reusable | Reusable | Identical |
Discussion of Technological Characteristics
-
- Propper Flip-Tip™ Laryngoscope blade (K915804) and the GBV200.DBL Laryngoscope both have a flexible tip that is adjustable to 70 degrees using a levering system which includes a movable handle, tip and spring mechanism and both offer fiber optic illumination.
-
- Both devices are anatomically designed to improve visibility of the epiglottis and reduce teeth damage. Both devices provide a laryngoscope stationary handle containing batteries, Propper utilizes C Batteries and GBV200.DBL a rechargeable battery, to power light bulb through their fibro-optic bundle which provides bright white illumination.
- Both systems have a stationary handle and in addition to the Propper design the 4. GSV200.DBL uses a ratchet spring holder with a ball joint socket that locks the movable blade in closed position while introducing the two blades in patient mouth and unlocks to open position in step by step progression.
- In addition to the Propper laryngoscope design, GSV200.DBL uses the movable blade, which 5. is attached to the movable handle and articulates with stationary blade so movement in the movable handle is transmitted to the movable blade to:
- A. To create a pathway to introduce the endotracheal tube with ease
- B. The movable blade carries camera arrangement as accessory for indirect visualization of laryngeal anatomy in unpredictable difficult intubation. The camera angle will be looking upward and forward to show the most anterior position of larynx in difficult intubation
-
- Both offer a reusable Flexi-Tip style laryngoscope blade, both recommend pre-vacuum sterilization at 132°C for 4 minutes.
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Non-Clinical Performance Data
- IEC 60335-1 Corrigendum 1 Household and similar electrical appliances Safety Part ● 1: General Requirements
- . IEC 60335-2-29 Safety of household and similar electrical appliances - Safety - Part 2-29 Particular requirements for battery charges
- IEC 60950-1 Information technology equipment – Safety – Part 1: General requirements
- IEC 60601-1 + CORR 1 (2006) + CORR 2 (2007) + A1 (2012) Medical electrical equipment . Part 1: General requirements for basic safety and essential performance
- IEC 60601-1-2:2007 Medical electrical equipment Part 1-2: Collateral standard: Electromagnetic compatibility - Requirements and tests
- . USP 24, NF 19 Biological Test for Plastics, Class VI 70 degrees C
- . AAMI/ANSI ST79 Comprehensive Guide to Steam Sterilization and Sterility Assurance in Health Care Facilities
- . ISO 10933-5 Biological Evaluation of Medical Devices – Part 5: Tests for in vitro Cytotoxicity L929 MEM Elution Test
- ISO 10993-10 Biological Evaluation of Medical Devices – Part 10: Test for Irritation and Skin Sensitization Kligman Maximization Test
- ISO 10993-10 Biological Evaluation of Medical Devices – Part 10: Test for Irritation and Skin Sensitization Intracutaneous Injection Test
- ISO 10993-11 Biological Evaluation of Medical Devices – Part 11: Tests for Systemic Toxicity
- ASTM F 756-08 Standard Practice for Assessment of Hemolytic Properties of Materials
- ASTN F 619-03 Standard Practice for Extraction of Medical Plastics
- A Simulated Use/Usability study was conducted using Anesthesiologists, Emergency Room Physicians, and Emergency Medical Service (EMS).
- . Software Validation per Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices
Clinical Study
No clinical studies were conducted.
Conclusion
The Girgis Scope Video 200 Double Bladed Laryngoscope model (GSV200.DBL) has the same indications for use, flexible tip design, fiber optic bundle for lighting, laryngoscope blade design, laryngoscope handle design, same methods of sterilization, and similar nonclinical testing and are battery operated as the Propper Flip-Tip Laryngoscope (K915804). The DVR accessory improves visualization of the epiglottis and the usability study demonstrated ease-of-use of the system. Based on the similarities of the two laryngoscope systems no different questions of safety and effectiveness have been raised and we conclude that our laryngoscope system is substantially equivalent to the predicate laryngoscope system.
§ 868.5540 Rigid laryngoscope.
(a)
Identification. A rigid laryngoscope is a device used to examine and visualize a patient's upper airway and aid placement of a tracheal tube.(b)
Classification. Class I (general controls). The device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 868.9